Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA628173
`ESTTA Tracking number:
`09/19/2014
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`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91173963
`Plaintiff
`Mini Melts, Inc.
`ROBERT G OAKE JR
`OAKE LAW OFFICE
`825 MARKET STREET, SUITE 250
`ALLEN, TX 75013
`UNITED STATES
`rgo@oake.com
`Stipulated/Consent Motion to Extend
`Robert G. Oake, Jr.
`rgo@oake.com
`/Robert G. Oake, Jr./
`09/19/2014
`Motion to Extend Briefing Date.pdf(65814 bytes )
`Ex 1.pdf(91127 bytes )
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`Proceeding
`Party
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`Correspondence
`Address
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`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
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`ESTTA628173
`ESTTA Tracking number:
`09/19/2014
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91173963
`Plaintiff
`Mini Melts, Inc.
`ROBERT G OAKE JR
`OAKE LAW OFFICE
`825 MARKET STREET, SUITE 250
`ALLEN, TX 75013
`UNITED STATES
`rgo@oake.com
`Stipulated/Consent Motion to Extend
`Robert G. Oake, Jr.
`rgo@oake.com
`/Robert G. Oake, Jr./
`09/19/2014
`Motion to Extend Briefing Date.pdf(65814 bytes )
`Ex 1.pdf(91127 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
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`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`TRADEMARK TRIAL AND APPEAL BOARD
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`Mini Melts, Inc.,
`Opposer,
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`v.
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`Reckitt Benckiser LLC,
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`Applicant.
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`§
`§
`§
`§
`§ Opposition No. 91/173,963
`§
`§
`§
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`OPPOSER’S UNOPPOSED MOTION TO EXTEND REPLY BRIEF DEADLINE
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`Opposer Mini Melts, Inc. moves to extend the deadline for filing its reply brief by two
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`weeks, respectfully showing as follows:
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`1.
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`The deadline for filing the reply brief in this matter currently is September 23,
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`2014. Opposer Mini Melts, Inc. requests that this deadline be extended to October 7, 2014 (two
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`week extension).
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`2.
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`Counsel for Opposer Mini Melts, Inc. has conferred with counsel for Applicant
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`Reckitt Benckiser LLC regarding the merits of this motion and this motion is unopposed.
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`3.
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`Due to a combination of both expected and unexpected litigation matters in
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`several patent infringement cases counsel for Opposer is handling by himself, a two week
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`extension of time to file the Mini Melts reply brief in the opposition is requested. These matters
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`(that have or are taking place during the 15 day reply period) include responding to a motion to
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`transfer venue, responding to a motion for summary judgment, preparation for and attendance at
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`two depositions, document inspections, responding to interrogatories and requests for
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`production, preparation of a motion to strike and sur-reply to objections to a report and
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`recommendation, preparation of a patent infringement lawsuit against a Chinese Corporation,
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`preparation of cease and desist letters, preparation of contractual documentation, multiple
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`1
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`meetings and conferences, as well as other matters such as providing initial disclosures, drafting
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`patent applications, and reviewing new case matters including patent infringement and invalidity
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`evaluations. Counsel for Opposer is handling all these matters by himself. A two-week
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`extension is needed because the week after the current due date counsel for Opposer is involved
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`in preparation for and attendance at two more depositions and other case matters. (See
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`declaration of Robert G. Oake, Jr. attached as Exhibit 1).
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`4.
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`The existence and press of other litigation matters can constitute good cause for a
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`limited extension of time. See Societa Per Azioni Chianti Ruffino Esportazione Vinicola
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`Toscana v. Colli Spolentini Spoletoducali SCRL, 59 USPQ2d 1383, 1384 (TTAB 2001)
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`(“Opposer’s counsel, in his declaration, has set forth the facts relating to his other litigation
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`matters in sufficient detail to warrant a finding that good cause exists for at least a limited
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`extension of opposer’s testimony period”).
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`5.
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`6.
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`Applicant does not oppose this motion.
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`For the reasons set forth above, Mini Melts moves for an order extending the
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`deadline for a filing a reply brief in this matter two weeks (until October 7, 2013).
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`Respectfully submitted,
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`/s/ Robert G. Oake, Jr.
`Robert G. Oake, Jr.
`Texas State Bar No. 15154300
`Oake Law Office
`825 Market Street, Suite 250
`Allen, Texas 75013
`(214) 207-9066
`rgo@oake.com
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`Attorney for Opposer Mini Melts, Inc.
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`CERTIFICATE OF CONFERENCE
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`The undersigned attorney for Opposer has communicated with attorney for Applicant and
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`/s/ Robert G. Oake, Jr.
`Attorney for Opposer Mini Melts, Inc.
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`this Motion to Extend Time is unopposed.
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`CERTIFICATE OF SERVICE
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`I certify that a true and correct copy of the foregoing reply was served upon the Applicant
`via e-mail on September 19, 2014 as follows:
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`Debra Deardourff Faulk
`Debra.Faulk@gray-robinson.com
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`/s/ Robert G. Oake, Jr.
`Attorney for Opposer Mini Melts, Inc.
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`3
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`EXHIBIT 1
`EXHIBIT 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`TRADEMARK TRIAL AND APPEAL BOARD
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`Mini Melts, Inc.,
`Opposer,
`
`
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`
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`v.
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`Reckitt Benckiser LLC,
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`Applicant.
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`§
`§
`§
`§
`§ Opposition No. 91/173,963
`§
`§
`§
`§
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`DECLARATION OF ROBERT G. OAKE, JR.
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`My name is Robert G. Oake, Jr. I am an attorney at law in good standing with the State
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`1.
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`Bar of Texas and licensed to practice law in the state of Texas. I am a registered patent attorney
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`and licensed to practice before the United States Patent and Trademark Office. I represent Mini
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`Melts, Inc., the Opposer in this opposition. I have personal knowledge of the facts stated in this
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`declaration, as more particularly set forth below.
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`2. Due to a combination of both expected and unexpected litigation matters in several patent
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`infringement cases I am handling by himself, a two week extension of time to file the Mini Melts
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`reply brief in the opposition is requested. These matters (that have or are taking place during the
`
`15 day reply period) include responding to a motion to transfer venue, responding to a motion for
`
`summary judgment, preparation for and attendance at two depositions, document inspections,
`
`responding to interrogatories and requests for production, preparation of a motion to strike and
`
`sur-reply to objections to a report and recommendation, preparation of a patent infringement
`
`lawsuit against a Chinese Corporation, preparation of cease and desist letters, preparation of
`
`contractual documentation, multiple meetings and conferences, as well as other matters such as
`
`providing initial disclosures, drafting patent applications, and reviewing new case matters
`
`including patent infringement and invalidity evaluations. I am handling all these matters by
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`Page 1
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`
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`myself. A two-week extension is needed because the week after the current due date I am
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`involved in preparation for and attendance at two more depositions and other case matters.
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`3.
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`I declare under penalty of perjury that the foregoing is true and correct to the best of my
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`knowledge and belief.
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`This 19th day of September, 2014.
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`Robert G. Oake, Jr.
`Attorney for Opposer Mini Melts, Inc.
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`Page 2
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