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`ESTTA Tracking number:
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`ESTTA987011
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`Filing date:
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`07/11/2019
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding
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`Applicant
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`87634855
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`FN Herstal SA
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`Applied for Mark
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`THE RIGHT ARM OF THE FREE WORLD
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`Correspondence
`Address
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`BURTON S EHRLICH
`LADAS & PARRY LLP
`224 S MICHIGAN AVENUE SUITE 1600
`CHICAGO, IL 60604
`UNITED STATES
`CHIUSTM@LADAS.NET
`312-427-1300
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`Submission
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`Attachments
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`Filer's Name
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`Filer's email
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`Signature
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`Date
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`Applicant's Request to Extend
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`THE RIGHT ARM OF THE FREE WORLD.pdf(24132 bytes )
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`Burton S. Ehrlich
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`CHIUSTM@LADAS.NET
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`/bsehrlich/
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`07/11/2019
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`TRADEMARK TRIAL AND APPEAL BOARD
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`) TTAB Paralegal Specialist:
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`Serial Number: 87/634,855
`) AMY L MATELSKI
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`Applicant:
`FN HERSTAL SA
`) Examining Attorney:
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`) Sarah Hopkins
`Mark:
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`THE RIGHT ARM
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`OF THE FREE WORLD ) Law Office 123
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`Filed:
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`October 5, 2017
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`REQUEST FOR A FURTHER SIXTY (60) DAY EXTENSION OF TIME FOR
`FILING OF APPLICANT’S APPEAL BRIEF IN PART BASED UPON
`FURTHER EFFORTS TO RESOLVE WITH THE EXAMINER AN ACCEPTABLE
`RESOLUTION OF THE MATTER AND TO PERMIT TIME FOR THE
`FURTHER RECEIPT OF INSTRUCTIONS FROM THE CLIENT
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`The Applicant by and through its legal counsel, Burton S.
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`Ehrlich of Ladas & Parry LLP, hereby requests a further sixty
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`(60) day extension for the filing of the Applicant’s brief to
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`allow for the Applicant to potentially moot the need for this
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`appeal by fully resolving this matter at the Examiner level and
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`for additional time for consulting with the client for the
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`Applicant. In support of this Motion the Applicant submits as
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`follows:
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`The Applicant previously requested reconsideration of the
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`rejection of registrability in a paper filed with the Trademark
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`Attorney Examiner. When the request for reconsideration was denied
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`the Board subsequently set the briefing schedule of sixty (60) days
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`for the filing of the Applicant’s brief and the Applicant is now
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`seeking a further extension of the presently set due date.
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`- 1 -
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`The Applicant’s counsel believes that there still may be a
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`basis for resolving this matter with an amendment or submissions at
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`the Examiner level. The Applicant is in the process of seeking
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`further instructions and clarifications from his client on pursuing
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`a potential follow-up action and communication, so as to seek to
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`resolve this matter at the Examiner level and by consultations with
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`the Examiner. Based upon the current understanding of the
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`situation it is believed that a possible reasonable and acceptable
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`resolution may exist to resolve issues in this application. In
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`part, additional time is needed for the consideration of such a
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`resolution, which if resolved in this manner could moot the appeal.
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` The additional time would include time for consulting with the
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`client and with the Examiner in seeking a potential resolution.
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`Furthermore, additional time would also be necessary for
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`consulting with the principals for the client on the potential
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`appeal brief, should that become necessary.
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`Furthermore, this revised briefing schedule will also
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`accommodate the busy schedule of the Applicant’s counsel and
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`his principals for the client. During the time period
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`Applicant’s counsel has been heavily involved in District Court
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`proceedings including a patent infringement case involving a
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`multitude of foreign based Defendants, TTAB adversarial
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`matters, and other matters with time sensitive deadlines
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`involving both foreign and domestic intellectual property law
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`- 2 -
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`related matters for a number of clients. This extension will
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`allow for counsel to consult and prepare any necessary papers.
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`Based upon the foregoing, it is respectfully requested
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`that the due date for the brief be reset for sixty (60) days
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`with the Applicant’s brief under this extension becoming due on
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`September 10, 2019.
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`Burton S. Ehrlich
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`Ladas & Parry
`224 South Michigan Avenue
`Chicago, IL 60604
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`(312) 427-1300
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`Respectfully submitted,
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`/Burton S. Ehrlich/
`Burton S. Ehrlich
`Attorney for Applicant
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`CERTIFICATE OF ELECTRONIC FILING
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`I hereby certify that this paper is being electronically
`filed with the United States Patent and Trademark Office on this
`11th day of July, 2019.
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` /Burton S. Ehrlich/
`One of Petitioner's attorneys
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`- 3 -
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