Patent Office pushing for permanent rule changes before administration change

&gt; <i>The Office already has received input from stakeholders on the Office policies discussed above and on use of the Office&#x27;s discretion in institution of an AIA trial ... Among other things, stakeholders have indicated that the Office&#x27;s use of discretion as outlined above helps to ensure that (a) AIA proceedings do not create excessive costs and uncertainty for the patent owner and the system</i><p>(this proposal helps to prevent) &quot;excessive costs and uncertainty for the patent owner&quot;... yah, what a shame that a wrongfully&#x2F;improperly granted patent could be overturned.

&gt; If the new rules pass, a patent that survives one IPR [patent appeal&#x2F;review] may never have to face another<p>Will this lead to all patent holders appealing their own patent, deliberately losing the appeal, and then being able to peruse others with frivolous claims knowing that it can&#x27;t be appealed again?

I&#x27;m surprised this isn&#x27;t codified in the law instead of left up for administrative regulation.