`ESTTA278219
`ESTTA Tracking number:
`04/15/2009
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`Notice of Opposition
`
`Notice is hereby given that the following party opposes registration of the indicated application.
`Opposer Information
`
`Name
`Granted to Date
`of previous
`extension
`Address
`
`AuthenTec, Inc.
`04/15/2009
`
`100 Rialto Place Suite 100
`Melbourne, FL 32901
`UNITED STATES
`
`Attorney
`information
`
`Bridget Heffernan Labutta
`Allen, Dyer, Doppelt, Milbrath & Gilchrist, P.A.
`255 S. Orange AvenueSuite 1401
`Orlando, FL 32801
`UNITED STATES
`blabutta@addmg.com, dsigalow@addmg.com Phone:407-841-2330
`Applicant Information
`
`Application No
`Opposition Filing
`Date
`International
`Registration No.
`Applicant
`
`77163242
`04/15/2009
`
`NONE
`
`Publication date
`Opposition
`Period Ends
`International
`Registration Date
`
`12/16/2008
`04/15/2009
`
`NONE
`
`Route1 Inc.
`155 University Avenue, Suite 1920
`Toronto, Ontario, M5M3B7
`CANADA
`Goods/Services Affected by Opposition
`
`Class 009.
`All goods and services in the class are opposed, namely: Computer software that provides a secure
`remote access connection service, delivered through any Internet Protocol enabled network
`
`Grounds for Opposition
`
`False suggestion of a connection
`Priority and likelihood of confusion
`Dilution
`
`Trademark Act section 2(a)
`Trademark Act section 2(d)
`Trademark Act section 43(c)
`
`Mark Cited by Opposer as Basis for Opposition
`
`U.S. Registration
`No.
`Registration Date
`
`2740918
`
`07/29/2003
`
`Application Date
`
`11/16/1999
`
`Foreign Priority
`
`NONE
`
`
`
`Word Mark
`Design Mark
`
`TRUEPRINT
`
`Date
`
`Description of
`Mark
`Goods/Services
`
`NONE
`
`Class 009. First use: First Use: 1999/12/00 First Use In Commerce: 2001/09/00
`Authentication and identification products, namely, computer software, biometric
`matching software, biometric indexing software, and cryptographic protection
`software, and related hardware, namely, fingerprint sensors and associated
`computer chips and electronic circuitry for use in determining the identity of
`unknown persons and to verify the claimed identity of persons
`
`Attachments
`
`75850660#TMSN.gif ( 1 page )( bytes )
`KE1708.PDF ( 5 pages )(200379 bytes )
`
`Certificate of Service
`
`The undersigned hereby certifies that a copy of this paper has been served upon all parties, at their address
`record by First Class Mail on this date.
`
`Signature
`Name
`Date
`
`/David L. Sigalow/
`David L. Sigalow
`04/15/2009
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of Application Serial No. 77/163,242
`Published in the Official Gazette on December 16, 2008
`
`AuthenTec, Inc.,
`
`v.
`
`Route], Inc.,
`
`Opposer,
`
`Opposition No:
`Mark: TRUOFFICE
`
`Applicant.
`
`I
`
`NOTICE OF OPPOSITION
`
`Opposer AuthenTec, Inc., a Delaware corporation whose address is 100 Rialto Place,
`
`Suite 100, Melbourne, Florida, 32901, believes it will be damaged by registration of the mark
`
`TRUOFFICE, shown in U.S. Application Serial No. 77/163,242, in International Class 9 for
`
`“computer software that provides a secure remote access connection service, delivered through
`
`any Internet Protocol enabled network,” and hereby opposes registration of the application,
`
`pursuant to an Extension of Time allowed on December 30, 2008.
`
`As grounds for opposition it is alleged that:
`
`1.
`
`Applicant seeks to register the mark TRUOFFICE as a trademark for the above-
`
`described goods, as evidenced by the publication of the mark in the Official Gazette on
`
`December 16, 2008.
`
`2.
`
`Applicant filed its application on April 26, 2007, claiming priority further to
`
`corresponding Canadian Trademark Application No. 1,339,332, which has since issued into
`
`
`
`Canadian Registration No. TMA 718,639. Applicant’s application is also based its intent to use
`
`the mark in commerce within the United States.
`
`3.
`
`Opposer is the owner of the U.S. Trademark Registration No. 2,740,918 for the
`
`mark TRUEPRINT, which registered on the Principal Register on July 29, 2003 and was based
`
`upon an application filed on November 16, 1999.
`
`4.
`
`Opposer is also the owner of the following pending TRUE-based applications, all
`
`of which (with the exception of Application Serial No. 77/451,639 for the mark TRUEME) have
`
`been allowed:
`
` Mark
`
`TRUEFINGER
`TRUEVAULT
`TRUEMAGIC
`
`A lication Serial No.
`
`78/785,002
`77/206,847
`77/ 1 83 299
`
`
`
`Filing Date
`
`
`
`June 15, 2007
`June 15, 2007
`Ma 17, 2007
`Ari127,2007
`March 15, 2007
`March 13,2007
`Aril18, 2008
`
`
`
`5.
`
`Opposer has used its TRUEPRINT mark in commerce since at least as early as
`
`September 2001 in connection with the products set
`
`forth in the registration, namely,
`
`“authentication and identification products, namely, computer software, biometric matching
`
`software, biometric indexing software, and cryptographic protection software, and related
`
`hardware, namely, fingerprint sensors and associated computer chips and electronic circuitry for
`
`use in determining the identity of unknown persons and to verify the claimed identity of persons”
`
`in International Class 9.
`
`6.
`
`Opposer is also the owner of various other trademarks directed to authentication
`
`and identification products,
`
`including AUTHENTEC (U.S. Registration No. 3,434,565),
`
`PERSONAL SECURITY FOR THE REAL WORLD (U.S. Registration No. 2,470,452),
`
`2
`
`
`
`ENTREPAD (U.S. Registration No. 2,801,537), THE POWER OF TOUCH (U.S. Registration
`
`No. 3,105,183), and A (& Design) (U.S. Registration No. 2,447,074).
`
`7.
`
`Opposer has extensively promoted and continuously used its marks throughout
`
`the United States, and has made significant sales of products under each of its marks and, as a
`
`result, Opposer’s marks have developed valuable goodwill.
`
`8.
`
`9.
`
`The TRUE-based marks are distinctive and valuable assets of Opposer.
`
`Opposer used the mark TRUEPRINT in commerce prior to Applicant’s filing of
`
`its application and, on information and belief, before Applicant’s first use of its mark in
`
`connection with its goods within the United States.
`
`10.
`
`Applicant’s mark TRUEOFFICE is confusingly and deceptively similar to
`
`Opposer’s marks TRUPRINT,
`
`as well as Opposer’s other TRUE-based applications.
`
`Applicant’s mark is very similar in sight, sound, connotation, and commercial impression to
`
`Opposer’s TRUE-based marks.
`
`11.
`
`Applicant’s goods, “computer sofiware that provides a secure remote access
`
`connection service, delivered through any Internet Protocol enabled network” in International
`
`Class 9, are very similar and closely related to Opposer’s authentication and identification
`
`products, which are also in International Class 9.
`
`12.
`
`Upon infonnation and belief, Applicant’s channels of trade and class of
`
`purchasers are likely to be very similar to those of Opposer.
`
`13.
`
`Due to the similarity between Applicant’s mark and goods and Opposer’s marks
`
`and goods, and the likely similarity of the respective channels of trade and classes of purchasers,
`
`the registration of Applicant’s mark will cause great damage and injury to Opposer. Persons
`
`familiar with Opposer’s TRUEPRINT mark and goods would likely confuse Applicant’s
`
`3
`
`
`
`services with those provided by Opposer. Any defect, objection or fault found with Applicant’s
`
`goods offered under the mark TRUOFFICE may reflect upon and expose Opposer to liability,
`
`and seriously injure the reputation that Opposer has established for its goods.
`
`14.
`
`If Applicant is granted the registration herein opposed, it would obtain at least a
`
`primafacie exclusive right to use the mark TRUOFFICE in the United States, thereby causing
`
`damage and injury to Opposer.
`
`15.
`
`Registration of Applicant’s mark is likely to dilute the ability of Opposer’s marks
`
`to identify and distinguish Opposer as the source of its goods in the United States and
`
`worldwide.
`
`WHEREFORE, Opposer prays that Application Serial No. 77/163,242 be rejected, that
`
`this opposition be sustained, that the registration sought by Applicant be refused, and that
`
`Opposer be granted such additional relief as the Board deems just and proper.
`
`Respectfully submitted,
`
`
`/David L. Sigalow/
`
`David L. Sigalow, Esquire
`Allison R. Imber, Esquire
`Allen, Dyer, Doppelt,
`Milbrath & Gilchrist, P.A.
`255 South Orange Avenue, Suite 1401
`Orlando, Florida 32801
`Phone: 407 841-2330
`Fax: 407 841-2343
`
`E-mail: dsigalow@addmg.com
`aimber@addmg.com
`
`Attorneys for Opposer
`AuthenTec, Inc.
`
`
`
`CERTIFICATE OF SERVICE
`
`I certify that a true and correct copy of the foregoing was served by First Class Mail on
`April 15, 2009 to:
`
`Susan M. Freeciman, Esq.
`Nixon Peabody, LLP
`401 9111 St. NW STE 900
`
`Washington, DC 20004-2145
`
`Us