Comment Submitted by jim zhou

Re: Proposed rule, docket reference USCIS-2026-0166-000, regarding immigration benefit requests and the validity of signatures contained within While the commenter is glad to see that finally after three decades the prophetic words of third grade teachers in American elementary schools that "one day you will use cursive since they will make you sign everything by hand so you better practice now" is, at last, being given the veneer of truth and absolving three decades of jokes about the seriousness repeated year after year thence through graduation from high school, to validate what had been widely acknowledged as a requirement considered outdated and sufficiently outlandish to be a joke by generations of students is a poor reason, not to mention well beyond the remit of USCIS or any other agency, to impose a legal requirement that serves little purpose beyond the needless burden that technology had long made irrelevant. It is, additionally, a fool's errand considering that USCIS is an agency that primarily interfaces with non-Americans (attorneys that work in the field are likely the only consistent American-educated and licensed population that handles such requirement on a regular basis, which informally judging by attendance at AILA conventions is a numerous but still niche number of legal practitioners compared to even the legal practitioner community writ large). In an age when large swaths of matching-based "science" have been found to be wholly fraudulent in cases far more consequential even after attestation from "experts" who would swear at Daubert or Frye hearings of the validity of their craft only for more reliable and replicable scientific endeavors to disprove their expertise wholesale, the USCIS seems intent on recreating its own version of this antiquated exercise that would certainly end up with the same result - errors, delays, humiliation in the form of formal rejections in a world dictated by the holding in Loper Bright without reliance on Chevron and other blanket deference given judicially. It also, without stating outright, seems to repudiate the adequacy of technology long available in America in the ability for companies to create software solutions that can affix digital signatures with consistency, which does not reflect either the state of technology or the abilty for the legal and programming communities here to create such solutions that have so far been so widely accepted that agencies like the IRS readily accept digital signatures, and significant and well known private sector corporations that routinely require attestations in the format of a signature, ranging from contracts to buy or sell collectable works worth thousands to millions of dollars at auction houses like Christie's and Sotheby's, who now use the likes of Docusign - which is just one of many competing solutions - that attest to the validity of contracts daily involving transactions involving unique and valued close to budgets appropriated by congress to agencies such as the USCIS. A single auction, routinely ran, and compliant with federal and state laws and contains signatures for the contract between the consignor and consignee as well as the I-9 form, requires over six hundred signatures, all digital, for around 300 lots, all of which are varieties of rare, quality liquor. At the time of writing the estimated hammer price is well over a million dollars for the lot in the aggregate. The USCIS' 57 page fee schedule currently posted shows one fee in the six digits - imposed without APA procedures and conveniently a round number that any practitioner would likely characterize as arbitrary, capricious, and procedurally deficient in its placement. The second highest stated fee is $4500. Placing a firm number on the financial value of a benefit being subjective and needless, just the out-of-pocket cost required by USCIS even on its high end are trivial compared to hammer prices reached by a heavily regulated industry running heavily regulated auctions. In fact, with 96 hours to go, when premiums for buyers and sellers are added, a competitive bidding process have already, on the free market, outpaced the whole number created by the executive that can only be interpreted as "an outlandishly high amount", except it isn't. USCIS' processing procedures have erred on the side of security and have worked so far. If auction houses staffed full of authenticators whose job involves authenticating everything imaginable including signatures are fine with digital signatures, it is frankly hubristic and lurid to think that staff without said experience should be tasked to do work that would only have one effect: needlessly make the agency less efficient, for no logical reason but the whims likely from staffers who have not practiced law in the area or even attended law school. Manifesting is not a valid reason to enact procedure. There's no wishful thinking standard, and there can't be one. Why insult our tech adequacy?