`Cum
`
`i
`
`U.S. P
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`04-21 -2003
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`_
`atent & TMOfc/TM Mail Rcpt D1, #25
`
`IN THE UNITED STATES PATENT AND TRADEMARK OEFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of trademark application Serial No. 76106983
`
`For the mark Guru of Law
`
`Published in the Official Gazette on March 18, 2003
`
`1-
`
`Eslamboly & Barlavi
`V.
`
`Marcus Ambrose
`
`Eslamboly & Barlavi
`
`NOTICE OF OPPOSITION
`
`T
`
`Bahman Eslamboly, General Partner
`Kamran Barlavi, General Partner
`
`.
`
`6100 Wilshire Blvd.
`
`Suite 360
`
`Los Angeles, CA 90048
`
`C
`4’-
`
`:1
`
`_.
`
`"(*3
`
`:4
`{R
`
`g
`
`_«
`
`The above identified opposer believes that it will be damaged by registration of
`the mark shown in the above-identified application, and hereby opposes the same.
`
`The grounds for opposition are as follows:
`
`1.)
`
`First Use in Commerce - Eslamboly & Barlavi has been doing business under
`the name Lawgurucom since 1995 and has been using the mark Lawguru in
`commerce since July 12, 1996 (Exhibit “A” and “B”) . The Applicant claims
`to have first used the mark Guru of Law on August 8, 2000, the day he filed
`application for the mark.
`
`1
`
`2.)
`
`Confiisingly Similar — Potential clients/visitors may confuse Guru of Law
`with Lawguru.com an already established business with a large clientle.
`Lawguru.com’s clientle includes legal professionals, academics and the
`general public. The Applicant may benefit from Lawguru.com’s good name
`05/09/2003 UHHDERSO 00000078 76106983
`
`01 FC:6402
`
`300.00 OP
`
`
`
`
`
`'9)
`
`and standing in both the legal and internet communities, whereas, the
`Applicant’s actions or inactions may detrimentally harm Lawguru.com’s good
`name.
`
`Economic Hardship — Eslamboly & Barlavi has spent over seven years of time
`and thousands of dollars promoting Lawguru to achieve “brand recognition”.
`Lawgurucom has been promoted via the internet, television, articles and
`lectures. It is difficult to estimate the potential economic damages, depending
`on how many people confuse Lawguru with the Guru of Law the Applicant
`proposes.
`
`The Lawguru mark would be diluted. Eslamboly & Barlavi has filed a
`Trademark Application for the mark Lawguru, Application Serial Number
`78058964, based on use in commerce. The granting of such similar marks
`would defy the purpose of a trademark.
`
`
`
`ahman Eslamboly, Partne
`
`Date glggzz
`
`/7, 24¢;
`
`
`
`
`
`Lawgurucom ~ Home Page
`
`'
`
`Page 1 of 2
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`@[a“3m-“gum
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`[fin SaaI'cl_12fi+Laua|tBsfl°nm
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`Welcome to Lawgurzacam the Home Page ofThe Law Offices ofEslamboly & Bax.-lavi. This .
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`.0 :_;.;;.~--r-
`I 9.2 - =23. 2-! 0 r
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`%l also represents all types of artists (i.e. photographers, graphic artists, computer artists,
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`ekust by allin PILAW-TALK, from anywhere in the United States,
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`Although many many hours went into the design and construction of this site, we are far from
`done. We are always adding new material. This site is ever gro ‘
`..
`» ~- d ever expanding.
`
`However, this site is not perfect. Should you discover any A W‘
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`wish to make any comments please feel free to e-mail
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`site, please write us.
`
`.c. We
`r
`uld be linked to our
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`This page's Weh-Counter indicates that since July 12, 1996 you are visitor number
`
`You knew that since this was a law firm’: site there had to be some fine print somew re.fill are it is: This web site is provided for your
`
`http://www.lawgu.ru.com/
`
`8/22/96 2:30:16 AM
`
`EXW/Wr “ P: "
`
`Lega I
`Scare In
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`
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`
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`
`
` J wguru.com - Home Page
`
`othing transmitted from thiweb site cons '
`lnfommion only.
`Luv Oflices ofEslamboly & Barlavifleae remeber the
`law.
`
`nude of
`tea the establishment ofan axmrney-client relniship between you and The
`information at thin site oulydeula with California luv and some federal
`in. I -V not rely on these materials without first seeking the advice of an
`
`‘
`
`Page 2 of2
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`-
`
`Los Angeles, CA 9004
`(800) LA W-TALK
`(213) 651-3333
`fax (213) 658-6041
`
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`I -800-LA W-TALK
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`1
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`6"
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`_
`Email: LawTaZ_;h@,lawg1_4ru. cog;
`Copyright © 1996 ESLAIVIBOLY & BARLAVI
`This page was designed andpragrammed by Bahman Eslambolz
`
`Revision date: August 21, 1996
`
`‘
`
`'
`
`- ~
`
`http://www.lawguru.com/
`
`8/22/96 2:30:20 AM
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