Carol Spils
`Trademark Examining Attorney
`Law Office 104
`Commissioner for Trademarks
`P.0. Box 1451
`Alexandria, VA 22313-1451
`
`78/699926
`Serial No.
`August 24, 2005
`Filing Date:
`TENDERFEETSHOES DIABETIC FOOTTNEAR & Design
`Mark:
`BGizunt, lnc.
`Applicant:
`March 20, 2006
`Office Action:
`818-991-4001
`Applicant Phone:
`Applicant Zip Code: 91301
`Applicant E-mail:
`bob@bgizunt.com
`
`Ream. ,0, R,c°,,sid,,afi°,, of Fina, M0,,
`and Amendment to Identification of Goods
`
`llllllllllllllllllllllllllllllllllllllllllllllll
`
`03-12-2007
`U.S. PiHK&TMOl:lTM Mal Ram K!)
`
`The Applicant, pursuant to 37 CFR (52.64 (b), intends to file a notice of appeal to
`the Trademark Trial and Appeal Board. However. since the evidentiary record in
`an application should be complete prior to filing an appeal, the Applicant is
`supplying additional evidence to support its conclusion that there is no likelihood
`of confusion between the Applicant's and Registrant's marks. Additionally, in
`order to clearly establish that the Applicant's goods should be regarded as
`professional products. the Applicant wishes to clarify and limit the identification of
`goods pursuant to Trademark Rule §2.71 (a). We hereby request the Examining
`Attorney reconsider our arguments in light of this new evidence and amended
`description.
`
`I. Comparison of the Goods
`
`Attached to the Examining Attorney's second Office action dated October 12,
`2006 were 47 third-party registrations which ostensibly suggested that the goods
`listed therein, namely footwear (shoes) andlor inserts or inner soles are of a kind
`that may emanate from a single source. While that may be so, we don't see its
`relevance to the present case because. as we stated on the very first page of our
`prior response: “In this case, the goods are at least in part related - orthotic
`inserts for footwear and orthopedic inner soles. ..” While we agree that several
`
`

`
`(2)
`
`Serial No. 78/699926
`Law Office 104
`
`Carol Spils
`
`manufacturers produce orthopedic footwear as well as orthotic inserts (as we do
`ourselves), we view the proof of that relationship as moot since we have already
`admitted the relationship of the Applicant's and Registrant's products.
`Additionally, the Registrant has not claimed orthopedic footwear as part of their
`recitation.
`
`This large number of registrations does raise an interesting question, since the
`vast majority of them — 35 out of 47 — are for Class 025 (clothing) items and have
`nothing to do with custom made orthotic inserts which are, as describedin our
`prior response, medical devices which deal with the prevention or correction of
`joints and ligaments. See attached definitions for the terms orthopedic and
`orthotic taken from Dictionarycom and the American Heritage Dictionary
`[EXHIBITS 1 and 2].
`
`It is the Applicant's contention that although its product is obviously similar to the
`product of the cited Registrant, the fact that each individual insert is exclusively
`made for an individual patient, the prescribing doctor (the actual customer in the
`supply chain) views and evaluates the product in terms of how well it conforms to
`his prescription. This is not a case where two low price products, used for the
`same or similar purposes, are marketed side by side in a supermarket and
`purchased with a minimum of care. Rather, in the present case, the goods are of
`a highly technical nature and are custom made appliances. They are purchased
`with a high degree of care as we shall describe in a later section.
`
`II. Amendment to Identification of Goods
`
`In order to make clear that the Applicant's goods are intended as therapeutic
`medical devices, the Applicant offers the following amendment to the
`identification of goods:
`
`Please substitute the following identification for that given previously:
`
`Prescription orthopedic footwear; Prescription orthotic inserts
`for footwear in International Class 010.
`
`

`
`(3)
`
`’
`
`Serial No. 78/699926
`Law Offlce 104
`
`Carol Spils
`
`lll. Weakness of the Marks
`
`The Examining Attorney has pointed out that the terms TENDERFEET and
`TENDERFOOT are clearly the dominant element in the Applicant's and
`Registrant's marks. We agree with this analysis but we need to emphasize that
`in relation to the goods at hand, the term TENDERFOOT is a weak and highly
`suggestive expression. Whether a tenn is suggestive is determined not in the
`abstract, but in relation to the goods for which registration is sought and the
`context in which it is being used in connection with those goods. According to
`the American Heritage® Dictionagg of the English Language, the meaning of the
`term “tender” is:
`
`1 a. Easily crushed or bmised; 5a. Easily hurt; sensitive;
`5b. Painful; sore
`[EXHIBIT No. 3]
`
`Thus, a tender foot is a sensitive, sore and painful condition that is addressed by
`orthotic inserts which are commonly used to treat such conditions. When a term
`has a well known and particular significance in an industry, it is considered as a
`suggestive tenn. [See United States Shoe Corp. v. Chapman, 229 USPQ 74
`(TTAB 1985) at 75.]
`
`As additional evidence of the connection between the terms “tender feet” and
`"orthotic inserts" to which the public has been exposed, we present six articles
`taken from the popular press [see EXHIBITS No. 4 through 9]. These articles
`were found on the LexisNexis Academic database under the categories of
`Medical and Health News as well as the general category of U.S. News.
`
`The evidence shows that sore and tender feet are a common condition and that
`orthotic inserts are frequently prescribed to remedy this problem. According to
`the National Center for Health Statistics, 76% of Americans have foot problems.
`[Exhibit 4] The articles go on to say that prescription orthotic devices typically
`work more effectively than off-the—she|f inserts found in stores. [Exhibit 5] Also
`mentioned in these articles are the special foot problems encountered by
`diabetics and the pain and sensitivity that they endure. [Exhibit 6]
`
`

`
`(4)
`
`Serial No. 78/699926.
`Law Office 104
`
`Carol Spils
`
`A portion of a mark may be weak in the sense that such portion is highly
`suggestive or is in common use by many other sellers in the market.
`In our
`previous response to the first Office action, we pointed out that the electronic
`records of the USPTO contain seven active registrations or applications where
`the term “TENDERFOOT” is used in connection with goods or services related to
`care of the feet. Although third-party registrations, by themselves, are entitled to
`little weight on the question of likelihood of confusion, they can be probative as to
`the meaning of a mark or part of a mark:
`
`“[Third-Party registrations] are, however, competent to establish that a
`portion common to the marks involved in a proceeding has a normally
`understood and well known meaning; that this has been recognized by the
`Patent and Trademark Office by registering marks containing such a
`common feature for the same or closely related goods where the
`remaining portions of the marks are sufiicient to distinguish the marks as a
`whole; and that therefore the inclusion of [the common element] in each
`mark may be an insufficient basis upon which to predicate a holding of
`confusing similarity. " [See American Hospital Supply Corporation v. Air
`Products and Chemicals, Inc., 194 USPQ 340 (TTAB 1997) at 343]
`
`See also Tetronix, Inc. v. Daktronics, Inc., 189 USPQ 693 (CCPA 1976) where
`the Court of Customs and Patent Appeals stated:
`
`“Because marks, including any suggestive portions thereof, must be
`considered in their entireties, the mere presence of a common, highly
`suggestive portion is usually insufficient to support a finding of likelihood
`of confusion. "
`
`We also find in a recent decision of the Trademark Trial and Appeal Board --
`In re Box Solutions Corp., Serial No. 76267086, 'lTAB May 23, 2006:
`
`“The connotation of the marks, derived from the common word BOX,
`implying computer, is similar, but applicant's mark has a slight variation
`due to the additional word SOLUTIONS which creates a difierence in
`sound. Overall, we find the differences outweigh the similarities given the
`weakness of the common element.”
`
`

`
`(5)
`
`Serial No. 78/699926
`Law Office 104
`
`Carol Spils
`
`One of the key factors in determining whether there is a likelihood of confusion
`between two marks is “The number and nature of similar marks in use on similar
`goods.” In The Matter of The Application of E.l. DuPont DeNemours & Co. 177
`USPQ 563 (CCPA 1973). [DuPont Factor No. 6] This factor is actually an
`inquiry into the strength or weakness of the opposing mark in question. The
`Examining Attorney's conclusion that there is a likelihood of confusion is based
`on the premise that the cited mark and the Applicant's mark both contain the
`“dominant" wording TENDERFOOT or TENDERFEET. Inherent in this premise
`is the assumption that the wording TENDERFOOT is both strong and distinctive.
`However. the Applicant submits additional evidence to show that the opposite is
`true. This additional evidence consists of web pages taken from several of the
`third-party registrants indicating that the marks are in current use and could well
`be familiar to consumers of these products. [See EXHIBITS No. 10 through 13]
`
`The highly suggestive nature of the term TENDERFOOT towards orthotic
`appliances renders this term to have little source identifying power.
`In situations
`like this, purchasers distinguish slight differences among the marks under
`consideration.
`In the present case, the marks are fairly distinct from each other,
`certainly in terms of appearance and sound as was discussed in our response to
`the first Office action. We would also draw the Examining Attorney's attention to
`the letters attached to our first response from the doctors who purchase the
`Applicant's orthopedic shoes and orthotic inserts.
`In all cases, those customers
`refer to the Applicant as “Tenderfeetshoes” or “Tenderfeet Shoes." It is clear
`from this evidence that the term “SHOES” is viewed as an integral part of the
`Applicant's mark. Undoubtedly, these customers are more likely to rely on the
`additional elements in the Applicant's mark, including its design feature of a
`shoe, to select their desired source for orthopedic shoes or orthotic inserts.
`
`Applicant appreciates that a "word mark" registration is not limited to any
`particular design, and thus could possibly be used with a design closely
`resembling the one chosen by the Applicant. However, the Lanham Act “does
`not talk in terms of remote possibilities of confusion but, rather, the likelihood of
`such confusion occurring in the marketplace.” [See Triumph Machinery Co. v.
`Kentmaster, 1 USPQ2d 1826 (TTAB 1987)]
`
`

`
`(6)
`
`Serial No. 78/699926
`Law Office 104
`
`Carol Spils
`
`Although weak marks are entitled to some degree of protection from registration
`of another confusingly similar mark, we do not believe that the marks under
`consideration are confusingly similar. As was pointed out in the case of In re Lar
`Mor International, Inc., 221 USPQ 180 (TTAB 1983) at 181:
`
`“Moreover, such similarity as there is in connotation must be weighed
`against the dissimilarity in appearance, sound, and all other factors, before
`reaching a conclusion on likelihood of confusion as to source.”
`
`When these other factors are taken into account, the Applicant's mark
`TENDERFEETSHOES DIABETIC FOOTWEAR & design is not likely to cause
`confusion with the cited mark.
`
`Case law supports the Applicant's position that when the dominant wording is so
`highly suggestive of the recited goods, the possibility of confusion is greatly
`diminished.
`In determining that BOND-PLUS and WONDER BOND PLUS, both
`for adhesives were not confusingly similar, the Board held that:
`
`“Despite certain obvious similarities in appearance, sound and connotation
`(i. e. the fact that opposer's mark “BOND-PLUS” is completely
`encompassed within applicant's “WONDER BOND PLUS” mark, the latter
`differing only by addition of the somewhat laudatory prefix term
`“WONDER'), the Board does not believe that contemporaneous use of
`these marks would be likely to cause confusion or mistake. This is
`primarily because opposer's “BOND-PLUS” mark is so highly suggestive
`of adhesive products that it may be regarded as a "weak" mark such that
`addition of other matter, even of a suggestive or laudatory character,
`would in ourjudgment be capable of distinguishing “BOND-PLUS” from
`other adhesive marks in the minds of the consuming public. " [See
`Industrial Adhesive Company v. Borden, Inc., 218 USPQ 945 ('l‘|'AB
`1983n
`
`.
`
`As a final point, in all of the above analysis, the standard of care assumed was
`that of an ordinary purchaser exercising ordinary care. However, as we shall see
`in the next section, the appropriate standard of care for the present case should
`be that of a discriminating purchaser exercising a high degree of care.
`
`

`
`(7)
`
`Serial No. 78/699926
`Law Office 104
`
`Carol Spils
`
`IV. Sophisticated Purchasers and the Degree of Discrimination
`
`(a). Analysis of Purchaser Class
`
`The fourth DuPont‘ factor deals with “the conditions under which and buyers to
`whom sales are made, i. e. “impulse” vs. careful, sophisticated purchasing.” It is
`important to note that in the present case, sales of the described goods are made.
`directly to podiatrists and medical foot care specialists and not to the general
`public.
`In this regard, the trademark or brand name is not carried with the
`product through to the end purchaser, so that the doctor's patients are not likely
`to encounter the Applicant's mark. This situation is analogous to the case of
`Albert Trostel & Sons Co., 29 USPQ2d 1783 (‘ITAB 1993):
`
`"What is missing from the record is convincing evidence that finished
`products of this nature commonly cany not only the trademark of their
`manufacturer but also the trademark of the producer of the leather from
`which they are made."
`
`McCarthy on Trademarks and Unfair Competition states that where the buyers
`are composed solely of professional or commercial purchasers, it is reasonable
`to set a higher standard of care than exists for consumers? In our response to
`the first Office action, we listed five cases where the courts and the Board found
`that sophisticated purchasers would be expected to exercise a high degree of
`care in making their purchasing decisions:
`
`A. Accuride lntemational, Inc. v. Accuride Corporation, 871 F.2d 1531
`(9th Cir. 1989)
`
`B.
`
`In re Software Design, Inc., 220 USPQ 662 (‘ITAB 1983)
`
`C. GB Electrical, Inc. and Applied Power Inc. v. Thomas & Betts
`Corporation, 37 USPQ2d 1177 (E.D. Wis. 1995)
`
`D. Perini Corporation v. Perini Construction, lnc., 915 F.2d 121 (4th Cir.
`1990)
`
`E. Electronic Design & Sales, Inc. v. Electronic Data Systems
`Corporation, 954 F.2d 713 (Fed Cir. 1992).
`
`-
`
`‘ In the Matter of the Application of E.l. DuPont DeNemours & Co., supra
`2 J. Thomas McCarthy, McCarthy on Trademarks and Unfair Competition § 23:101 (4th ed.)
`
`

`
`(3)
`
`' Serial No. 78/699926
`Law Office 104
`
`Carol Spils
`
`In the present case, where the relevant buyer class is composed of medical
`professionals, further cases have been located which specifically cite these
`professional’s ability to distinguish the source of the goods from among suppliers
`with marks that resemble each other. Some of the following cases fall into that
`
`category:
`
`In the case of Barre-National Inc. v. Barr Laboratory, Inc. 21 USPQ2d 1755
`(D.N.J. 1991) where the marks were BARRE and BARR respectively, the District
`Court stated that:
`
`“Some buyer classes, such as professional buyers or consumers of very
`expensive goods, will be held to a higher standard of care than others.
`Since persons who order generic pharmaceuticals from the manufacturer
`includes only industry professionals, such as pharmacists and dmg
`wholesalers, the buying class could be expected to exercise a high
`standard of care. ” [internal citations removed]
`
`In Blue Bell Bio Medical v. Cin-Bad, |nc., 9 USPQ2d 1870 (5th Cir. 1989), the
`Court of Appeals stated the following:
`
`“The district court employed this digits (sic) of confusion analysis. The
`court focused on three critical factors in finding no likelihood of confusion
`between the Blue Bell and CBi products. First, the court noted that a
`medical cart is a major piece of equipment bought by medical
`professionals who are likely to exercise a high degree of care in
`purchasing them.”
`
`Similarly in Astra Phannaceutical Products, Inc. v. Beckman Instruments, Inc.,
`220 USPQ 786 (1st Cir. 1983) where the marks in question are both ASTRA, we
`quote:
`
`"Perhaps the mostcritical factor that weighs against Astra in our
`consideration of this issue is the sophistication of the class of prospective
`purchasers of the subject products.
`If likelihood of confusion exits, it must
`be based on the confusion of some relevant person; i. e., a customer or
`purchaser. And there is always less likelihood of confusion where goods
`are expensive and purchased after careful consideration.”
`
`

`
`(9)
`
`Serial No. 78/699926
`Law Office 104
`
`Carol Spils
`
`.
`
`Finally, in the case of In re Digirad Corp., 45 USPQ2d 1841 (TTAB 1998), where
`the marks under consideration are DIGIRAD and DIGIRAY, the Board found:
`
`. .that the purchasers of such equipment, doctors and directors of
`hospital diagnostic imaging departments, are very knowledgeable with
`respect to these goods; and that such purchases, which involve extensive
`discussions between seller and buyer, are taken with great care and
`consideration. ”
`
`(b). Level of Interaction Between Buyer and Seller
`
`In all of the above cases, it was recognized that professional purchasers
`generally, and medical professionals in particular, are expected to exercise great
`care and deliberation when selecting a source for their goods and services.
`It is
`the Applicant's contention that there is still a further subset" of medical
`professionals wherein the relationship between the buyer and seller is more in
`the nature of a partnership.
`
`In the response to the first Office action, we detailed the process which the foot
`care specialist and the perdorthic supplier use to insure the orthotic inserts and
`orthopedic footwear confonn to the impressions taken by the doctor for each
`individual patient. An alliance is needed between these two specialties to affect
`a satisfactory end result. There are extensive discussions between the doctor
`and the laboratory since great care and skill are required at each step to produce
`an appliance which has the correct fit and function.
`
`Another example of this type of relationship would be between a dentist and his
`dental laboratory who are involved in providing prosthodontic appliances such as
`crowns and bridges.
`In the same way, the dentist must send exact impressions
`to the laboratory. At the lab, the dental technician uses his arts and skills to
`fabricate a crown or bridge that will exactly ft the preparation made by the
`dentist. Again there are extensive discussions required between the dentist and
`the dental laboratory.
`
`

`
`(10)
`
`Serial .No. 78/699926
`Law Office 104
`
`Carol Spils
`
`When the level of interaction between buyer and seller becomes one of a close
`knit partnership, there can be no confusion regarding source. We have only
`found a few cases that discuss the consequence that a high level of interaction
`imposes on dispelling a likelihood of confusion. One such case was that of In re
`Digirad Corp., supra where the Board found:
`
`“. ..that such systems are custom-designed to meet the needs of the buyer
`and that extensive discussions and negotiations are necessary due to
`both the complexity of the technology and the high cost of the equipment.”
`
`We also found some similarities to this situation in the case of General Controls
`‘Co. v. H|—G. Inc, 136 USPQ 570 (D.Conn. 1962) where the court stated:
`
`“Much of the defendant's business is initiated byjoint cooperation between
`the buyer and the defendant in the development ofparticular relays
`specially made to comply with technical specifications often requiring the
`defendant to make up and furnish samples for test purposes before
`production runs are set up. The defendant's relays are not found on the
`shelves of any retail store. .. This is a stronger case than Federal
`Telephone & Radio Corp. v. Federal Television Corp., 180 F.2d 250 (2nd
`Cir. 1950) for finding, both as to the actual products and the source of the
`products that
`. .confusion would not extend to those of the plaintiffs
`customers who are manufacturers, for such buyers know the persons with
`whom they deal ...””
`
`For a description of the rolls played by both the pedorthics supplier and that of
`the prescribing physician in the process of supplying orthopedic footwear and
`orthotic inserts. see the attached evidence [EXHIBIT 14 —Pages 1 through 5]
`taken from the website of the Pedorthic Footwear Association at the web address
`of httg:/lwww.pedorthics.org.
`
`

`
`(1 1)
`
`Serial No. 78/699926
`Law Office 104
`
`Carol Spils
`
`(c). Decombe and Pellerin Milnor Do Not Apply
`
`The Examining Attorney has cited the cases of In re Pedro Ruiz—Tagle Decombe,
`9 USPQ2d 1812 (‘ITAB 1988) and In re Pellerin Milnor Corporation, 221 USPQ
`558 (TrAB 1983) to indicate that purchasers who are sophisticated or
`knowledgeable in a particular field are not necessarily knowledgeable in the field
`of trademarks or immune from source confusion. The Applicant objects to the
`use of these cases as a bar to registration of its mark because of the different
`circumstances between those cases and our own. Not only are the type of
`purchasers different but also there is a great difference in the need for careful
`purchasing decisions.
`
`In Decombe, the Board made it clear that the buying class of the applicant's
`claimed goods not only consisted of purchasing agents and distributors of fresh
`produce, but also included the end consumer. That is because there was good
`evidence of a trend in the produce business to place labels on the produce itself
`like in the instance of CHIQUITA, SUNKIST and DOLE. The Board pointed out
`that:
`
`“None of these arguments changes the ultimate fact that trademarked
`produce has and increasingly does appear alongside the unmarked
`species and that information relating to this situation is readily available to
`consumers. Moreover, the fact that a number of fresh fruits and/or
`vegetables are cun'entIy being marketed by brand name cannot have
`escaped the attention of even the most casual shopper.”
`
`So the Decombe case consists of a mixed buyer class and should not be
`compared to a situation where the buyer class consists solely of professional
`buyers. Additionally, the goods in Decombe were fruits and vegetables which
`can hardly be considered as a technically complex product or one that is custom
`made for the buyer.
`
`in the Pellerin Milnor case, admittedly the products are expensive and of a
`technical nature. The applicant desired to register the mark MILTRON for a
`microprocessor for controlling a commercial laundry machine and was refused
`registration based on the registered mark MILLTRONICS for electronic control
`devices for regulating the operation of machinery. The Board considered the
`minor difference in the marks to be a primary reason for potential confusion.
`
`

`
`(12)
`
`Serial No. 78/699926
`Law Office 104
`
`Carol Spils
`
`The Board did acknowledge that “the goods before us are expensive equipment
`items not likely to be purchased without great care or by other than technically
`knowledgeable people.” So the reason this case went against Pellerin Milnor
`was that there was virtually no distinction between the marks:
`
`“The essential sight/sound difference between the two marks lies in the
`final syllable "ICS" of applicant's mark. We consider this of minor import
`as a distinguishing element. The Board has frequently found likelihood of
`confusion from use of marks on related technical products which were
`essentially the same but for the presence of a brief and relatively common
`suffix on one of the marks."
`
`In fact, in almost all the cases which ran afoul of the sophisticated purchaser
`argument, the marks were either identical or very highly similar (see discussion
`on page 9 of the Applicant's response to the first Office action).
`In the present
`case, we do not believe the mark similarity reaches to the level of similarity in
`Pellerin Milnor.
`
`Finally, as we pointed out in the previous section, the Applicant's customers are
`podiatrists or medical foot care specialists. They are ultimately responsible for
`the performance of the orthotic inserts and orthopedic shoes. Their professional
`reputations are on the line so you know they will be highly discriminating and
`careful purchasers of these products and will not be confused as to their source.
`
`V. Signed Declarations from Professional Purchasers
`
`In our previous response to the first Office action, we supplied letters from Dr.
`Neil H. Hecht, D.P.M., Dr. Sanford J. Weitzbuch, D.P.M., and Dr. Peter Akerele
`which documented the close relationship they maintain with the Applicant in
`order to procure diabetic shoes and custom molded inserts in their various
`practices. Each of the doctors has been in practice for over 25 years and can be
`considered as a knowledgeable expert in their field.
`
`In order to verify their statements, we have asked the doctors to each sign a
`declaration stating for the record that they have written a letter of support
`endorsing the products and services of the Applicant and to the best of their
`knowledge, there is no other mark which has caused them to be confused or
`caused them to be mistaken regarding their choice of supplier for orthopedic
`shoes or orthotic inserts.
`
`Copies of the signed declarations are attached to this response as EXHIBITS
`Nos. 15, 16 and 17.
`
`

`
`(13)
`
`Serial No. 78/699926
`Law Office 104
`
`Carol Spils
`
`VI. Conclusion
`
`It is our conclusion that the common element of the AppIicant’s_mark
`TENDERFEETSHOES DIABETIC FOOTWEAR and design and that of the
`Registrant, TENDERFOOT are each a weak and highly suggestive term in
`relation to foot care products. Therefore, purchasers will utilize those differences
`between the marks in order to identify the source of the products they seek.
`In
`the present case, we saw that the disclaimed term “SHOES” was used frequently V
`by purchasers to draw such a distinction.
`
`“
`
`We also note that the Applicant's customers are limited to professional foot care
`specialists who have a continuing need to verify the fit and quality of their
`orthopedic supplies.
`In this profession, there is a high degree of cooperation
`between the buyer and seller which greatly reduces the likelihood of confusion.
`
`In light of the above arguments and additional evidence, we respectfully request
`the Examining Attorney to withdraw the Section 2(d) refusal and forward our
`application to publication.
`
`Date:
`
`By:
`
`Respectfully submitted,
`
`’.
`
`Bob Schwartz
`
`President
`
`BGizunt, Inc.
`
`6040 Colodny Drive
`
`Agora Hills, CA 91301
`
`Tel: 818-991-4001 ext. 501
`
`

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`Serial No. 78/699926
`Law Office 104
`Carol
`
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`Law Office 104
`Carol Spils
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`Serial No. 78/699926
`Law Offi‘? 104
`Carol