`8? MAIN STREET. SUITE 508
`WHITE PLAINS, NY 10601
`TEL (914) 285-0700
`
`.
`I
`.
`‘
`H
`WWW ran?” “W com
`
`March 16, 2015
`
`TTAB
`
`IN NEW YORK CRTY
`
`----
`NEW vonx, NY 10017
`TEL (212) 599-5533
`FAX (212) 5996385
`
`VIA CERTIFIED MAIL
`
`Trademark Trial and Appeal Board
`U.S. Patent and Trademark Office
`
`P.O. Box 1451
`
`Alexandria, VA 22313/1451
`
`Re:
`
`Serial No’s. 86416412 and 86416038
`
`Dear Sir or Madam:
`
`This law firm represents GLOCK, Inc.
`
`GLOCK, Inc. recently had two trademarks published for opposition with the USPTO.
`These two trademarks, G17 and G18, correspond to the above-referenced serial numbers. On
`March 5, 2015, Kent Wu of The Wuster, filed a 90 day request for extension of time to oppose
`both trademarks for good cause. These motions were granted by the TTAB. Enclosed, please
`find GLOCK, Inc.’s request for reconsideration regarding the extension of time granted for both
`serial numbers.
`
`As neither of these matters has been assigned opposition numbers, customer service
`advised that we send in our motions Via certified mail.
`
`We appreciate your consideration in this matter. Please do not hesitate to contact us with
`any questions.
`
`Very truly yours,
`
`RENZULLI LAW FIRM, LLP
`
`llllllllllllllllwlgllllwlllgll||||l|||||||l MW OAEOQ” €dj:3V\.
`
`U 5 Patent 8. TMOYC./TM Mall Rim Dt #22
`
`Julianna E. Orgel-Eaton
`
`cc:
`
`John F. Renzulli, Esq.
`
`
`
`1|
`
`11
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Application Serial No. 86416038
`
`) )
`
`)
`)
`
`) )
`
`) )
`
`)
`
`In the matter of Serial No. 86416038
`
`Date of Publication: March 3, 2015
`For the mark: G17
`
`Kent Wu,
`
`Opposer,
`
`v.
`
`GLOCK, Inc.,
`
`Applicant.
`
`RES QUEST FOR RECONSIDERATION
`
`GLOCK, Inc. (“Applicant”) by its attorneys, Renzulli Law Firm, LLP, requests that pursuant to §
`
`21 1.01 of the TBMP, the Board reverse its March 5, 2015 decision to grand an extension of time to Kent
`
`Wu (“Opposer”).
`
`Opposer requested a 90 day extension of time to oppose Applicant’s trademark for good cause.
`
`According to Opposer, he believes good cause is established because “the potential opposer is engaged in
`
`settlement discussions with applicant.” Applicant responds to this request to notify the Board that this
`
`claim is false information which has no basis in fact. Applicant and/or his attorney have never contacted
`
`GLOCK or this office for any reason. Applicant believes that this is a tactic by Opposer to harass
`
`Applicant and delay its trademark registration without good cause.
`
`Applicant
`
`is the plaintiff in a trademark and patent
`
`infringement
`
`lawsuit against Opposer’s
`
`company, The Wuster (1:14 cv-00568 AT) in the Northern District of Georgia. At issue in this lawsuit is
`
`Opposer’s infringing use of Applicant’s intellectual property,
`
`including but not
`
`limited to,
`
`the G17
`
`trademark. This lawsuit is in its early stages of discovery and there have been no settlement discussions.
`
`
`
`CONCLUSION
`
`It
`
`is clear that Opposer has filed this extension of time in bad faith. Opposer has espoused
`
`unmitigated untruths and is attempting to obtain a benefit from the Board to which he is not entitled.’
`
`Applicant submits that based on the facts, it would be unjust to allow Opposer to have a 90 day extension
`
`of time. For the foregoing reasons, Applicant respectfully requests that the Board reverse its decision.
`
`Respectfully submitted this 16”‘ Day of March, 2015.
`
`By:
`
`/s/ Julianna E. Orgel—Eaton
`John F. Renzulli
`
`Julianna E. Orgel—Eaton
`RENZULLI LAW FIRM, LLP
`81 Main Street, Suite 508
`White Plains, NY 10601
`Telephone: (914) 285-0700
`Facsimile: (914)285-1213
`'}orgel@re112ul1 i law.com
`
`Attorneys for Applicant, GLOCK, Inc.
`
`1 Central Manufacturing Inc. v. Third Millennium Technology Inc., 61 USPQ2d 1210 (TTAB 2001).
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