title "Patent Attorney" may also be used by solicitors provided that they have specialist expertise in patents, whereas the term "Patent Agent" relates to persons who have passed the relevant specialized examinations. Qualification is achieved by passing the PEB patent foundation level papers (or gaining an exemption by passing certain university courses such as that organised by Queen Mary University in London) and then the PEB patent advanced level papers. The PEB patent foundation papers are FC1 (formerly P1) - UK Patent Law and Procedures, FC2 (formerly "Law") - Basic English Law, FC3 (formerly P5) - International Patent Law, FC4 (formerly "D&C") - Designs & Copyright, FC5 (formerly P7) - Trade Mark Law. The PEB patent advanced papers are FD1 (formerly P2) - Patent Practice, FD2 (formerly P3) - Drafting a Patent Application, FD3 (formerly P4) - Amending a Patent Application and FD4 (formerly P6) - Infringement and Validity of a Patent. Exemptions from FD2 and FD3 can be obtained by passing the corresponding European Qualifying Exams (Papers A & B respectively). Membership of the Chartered Institute of Patent Attorneys as a Fellow gives the right to call oneself a Chartered Patent Agent or Chartered Patent Attorney. (To be elected as a Fellow, a person must have passed the UK Advanced Level exams, have accrued sufficient professional experience and be nominated by two existing Fellows). United States In the United States, a practitioner may either be a patent attorney or patent agent. Both patent attorneys and patent agents have the same license to practice and represent clients before the United States Patent and Trademark Office (USPTO). Both patent agents and patent attorneys may prepare, file, and prosecute patent applications. Patent agents and patent attorneys may also provide patentability opinions, as noted by the U.S. Supreme Court in Sperry v. Florida. In the time since the USPTO issued the first patent in 1790, approximately 73,000 citizens have passed the USPTO registration examination, allowing them to register to prosecute patent applications. (This total does not include current patent examiners, who are not allowed to serve as patent attorneys or agents and thus do not appear on the list of enrolled practitioners.) Today, roughly 45,000 people are on the list of registered patent attorneys and agents, with slightly less than 34,000 of them also licensed to practice law. Of the states, California has the most patent attorneys (and agents), followed by New York