USPTO Overhauls Security and AccessRole-Based Authorization and Enhanced CAR Form Process
Alt Legal Team | July 23, 2025
During a recent USPTO webinar “USPTO Hour: Trademark Change Address or Representation authorization updates,” featuring USPTO representatives Jason Lott, Managing Attorney, Trademarks Customer Outreach and Matt Schwab, Senior Legal Administrator for Trademarks Technology and Systems, trademark practitioners and brand owners received in-depth updates about the USPTO’s evolving strategy to address fraud, streamline filings, and improve the security and transparency of trademark records. The central themes included: combating rampant trademark application hijacking and unveiling new role-based account controls, including updates to the Change Address or Representation (CAR) form.
Why Hijacking Has Become a Growing Threat
Trademark fraud wasn’t always so pervasive. In earlier years, the trademark process offered little incentive for abuse. But the landscape has shifted dramatically. Factors such as brand registries on e-commerce platforms, increased IP awareness, and a surge in filings from small businesses and entrepreneurs have inadvertently opened the door for scammers. These bad actors are now actively targeting the trademark system to skim money and hijack applications.
Over just the past year, the USPTO has confirmed:
- 15,000+ cases of attorney credential theft
- 1,000+ fraudulent CAR forms submitted each week (prior to ID verification rollout)
- High-volume filings from questionable accounts (1,500+ filings over two days from just three accounts)
The Scammer Playbook: Tactics in Use Today
Fraud isn’t limited to stolen identities. The USPTO has flagged several sophisticated schemes, including:
- Fake websites offering low-cost IP services, then stealing verified ID documents to create fraudulent accounts.
- Applications mimicking well-known brands, using similar marks and lookalike email addresses (e.g., switching to Gmail or Outlook addresses to fly under the radar).
- Impersonation of USPTO officials, offering fake consultations and requesting action on behalf of applicants.
- Bad-faith express abandonments—a malicious way to remove genuine owners from the record temporarily.
Scammers have even adapted to ID verification by recruiting victims to unknowingly verify accounts that the fraudster ultimately controls.
The Solution: Role-Based Access and Account Protections
To restore integrity and trust, the USPTO has implemented a three-phase protection system:
- Phase 1 (2019): Two-factor authentication at login.
- Phase 2 (2022): ID verification for all account holders.
- Phase 3 (2025): Role-based access—live now.
With this final phase, each user’s role (e.g., attorney, owner, support staff) determines their level of access and what actions they can perform. For example:
- Pro se owners won’t be able to access bulk filing tools.
- Attorneys can manage complex dockets and supervise support staff through structured permissions.
- Support staff must be sponsored by attorneys and explicitly verified.
This structure supports both security and convenient collaboration while protecting against misuse.
Big Update: Revamped CAR Form Process Now Live
A major highlight of the webinar was the launch of a new CAR form on July 17, 2025, which enables a client to revoke and appoint an attorney in one submission. This change resolves confusion around whether new attorneys needed permission from the previous representative (they don’t).
How it works:
- New attorneys can initiate the form.
- A request for authorization is sent directly to the trademark owner.
- The owner has 48 hours to approve or reject the change.
- If approved, the new attorney’s representation is established immediately.
If you’re on good terms with a previous attorney, you may still include them in the process—but it’s not required. This single-step form simplifies transitions and enhances transparency.
Good to know:
- Signature options include e-signature and PDF.
- The form now triggers additional authorization only in cases where there’s a mismatch between account data and the application record.
- Most attorneys will not encounter the additional authorization flow—preliminary data indicates it affects fewer than 20% of users.
- If the owner is the one submitting the CAR form themselves via their own MyUSPTO account, they generally won’t encounter additional authorization. The form recognizes their ownership.
Questions Answered: Common Scenarios and What to Do
What happens if the owner signs the CAR form?
If there’s a match between the owner’s MyUSPTO account and the application record, no additional authorization is triggered.
What if you’re representing a foreign-domiciled client?
You can now revoke and appoint in the same form—even in cases where a U.S. attorney is required—thanks to the July 17 update. This update solves the two-step challenge foreign clients faced before, where they couldn’t complete the process without a U.S. attorney.
What if your client is unreachable or has an outdated email?
The USPTO recommends two-step submission (revocation by the client, followed by appointment by the attorney) or contacting TEAS at teas@uspto.gov for assistance.
What if the case is abandoned?
If the application was abandoned less than six months ago, you can file a Petition to Revive. Beyond six months, a new application is needed. Be cautious of scams falsely promising revival in expired cases—fraudsters are exploiting this exact situation.
How are dockets affected?
Currently, cases remain in an attorney’s docket even if their representation is revoked. Future updates will include shared docket views and more advanced docket management options.
What about TTAB and attorney records?
TSDR and TTABView systems don’t currently sync in real time, but USPTO is working toward better integration. For now, appearance filings in TTABView will not instantly update TSDR.
What to do if fraud is blocking your application?
A Letter of Protest may be appropriate in cases where specimens appear fake or copied (e.g., altered stock photos or reused brand images). For registrations, consider a Petition to Cancel or Notice of Opposition before the TTAB. In some cases, expungement or reexamination may apply—especially for non-use-based issues.
Final Reminders
- The agency continues to refine its security tools and user experience, even as it juggles complex systems like Trademark Center, TTAB Center, and TEAS.
- Additional authorization will likely evolve—timelines may be adjusted based on feedback (the current 48-hour window is the upper limit of typical industry standards).
- If you encounter unexpected behavior or are unsure about a process, the USPTO encourages direct communication via teas@uspto.gov.
Looking Ahead
Trademark Center is on track to support additional forms and workflows—including correspondence and response filings—later this year. While things may still feel segmented across systems, the end goal is a centralized, secure, and streamlined experience for trademark professionals and business owners alike.
For now, staying informed and maintaining up-to-date, accurate contact information is one of the best ways to protect your clients and your practice from fraud and filing disruption.