Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA290231
`ESTTA Tracking number:
`06/17/2009
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91176791
`Defendant
`MATTEL, INC.
`Lawrence Y. Iser, Esq.
`Kinsella Weitzman Iser Kump & Aldisert LLP
`808 Wilshire Blvd., Suite 300
`Santa Monica, CA 90401
`UNITED STATES
`CFitzgerald@kwikalaw.com
`Defendant's Notice of Reliance
`Chad R. Fitzgerald
`cfitzgerald@yahoo.com
`/crf/
`06/17/2009
`Applicants Notice of Reliance re Printed Publications Vol. 1.pdf ( 141 pages
`)(8623934 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`
`ESTTA290231
`ESTTA Tracking number:
`06/17/2009
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91176791
`Defendant
`MATTEL, INC.
`Lawrence Y. Iser, Esq.
`Kinsella Weitzman Iser Kump & Aldisert LLP
`808 Wilshire Blvd., Suite 300
`Santa Monica, CA 90401
`UNITED STATES
`CFitzgerald@kwikalaw.com
`Defendant's Notice of Reliance
`Chad R. Fitzgerald
`cfitzgerald@yahoo.com
`/crf/
`06/17/2009
`Applicants Notice of Reliance re Printed Publications Vol. 1.pdf ( 141 pages
`)(8623934 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of Application Serial No. 78/751,105
`Pubiished for Opposition in the OFFICIAL GAZETTE on December 12, 2006
`
`UMG RECORDINGS, INC.
`
`I
`
`Opposition No: 91 176791
`
`Opposer
`
`V.
`
`MATTEL, INC.
`
`Appiicant
`
`
`
`APPLICANTS NOTICE OF RELIANCE RE: FRINTED PUBLICATIONS
`
`Vol. 1 of 7
`
`55040.00084/457SSJ
`
`
`
`Pursuant 37 C.F.R. § 2.122(e), Applicant Mattel, Inc. hereby makes of record, and
`
`notifies Opposer UMG Recordings, inc. (“Opposer”) of its reliance on, the following printed
`
`publications offered to show that the term “Motown” (l) is primarily descriptive of both the city
`
`of Detroit, Michigan and a genre of popular music; (2) is often used in publications available to
`
`the general public to describe or refer to the city of Detroit, Michigan or a genre of popular
`
`music; and (3) is part of several trademark applications and registered marks that have nothing to
`
`do with Opposer. True and correct copies of printouts of these publications are attached hereto
`
`as Exhibit A, and Applicant asks the Board to take judicial notice thereof:
`
`1.
`
`Registration number 3067783 (serial number 7854i69i) for the mark MOTOWN,
`
`owned by Worid Products, Inc. and registered as of March 14, 2006 (printed from the US.
`
`Patent and Trademark Office’s (“USPTO”) Trademark Electronic Search System (“TESS”));
`2.
`Registration number 2768460 (serial number 78101526) for the mark MOTOWN,
`
`‘
`
`owned by Ford Motor Company and registered as of September 23, 2003 (printed from TESS);
`I
`‘ 3.
`Registration serial number 77502616 for the mark MOlOWN MONDAY, owned
`
`by applicant Nick Bovis (printed from TESS);
`
`4.
`
`Registration number 3471030 (serial number 77313087) for the mark MOTOWN
`
`TRESS, owned by Oradell International Corp. and registered as of July 22, 2008 (printed from
`
`TESS);
`
`5..
`
`Registration number 2649776 (serial number 75625492) for the mark MOTOWN
`
`MISSILE, owned by Arkenol, Inc. and registered as of November 12, 2002 (printed from TESS);
`
`6.
`
`Registration number 2598544 (serial number 75797779) for the mark MOTOWN
`
`MISSILE, owned by Arkenol, Inc. and registered as of July 23, 2002 (printed from TESS);
`
`55040.000844'457581
`
`2
`
`
`
`7.
`
`Registration number 24E1580 (serial number 75831433) for the mark MOTOW,
`
`owned by World Products, Inc. and registered as of December 5, 2000 (printed from TESS);
`
`8.
`
`Registration number 1552131 (serial number 73727171) for the mark MOTOWN
`
`SNACKERS, owned by Sargento Inc. and registered as of August 15, 1989 (printed from TESS);
`9.
`The USPTO’S complete file for registration number 2411580 (printed from the
`
`USPTO Trademark Document Retrieval (“TDR”) system);
`
`10.
`
`The USPTO’S complete file for seriai number 78101526 (printed from TDR);
`
`ii.
`
`12.
`
`The USPTO’S complete file for serial number 75625492 (printed from TDR);
`
`Pages from Random House Webster ’5’ College Dictionary, © 2000;
`
`13.
`
`The entry for “Motown” from the Oxford English DictiOnary Online,
`
`dictio‘nary.oed.oom, © 2009;
`
`£4.
`
`The entry for “Detroit” from the website wikipedieorg;
`
`15.
`
`The entry for “motown” from the website dictionagy.com;'
`
`16.
`
`The entry for “motown” from the website wordnetprincetonedu;
`
`17.
`
`The entry for “motown” from the website wordweboniineeom;
`
`18.
`
`The entry for “Motown” from the website wwwlhefreedictionaryeom;
`
`19.
`
`The entry for “motown” from the website dictionagydienet;
`
`20.
`
`Pages from Motown: Music, Money, Sex, and Power by Gerald Posner, © 2002;
`
`21.
`
`The entry for “Motown Motion Picture Studios” from the website wikigediaorg;
`
`22.
`
`“The Motown Missionary”, which appeared in The Observer on November 12,
`
`2000;
`
`23.
`
`“Commentary: Can Motown Get Out of This Funk”, which appeared in
`
`Businessweek Magazine on June 23, 2003;
`
`55040.00084/45753.1
`
`3
`
`
`
`24.
`
`“Hot Metei for Motown”, which appeared in The Toronto Star on December 23,
`
`2006;
`
`25.
`
`“Great Times And Cool Events”, which appeared on
`
`www.motownwinterblasteom on February 9, 2007;
`
`- 26.
`
`“Motown Wehcam 1.0”, which appeared on www.50ftmedia.com on March 16,
`
`2007;
`
`2007;
`
`27.
`
`“Mulitalo Moves To Motown”, which appeared on wwwwbaleom on March 25,
`
`28.
`
`“Don’t Drafi Brady Quinn”, which appeared on
`
`www.motommpertsrevival.blogspoteom on March 26, 2007;
`
`29.
`
`“Time for great Motown sale”, which appeared in The Economic Times on March
`
`27, 2007;
`
`30.
`
`“View From Motown”, which appeared on wmvblocrsmotortrendeom on March
`
`30, 2007;
`
`31.
`
`“Active Threads From The Forums”, which appeared on www.motownspoflseom
`
`on March 30, 2007;
`
`32.
`
`“Welcome to Motown Muscle”, which appeared on www.motownmuseieeom on
`
`March 30, 2007;
`
`33.
`
`Splash page for Motown Writers Network, www.motownwriéers.homestead.com,
`
`accessed on March 30, 2007;
`
`34.
`
`Splash page for Motown Thewdown, www.ffindr.com, accessed on March 30.
`
`2007;
`
`35.
`
`“Motown Cam”, which appeared on www.cartheamcom on March 30, 2007;
`
`55040.00084/457581
`
`4
`
`
`
`36.
`
`Splash page for Motowngirlscom, wwmotowngirlscom, accessed on March
`
`30, 2007;
`
`37.
`
`38.
`
`“Motown Wigs”, which appeared on wwwwigsaloacom on March 30, 2007;
`
`Splash page for Biker Bob’s, wwwbikerbobshdcom, accessed on March 30,
`
`2007;
`
`2007;
`
`2007
`
`39.
`
`“Motown cricket club”, which appeared on wwwgeocitieseom on March 30,
`
`40.
`
`Splash page for Motown HOG, www.motownhogcom, accessed on March 30,
`
`41.
`
`Spiash page for Motown First Federai Credit Union, www.motownfirst.com
`
`accessed on March 30, 2007;
`
`42.
`
`“Berry Gordy’s Motown Records”, which appeared on wwwhistog-ofqockcom
`
`on April 03, 2007;.
`
`-
`
`43.
`
`Splash page for Motown Metal Art Galiery, mvwmotownrnetaicom, accessed on
`
`September 05, 2007;
`
`44.
`
`“The American dream shudders to a halt in Motown”, which appeared in The
`
`Independent on November 08, 2008;
`
`45.
`
`“Raw nerves in Motown”, which appeared on www. reightsideradvisorscom on
`
`November 11, 2008;
`
`46.
`
`“Bush’s Motown Turnaroun ”, which appeared on “wwforbescom on
`
`November 11, 2008;
`
`47.
`
`“The Big Three Deserve to Die”, which appeared on wwwthedailxgreencom on
`
`November 16', 2008;
`
`50403003414575“
`
`5
`
`
`
`48.
`
`“Motown Mendieants’ Bailout Blamey”, which appeared in The New York Post
`
`on November 18, 2008;
`
`49.
`
`“Quest to Motown’s Ford Field Continues”, which appeared on
`
`www.wzzm13 .com on November 18, 2008;
`
`50.
`
`Page splash for FourWheeiereom, www.fourwheeier.com, accessed on
`
`November 20, 2008
`
`51.
`
`“Green Enk: Oil’s Down, Motown Drowns”, which appeared on
`
`www.blogs.wsj.eom on November 18, 2008;
`
`52.
`
`“Barack Obama And The Big Three”, which appeared on www.forbes.com on
`
`November 19, 2008;
`
`53.
`
`“Motor City: From Motown to nowhope town”, which appeared in The
`
`. Independent on November 19, 2008;
`
`54.
`
`“Motown Slowdown: How is Detroit’s economy affecting the city”, which
`
`appeared on www.mationaiposteom on November 19, 2008;
`
`55.
`
`“Let Detroit Go Bankrupt”, which appeared in the New York Times on November
`
`19, 2008
`
`56.
`
`“Talk of Auto Bailout Jumpstarts Wall Street”, which appeared on
`
`wwwforbeseom on November 20, 2008;
`
`S7.
`
`“Motown comes begging —- in three private jets”, which appeared on
`
`www.business.smh.eom on November 21, 2008;
`
`58.
`
`59.
`
`“Motown Rebound”, which appeared on wwwforbescorn on December 04, 2008;
`
`“Import cannakers teasing acres of coast to store unwanted vehicles”, which
`
`appeared on wwwautobiogeom on December 08, 2008;
`
`55040.000841’457581
`
`6
`
`
`
`60.
`
`“Think About Autos”, which appeared on wwwbaltimorechroniciecom on
`
`December 08, 2008;
`
`61.
`
`“Another ‘L’ of a Monday in Motown”, which appeared on \wvwfreepcom on
`
`December 08; 2008;
`
`62.
`
`“GM’S Bust Tums Detroit Into Urban Prairie of Vacant~Lot Fame”, which
`
`appeared on wwwbloombergeom on December 08, 2008;
`
`63.
`
`“Motown Motion Picture Studios”, which appeared on
`
`Whollywoodblackoutbiogspoteom on February 03, 2008;
`
`64.
`
`Page splash for March to Motown Blog, www.5ports.espn.go.com, accessed on
`
`March 15, 2009;
`
`65.
`
`“MSU’S March to Motown begins”, which appeared on wwwdetnewseom on
`
`March 16, 2009;
`
`66.
`
`“The 6th man: UNC win out down nets in Motown maybe”, which appeared on
`
`wwwisureveiileeom on March 16, 2009;
`
`67.
`
`“Welcome to Motown Jayi”, which appeared on wwwfreepeom on March 16,
`
`2009;
`
`68.—
`
`“Update 011 Detroit Shock ownership”, which appeared in The Seattle Times on
`
`March 16, 2009;
`
`69.
`
`“Expect a No. E and three No. 2 seeds to reach Motown”, which appeared on
`
`www.detnews.com on March 17, 2009;
`
`7’0.
`
`“Tips for 5111ng out yourrNCAA tournament brackets”, which appeared on
`
`wwwxeadingeagieeom on March 17, 2009;
`
`55040.00084/457583
`
`7
`
`
`
`71.
`
`“Will the Bulis Make the Playoffs?”, which appeared on wwwgapersbiockcom
`
`on March 17, 2009;
`
`72.
`
`“Youih gymnasts fare weii”, which appeared on www.1enconnect.com on March
`
`17, 2009;
`
`73.
`
`“Pitino’s Motown Moaopoly”, which appeared on www.mebieacherrepofteom on
`
`March 18, 2009;
`
`74.
`
`“American Idoi’ Top 10 in Motown; mat Giraud, Anoop Desai, Lil Rounds
`
`arrive to cheers”, which appeared on www.mlivecom on March 19, 2009;
`
`75.
`
`“ED GARNEY: Some intriguing themes form Hitsvilie NCAA”, which appeared
`
`on www.reviewioumal.com on March 19, 2009;
`
`76.
`
`“American Idol finalists party in Motown m Matt Giraud shows them around?”,
`
`which appeared on www.mewsdayeom on March 20, 2009;
`
`77.
`
`“American Idol“ stars 1i ght up Motown”, which appeared on mowireepcom on
`
`March 20, 2009;
`
`78.
`
`“Michigan’s new go~to~guy?”, which appeared 0n wwwfreepcom on March 20,
`
`2009;
`
`79.
`
`“Ruben Rosario: Singer takes anti-drug mission on 90 day tour”, which appeared
`
`on wwwLMincitieseom on March 21, 2009;
`
`80.
`
`“Williams ready to drive the Cardinals”, which appeared on wwwespncom on
`
`March 22, 2009;
`
`“Paging Dr. Phil”, which appeared on wwwfreepcom on March 22, 2009;
`
`r
`
`“March madness at work”, which appeared on www.freep.com on March 23,
`
`81.
`
`82.
`
`2009; '
`
`55040.00084l45758.1
`
`8
`
`
`
`84.
`
`“Detroit Pistons vs. Chicago Bulls —— Motown blues”, which appeared on
`
`wwwoetuscom on March 25, 2009;
`
`85.
`
`“American Idoi: Motown’s Just a Fancy name for Detroit”, which appeared on
`
`www.defamer.gawker.com on March 26, 2009;
`
`86.
`
`“OFF TO MOTOWN”, which appeared on wwwdailycampuscom on March'27,
`
`2009;
`
`87.
`
`“After a stirring raliy, Spartans one win from Final Four in Motown”, which
`
`appeared on Wfi'BEQCOD‘l on March 28, 2009;
`
`88.
`
`“A fairytale for Tom 1220, Magic and ail Spartans”, which appeared on
`
`wwwfreegcom on March 29, 2009;
`
`89.
`
`“Bashing Chris Osgood season continues”, which appeared on www.mlive.com
`
`on March 29, 2009;
`
`90.
`
`“Cap movie tax breaks? Might as weli kill “em”, which appeared on
`
`wwwfreepcom on March 29, 2009;
`
`91.
`
`“Heeis rolling toward Motown showdown. ”, which appeared on www.citizen—
`
`timescom on march 29, 2009;
`
`92.
`
`“March of the Spartans”, which appeared on www.azcentra1.com on March 29,
`
`2009;
`
`2009;
`
`93.
`
`“Motown Madness”, which appeared on wwwabcactionnewscom on March 29,
`
`94.
`
`“Motown medicine: Final Four”, which appeared on www.miarniherald.corn on
`
`March 29, 2009;
`
`55040.00084/457581
`
`9
`
`
`
`95.
`
`“Off to Europe . .. Motown blues
`
`Disaster at sea”, which appeared on
`
`wwwkxmecom on March 31, 2009;
`
`96.
`
`“Final Four is set for Motown”, which appeared on wwwwndueom on March 30,
`
`2009;
`
`97.
`
`“I220, Spartans complete march to Motown”, which appeared on
`
`_ wwwnwitimescom on March 30, 2009;
`
`98.
`
`“Spartytown”, which appeared on wvvwfreepeom on March 30, 2009;
`
`99.
`
`“Will we lose the crafi of automaking?”, which appeared on www.detnews.com
`
`on March 30, 2009;
`
`100.
`
`“Michigan State is coming home to Motown”, which appeared in The Los Angeles
`
`Times on March 30, 2009;
`
`101.
`
`“Motown Misery”, which appeared on wwwhuffingtonpostcom on March 30,
`
`2009;
`
`102.
`
`“Legendary UNLV Coach Sounds Off On Collegiate Sports”, which appeared on
`
`wwwiaSVegassuneom on March 31, 2009;
`
`103.
`
`“Motown bound: Final Four preview”, which appeared on www.utmpacer.com on
`
`‘ March 31, 2009;
`
`104.
`
`“Motown suffers from Wall Street envy”, which appeared in The Washington
`
`Times on March 31, 2009;
`
`105.
`
`“Showdown for Motown”, which appeared on wwwsmhcom on April 1, 2009;
`
`106.
`
`“If only for a weekend, some positive momentum for Motown”, which appeared
`
`on www.cbssportscom on April I, 2009;
`
`107.
`
`Page splash for rivaiscom, wwwrivalscom, on April 02, 2009
`
`55040.00084/é5758. 1
`
`10
`
`
`
`108.
`
`“Final Four won’t make or break Detroit”, which appeared on wwwfreepcom on
`
`April 02, 2009;
`
`109.
`
`“Frustration, disappointment spilling over in Motown”, which appeared on
`
`vwvwmbacom on April 02, 2009;
`
`110.
`
`“It’s the greening of Motown”, which appeared on www.hub.lsj.com on April 02,
`
`2009;
`
`I 11.
`
`“Spadens Final Arrive in Motown”, which appeared on wwwxyzcom on April
`
`02, 2009;
`
`112.
`
`“10 great places to stay in bounds in Detroit”, which appeared in USA Today on
`
`April 02, 2009;
`
`113.
`
`“Shaking Off the Motown Blues”, which appeared'in The New York Times on
`
`April 03, 2009;
`
`i 114.
`
`“Hot Foots Picks from The DANCW’ ROSE: Weekend of 4~3~2009”, which
`
`appeared on www.readitnews.com on April 03, 2009;
`
`115-
`
`“Spartan men ofMotown”, which appeared on wwwlansingstatejoumaleom on
`
`April 03, 2009;
`
`116.
`
`“Dick Jerardi: Arrival of Final Four has Motown’s streets bustling”, which
`
`appeared on wwwphillycom on April 04, 2009;
`
`117.
`
`““Final Four hope to find their mojo in Metown”, which appeared on
`
`wwwelandosentineicom on April 04, 2009;
`
`118.
`
`“Gonzo: Hard miles to Motown”, which appeared on wwwphilixcom on April
`
`04, 2009;
`
`55040900341453“
`
`1 1
`
`
`
`l 19.
`
`“Let spotlights, and tax incentives, work for Michigan”, which appeared on
`
`wwwi‘reepcom on April 04, 2009;
`
`120.
`
`“The Eccentric Soul Revue: Chicago’s mini-Motown”, which appeared on
`
`www.chicago.decider.c0m on April 04, 2009;
`
`121.
`
`“Insider: Pistons face the music in Motown without lverson”, which appeared in
`
`USA TODAY on April 05, 2009;
`
`122.
`
`“Motown Rocks with OId~School Feel”, which appeared in The New York Post on
`
`Amril 05, 2009;
`
`i
`
`123.
`
`“Paige: Motown’s Spirits get a lift”, which appeared in The Denver Post on April
`
`05, 2009;
`
`124.
`
`“Plowing new ground”, which appeared on www.hattlecreckenwuirercom on
`
`April 05, 2009;
`
`125.
`
`“Pride not pity should be Detroit’s Final legacy”, which appeared on
`
`wwwircepcom on April 05, 2009;
`
`126.
`
`“Red Wings down Wild with late goal”, which appeared on www.twincities.com
`
`on April 05, 2009;
`7127.
`“The Soul ofMotown: Spartans Battled to Rebuild Detroit’s Dignity”, which
`
`appeared on wwwemericanchroniclecom on April 05, 2009;
`
`128.
`
`“Spartans, Tar Heels In Motown Showdown”, which appeared on www.2tb0.com
`
`on April 05, 2009;
`
`£29.
`
`“Information About Motown Motion Picture Studio in “Pontiac”, which appeared
`
`on www.about.com on April 06, 2009;
`
`‘ 5.504006084145753]
`
`
`
`130.
`
`“Mood swing in Motown”, which appeared on wwwspectmmbuffaloedu on
`
`April 06, 2009;
`
`131.
`
`“Motown Woes Weigh on Adworld — but Not as Much as You’d Think”, which
`
`appeared on wwwadagecom on Aprii 06, 2009.
`
`i
`
`132.
`
`“One of Motown’s Favorite Sons”, which appeared on wwhlackathietenet on
`
`Aprii 06, 2009;
`
`133.
`
`“Showdown in Motown Captivates State”, which appeared on WWW.Wnem.com
`
`on April 06, 2009;
`
`134.
`
`“UNC Rocks, Rails into Motown Showdown”, which appeared on
`
`wwwaznericanchronicleeom on Apn'l 07, 2009;
`
`135.
`
`“Detroit Is East Lansing: The Significance ofthe Spartans in Motovm”, which
`
`appeared on wwwbieacherrepmteom on ApriI 07, 2009;
`
`136.
`
`“Jay Leno brings comic reiief to battered Motown”, which appeared on
`
`www.reuters.com on April 07, 2009;
`
`1.37.
`
`“Maruti steps up Dzire production”, which appeared on www.mydigitaflifecom
`
`on April 07, 2009;
`
`138.
`
`“Motown beatdown”, which appeared on ww.colubusdispatch.com on Aprii 07,
`
`2009;
`
`139.
`
`“Motown Blues: The Epic Fail of Chris Osgood”, which appeared on
`
`wwwbleacherrepoztcom on April 07, 2009;
`
`140.
`
`“Mowed down in Motown”, which appeared on www.themomingsun.com on
`
`Aprii 07, 2009;
`
`55040.00084/45’7531
`
`1 3
`
`
`
`141.
`
`“Spartans give Motown green-and—white buzz”, which appeared on
`
`“Wihenewstribnnecom on April 07, 2009;
`
`142.
`
`“Thousands Flocked to Breslin Center to Watch Big Game”, which appeared on
`
`www.wlns.com on April 07, 2009.
`
`143.
`
`“Pimp My Polar Bear”, which appeared on wwnbcchicagocom on April 08,
`
`2009',
`
`I44.
`
`“Motown Showdovm this weekend”, which appeared on www.mlive.com on
`
`Aprii 09, 2009;
`
`145.
`
`“Predatorsdon’t sweat Detroit trip”, which appeared on wwwtennesseancom on
`
`April 09, 2009;
`
`E46.
`
`“Morning Shootaround: Welcome, Redundancy, and Beating the Nets”, which
`
`appeared on wwmotownstringmusiccom on April 10, 2009;
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`147.
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`“Anderson’s success a product of hard work”, which appeared on
`
`www.mewsok.corn on April 12, 2009;
`
`I48.
`
`“Breaking down Pistons’ playoff scenarios”, which appeared on wwwfreepcom
`
`on April 12, 2009;
`
`149.
`
`“NBA Today: Pistons Guaranteed non-Winning Season”, which appeared on
`
`www.rotorob.com on April 12, 2009;
`
`150.
`
`“Five surprises from Motown Showdown”, which appeared on www.miive.con1
`
`on April 13, 2009;
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`151.
`
`“Granhoim touts Michigan to nation”, which appeared on wwwfreepcom on
`
`April 13, 2009;
`
`55040.00084/457531
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`1 4
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`
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`152.
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`“April Positioning Showdown in Motown ~ Chicago Bulls at Detroit Pistons”,
`
`which appeared on wvmbetuscom on April 13, 2009;
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`153.
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`“An Auto Merger Could Pay Off’, which appeared in The New York Times on
`
`Aprii 14, 2009;
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`154.
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`“Even the Casinos in Detroit Don’t Want Allen Iverson”, which appeared on
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`wwwslamonlineeom on April 14, 2009;
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`155.
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`“Motown CC Win Inaugural Michigan Sixes. Greater Detroit Colts Triumph in
`
`Junior Division”, which appeared on WWW.dreamticket.com on April 15, 2009;
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`156.
`
`“Franklin iands in Motown”, which appeared on www.clumbiatribune.com on
`
`April 15. 2009;
`
`157.
`
`“Is Flip Saunders Headed to Washington?”, which appeared on
`
`wwwbleacherrepoficom on April 15, 2009;
`
`158.
`
`“Motown suffers a bout of C sickness”, which appeared on www.cinaindiacorn on
`
`April 15. 2009;
`
`159.
`
`“Per Favore! Fiat Asks for Money”, which appeared on wwwthebigmoaeycom
`
`on April 15, 2009;
`
`160.
`
`“Recharging Detroit”, which appeared on www.cnnmoneyeom on April 15,
`
`2009;
`
`161.
`
`“Tigers close out strong homestand with torn Sox”, which appeared on
`
`www.canada.com on April 15, 2009;
`
`162.
`
`“Wheels: Challenger, a reminder of past, argues for survivai of Chrysier", which
`
`appeared on www.post—gazette.com on April 16, 2009;
`
`55040,00084f45758.l
`
`15
`
`
`
`163.
`
`“More plant closings, job cuts due at GM”, which appeared on
`
`www.cnnrnoneycom on April 17, 2009;
`
`164.
`
`“Stuttgart Is Driving Old Europe Past Detroit: Norman Pearlstine”, which
`
`appeared on wwwbloombergcom on April 16, 2009;
`
`I65.
`
`“Motown blues of Detroit green?”, which appeared on www.therealnews.com on
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`April 18, 2009;
`
`166.
`
`“Columbus will try and stop octopus—toting Wings fans”, which appears on
`
`Wfreepeorn on April 20, 2009',
`
`167.
`
`' “Govern-ator To Detroit: You’ll Be Backl”, which appeared on www.cnbc.com
`
`on April 20, 2009;
`
`168.
`
`“Lions hope facelift can generate wins”, which appeared on www.2nesn.com on
`
`April 20, 2009;
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`169.
`
`“The clock is ticking on a Motown turnaround”, which appeared on
`
`www.freep_.com on April 20, 2009;
`
`170.
`
`“The Thinking Behind the Lions Taking Matt Stafford for Number One”, which
`
`appeared on wwwbleacherreportcom on April 20, 2009;
`
`171.
`
`“A mutant Honda 305 in Motown”, which appeared on www.autonews.com on
`
`April 21, 2009;
`
`£72.
`
`“Lebron, the Most Hated man in Motown ~ Detroit vs. Clevelan ”, which
`
`appeared on wwwbetnscom on April 21, 2009;
`
`173.
`
`“Motown letdown”, which appeared in U Weeka on April 22; 2009;
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`174.
`
`“Rollin” to Motown: Cavs take 20 lead in series”, which appeared on www.mews»
`
`harlodcom on April 22, 2009;
`
`55040.90084!45758.1
`
`16
`
`
`
`I75.
`“Remaking Michigan, Retooling Detroit”, which appeared on wwnprorg on
`April 23, 2009;
`I
`
`“The Beat Report: Motown: Signed, sealed, delivered, it’s yours”, which appeared
`176.
`on www.mainecampus.com on April 23, 2009;
`
`177.
`
`“Ford beats 1Q earnings estimates, delivering hope to Motown”, which appeared
`
`on WdetneWSeom on April 24, 2009;
`
`178.
`
`“NPR: Detroit Faiis to Capitalize on Music Scene”, which appeared on
`
`www.mefixmagcom on April 24, 2009;
`
`179.
`
`“The Toxicity Report: Detroit Lions’ draft histOry”, which appeared on
`
`urwweportingnewscom on April 24, 2009;
`
`180.
`
`“Wiliiam Greiner: Why GM and Chrysler will keep us mired in recession", which
`
`appeared on www.economy.kansasci1y.com on April 24, 2009;
`
`181.
`
`“Stafford ready to be the man in Motown”, which appeared on wwwnflnrcom on
`
`April 24, 2009;
`
`182.
`
`“How Motown became Notovm: Can Detroit climb out of the gutter?”, which
`
`appeared on WW’W.II].i1'I'OI‘.CO.uk on April 25, 2009;
`
`183.
`
`“NFL Draft: Reeves sees no renewal for Motown”, which appeared on
`
`'www.aic.com on April 25, 2009;
`
`184.
`
`“Motown or Gotham? GM, Chrysler Weighing the Pros and Cons”, which
`
`appeared on www.biogs.wsi.com on April 27, 2009;
`
`185.
`
`“While We’re Waiting
`
`The End of and Era in Motown”, which appeared on
`
`www.wiatingfomextyear.com on April 27, 2009;
`
`55040.00084/45758.§
`
`l7
`
`
`
`186.
`
`“Move over Motown we’re taking over”, which appeared on
`
`www.momalkrefiectoreom on Aprii 28, 2009;
`
`187.
`
`“Council OKs deal to make Motown backdrop of ‘Parking Wars’“, which
`
`appeared on wwwdetnewscom on April 28, 2009;
`
`188.
`
`“Women’s culture zine creates city guide to find Motown’s “real heat”, which
`
`appeared on www.modelmedia.com on April 28, 2009;
`
`189.
`
`‘lBlinebury: Doomsday in Detroit?”, which appeared on www.hoopsworld.com on
`
`April 29, 2009;
`
`190.
`
`“Key Lenders Agree to Chrysler Debt Swap”, which appeared on www.wsj.com
`
`on April 29, 2009;
`
`191.
`
`“Michigan is Still MoTown For Asian Carmakers As Well As GM-Ford-
`
`Chrysler”, which appeared in Business Week on April 29, 2009;
`
`I92.
`
`“Larry Foote to be Released, Mot0wn Bound?”, which appeared on
`
`www.b1eacherrepolt.com on April 30, 2009.
`
`193.
`“Mathew Stafford Will Exercise the “Curse of Bobby Layne”, which appeared on V
`www.bleacherreport.com on April 30, 2009;
`i
`
`194.
`
`“The Chrysler Bankruptcy: Motown Shutdown”, which appeared in Forbes on
`
`April 30, 2009;
`
`195.
`
`“Quackery and faith healing in Motown {Respectful lnsolenceT’, which appeared
`
`
`on www.mdrelesssys-coacom on April 30, 2009;
`
`£96.
`
`“The Motown Conundrum”, which appeared on wwwbleaeherreportcom on
`
`Aprii 30, 2009;
`
`55040.00084/45758J
`
`1 8
`
`
`
`197.
`
`“Detroit greets Chrysler bankruptcy with dismay”, which appeared on
`
`wwwhaitinewsnet on May 01, 2009;
`
`198.
`
`“Comparison: 2009 BMW M5 vs 2009 Cadiltac CTS—V” in Motor Trend on May
`
`03, 2009;
`
`199.
`
`“Detroit Rock City”, which appeared on wwwbusinessmirroreom on May 03,
`
`2009;
`
`200.
`
`“Detroit To Be Featirred On ‘Dr. Phil’ Tonight”, which appeared on
`
`wwwwicom on May 04, 2009;
`
`201. “Undiscovered Band of the Month: Amelia Dunaway”, which appeared in Filter
`
`Magazine on May 05, 2009;
`
`I
`
`202.
`
`“2011 Detroit Auto Show: Heiio, Novi?”; which appeared on
`
`wwthecarconnectioncom on May 06, 2009;
`
`203.
`
`“Bing wins mayoral race in Motown”, which appeared on www.canada.com on
`
`May 06, 2009;
`
`204.
`
`“Detroit Elects Post—mene mayor - It’s Gonna Be a Hot Summer”, which
`
`appeared on www.blackvoices.com on May 06, 2009;
`
`205.
`
`“Catching Up With
`
`Akron/Family”, which appeared in Paste Magazine on
`
`May 07, 2009;
`
`206.
`
`“Ramirez will still be toved in L.A.”, which appeareé on
`
`wwwinsidethebayareacom on May 09, 2009;
`
`207.
`
`“Stanley Cup Playoff Betting”, which appeared on www.1'ustbet.com on May 10,
`
`2009;
`
`208.
`
`“Chuck Deity”, which appeared on waorldominecom on May 11, 2009
`
`55040.00084M57581
`
`'
`
`19
`
`
`
`209.
`
`“Frank Girardot: Twittering Whiie Santa Barbara burns”, which appeared on
`
`wwwwhittierdailynewscom on May 11, 2009;
`
`210.
`
`“Motown Move? GM Speculates on Moving From Detroit”, which appeared on
`
`wwwthecarconnectioncom on May 11, 2009;
`
`211.
`
`“What happens to the Motor City if GM hits the road?”, which appeared in the
`
`Financial Post on May 11, 2009;
`
`2E2
`
`“DJ Hero, Band Hero and Guitar Hero 5 Announced”, which appeared on
`
`wwslippcrybrickcom on May 12, 2009; ‘
`
`213.
`
`“Coach 1220 on Broadway!”, which appeared on wwwwzzrnliicom on May 12,
`
`2009;
`
`214.
`
`“GM‘s headquarters could be lost to economic crunch says CEO”, which
`
`appeared on www.canada.c0m on May 12, 2009;
`
`215.
`
`“It’s an august Aprii for automakers”, which appeared on www.cinaindia,com on
`
`May 12, 2009;
`
`216.
`
`“World Products” Motown LS Engine w Best Of Both Worids”, which appeared
`
`on www.vetteweb.com on May 12, 2009;
`
`217.
`
`“FS Detroit Has Ratings Momentum for Game 7 In Motown”, which appeared on
`
`www.multichannei.com on May 14, 2009;
`
`218.
`
`“Nelson Sends Letter Warnng of Serious Job Loss from Planned Auto Dealership
`
`Closings”, which appeared on www.chadrad.com on May 14, 2009;
`
`21
`
`“Urgency in Motown”, which appeared cu wwwlheglobeandmailcom on May
`
`14, 2009;
`
`55040.00084f45758.1
`
`20
`
`
`
`220.
`
`“l’uek drops on CaneswPens series Monday”, on www.mewsl4.com on May 15,
`
`2006;
`
`221.
`
`“There’s Always Beer Afterwards”, which appeared in The Ann Arbor Chronicle
`
`on May 20, 2009;
`
`222.
`
`“Armstrong: No frown leaving Motown”, which appeared in The Denver Post 9n
`
`May 12, 2009;
`
`223.
`
`“ESPNChicago writer: Rivalry with Motown holds nice memories for Windy
`
`City”, which appeared on wwwfreepeom on May 16, 2009;
`
`224.
`
`“Cadillac CTsuV”, which appeared in The New York Times on May 17, 2009;
`
`225.
`
`“Red—hot Rangers bound for Motown”, which appeared on
`
`http:lltexasrangersmibeom on May 17, 2009;
`
`226.
`
`“Epiphany (2009)”, which appeared on www.cw.oom on May 18, 2009;
`
`227.
`
`“Media paints grim portrait of Detroit”, which appeared in The Detroit News on
`
`May E9, 2009;
`
`228.
`
`“$300M sports complex proposed for Vandalia”, which appeared in the St. Louis
`
`Business Journal 011 May 20, 2009;
`
`229.
`
`“ID—Train earns first Tigers win”, which appeared on wwwfreepeom on May 20,
`
`2009;
`
`230.
`
`“Got Tickets?: The D—Train Has Finally Arrived In Motownl”, which appeared on
`
`http://bleaeherreport.com on May 20, 2009;
`
`231.
`
`“Motown Turnaround? 2009 Lions Look to The Future”, which appeared on
`
`http://bieacherreporteom on May 20, 2009;
`
`sso40noos4r4575az
`
`21
`
`
`
`232.
`
`“Souifol Symphony: The Motown Sound”, which appeared on
`
`www.citypaper.com on May 20, 2009;
`
`233.
`
`“Texas Rangers manage just one hit in 4-0 loss”, which appeared in The Dallas
`
`Morning News on May 20, 2009;
`
`234.
`
`“Thinking about Arrogance”, which appeared in the Baltimore Chronicle &
`
`Sentinel on May 20, 2009;
`
`235.
`
`“Motown, Chi—town share more than good hockey teams”, which appeared in The
`
`Detroit News on May 21, 2009;
`
`236.
`
`“Mowed Down in Motown”, which appeared on http:/fblogs.daiiasobservercom
`
`on May 21, 2009;
`
`237.
`
`“Car industry crisis takes toil in Motown”, which appeared on www.watoday.com
`
`on May 22, 2009;
`
`238.
`
`“Motown misery: Texas Rangers lose 11‘“ straight in Detroit”, which appeared in
`
`The Dallas Morning News on May 22, 2009;
`
`239.
`
`“Motown to Cowtown? What kind of farms would. work in Detroit?”, which
`
`appeared on wwwfreepeom on May 22, 2009;
`
`240.
`
`“Motown’s money machine”, which appeared on wwwdenvegposteom on May
`
`22, 2009;
`
`241.
`
`“Rockies spin some Motown magic”, which appeared on wwwdenvegpostcom
`
`on May 24, 2009;
`
`242.
`
`“Scott gets fresh start in BuffalO”, which appeared on hgpzllbufacoutcom on
`
`May 24, 2009;
`
`55040.00084f45758.l
`
`22
`
`
`
`243.
`
`“Motown’s new hits come from Red Wings defensemen”, which appeared in USA
`
`Today on May 26, 2009;
`
`244.
`
`“‘D—Train’ starting to settle in Motown”, which appeared on
`
`http://blackathlete.net on May 26, 2009;
`
`245.
`
`“Detroit: Ain’t Too Proud to Beg”, which appeared on wwwabcnetau on May
`
`26, 2009; I
`
`246.
`
`“Daunte Culpepper: Motown Need You to get Your Roll On”, which appeared on
`
`hgp:/fbleaeherrepo_rt.com on May 26, 2009;
`
`247.
`
`“Michigan Will Lead the Green Industrial Revolution”, which appeared on
`
`whuffing’gonpostcom on May 27, 2009;
`
`248.
`
`“Nothing Can Stop Eminem’s Relapse”, which appeared on www.conlinecom oh
`
`May 27, 2009;
`
`249.
`
`“Summer enteztainment hits all the right notes at Legacy Village”, which
`
`aopeared on http://hlogclevelandcom on May 27, 2009;
`
`250.
`
`“Detroit schools’ moment?", which appeared in The Detroit News on May 28,
`
`2009;
`
`251.
`
`“Performance Royalty showdown in Motown”, which appeared on wmvrbncom
`
`on May 28, 2009;
`
`252.
`
`“Detroit bent on spurning North American International Auto Show”, which
`
`appeared on http://blogmlivecom on May 29, 2009;
`
`253.
`
`“How Wall Street Almost Killed Detroit”, which appeared on
`
`wwwihebigmoneycom on May 31, 2009;
`
`55040.00084/45758.3
`
`23
`
`
`
`254.
`
`“Reality TV a popular career move for Motown.’s jobless”, which appeared on
`
`www.guardian.co.uk on May 31, 2009;
`
`255.
`
`“Red Wings take Game One”, which appeared on www.wjbdradio.com on May
`
`31, 2009;
`
`256.
`
`“Former Rays’ pitcher Edwin Jackson still mowing them down in Motown”,
`
`which appeared on http:/fblogs.tampabay.com on June 1, 2009;
`
`257.
`
`“Good news for Motown: General Motors will stay in Detroit”, which appeared
`
`on http://content.usatodaxcom on June 1, 2009;
`
`258.
`
`“Meiown’s spirit needs Lord Stanley more”, which appeared on wwwfreepcom
`
`on June I, 2009;
`
`259.
`
`“NHL looks into Caps’ steroid allegations", which appeared on www.canada.com
`
`on June 1, 2009;
`
`260.
`
`2 “Moving from Motown to Cowtown”, which appeared on www.modelmediaeom
`
`on June 2, 2009;
`
`26}.
`
`“Struggling Motown loses the heat”, which appeared on wwfmom on June 2,
`
`2009;
`
`262.
`
`“A Finals Dream Deferred”, which appeared on wwwpecom on June 3, 2009;
`
`263.
`
`“Motown And The Steel City Hit The ice For The Stanley Cup”, which appeared
`
`on wwwjauntedeom on June 4, 2009;
`
`264.
`
`“Motown Motion Picture Studio Unveiled”, which appeared on www.wxyz.com
`
`on June 4, 2009;
`
`265.
`
`“Sports Redux: Beckett, Bats In Motown Bash”, which appeared on
`
`http://bostonisteom on June 4, 2009;
`
`55040000841453“
`
`'
`
`-
`
`24
`
`
`
`266.
`
`I “Motown blues”, which appeared on “wwstraitstimescom on June 5, 2009;
`
`267.
`
`“Pittsborg columnist: Motown Stanley Cup parade officially Steal—ed”, which
`
`appeared on wwfieepcom on June 5, 2009;
`
`268.
`
`“Bloggers of the World, Unite! 300 wins, Sad Days in Motown”, which appeared
`
`on http:/fbieaeherreporteom on June 8, 2009;
`
`269.
`
`“Detroit’s Youth: Stay or go?”, which appeared on http://moneycnncom on June
`
`8, 2009;
`
`270.
`
`“Familiar ring”, which appeared on wwwphillycom on June 8, 2009;
`
`271.
`
`“Motown wonders: Where did our love go‘?”, which appeared on www.mstarcom
`
`on June 8, 2009;
`
`272.
`
`“Motown String Music”, which appeared on ww.motownstfingmusic.com on
`
`June 10, 2009;
`
`273.
`
`‘2, 3—wheelers save motoWn the blushes in May”, which appeared on June 9,
`
`2009;
`
`274.
`
`“Jacksonville Mass choir perfects Motown sound”, which appeared on
`
`Wfimcksonviilecom on June 9, 2009;
`
`275.
`
`“The Asteroids Galaxy Tour: BeatCrave Fav”, which appeared on
`
`http://beatcravecom on June 11, 2009;
`
`276.
`
`“Searching For The Cheapest Way To Motown?”, which appeared on
`
`www.mficom on June 10, 2009',
`
`I
`
`277.
`
`“Michigan Works to Remake Itself Without King Auto”, which appeared in The
`
`New York Times on June 10, 2009;
`
`55040.000841457581
`
`25
`
`
`
`278.
`
`“Mid—Week Ramblings”, which appeared on httyzlfblogs.ajc.com on June 10,
`
`2009;
`
`279.
`
`“THN at the Stanley Cup: It all boils down to a Motown Game 7", which
`
`appeared on Willehockqnewseom on June 10, 2009;
`
`280.
`
`“Motown seeks duty cuts, sops & easier credit”, which appeared in The Economic
`
`Times on June 11, 2009;
`281.
`“Music Fills The Air Sendays & Wednesdays At North School Par ”, which
`
`appeared on www.1'oumai-tepics.com on June ll, 2009;
`
`282.
`
`“On A Wing And Possibly A Prayer”, which appeared on
`
`hgngfbleachcrreportcom on June 11, 2009;
`283.
`“Summer In the Park”, which appeared on www.tv20detroit.com on June 12,
`
`2009;
`
`DATED: June 16, 2009
`
`Respectfully submitted,
`
`
`
`
`
`Lawren Y. Iser
`Attorney for Applicant Mattel, Inc.
`
`55040.00084/45758.l
`
`26
`
`
`
`ExhibitA '
`
`fixhibit: A
`
`Page: 27
`
`
`
`6/12/2009
`W '
`
`Trademark Eiectronic Search Syste...
`waited Emma W‘aterrii; and Trademark @fiim
`
` Homo} aim indent] Eaai‘fii‘ll
`Trademarks > Trademark Electronic Search System (TESS)
`
`$09592"?! Guidm‘l contamgl fiafififinfififil amz mortal News?! mg;
`
`TESS was last updated on Fn’ Jun 12 03
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