Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA374010
`ESTTA Tracking number:
`10/19/2010
`
`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
`
`Party who filed
`Extension of time
`to oppose
`Relationship to
`party who filed
`Extension of time
`to oppose
`
`Cynthia Callendar
`10/20/2010
`
`1870 Jasmine Joy Ct
`Las Vegas, NV 89117
`UNITED STATES
`CynthiaCallendar
`
`An unintentional typographical error occurred when Opposer, an individual,
`requested her first extension of time to oppose, causing her first and last name
`to run together. The only change being made herein is the addition of a space
`between Opposer's first and last name.
`
`Attorney
`information
`
`Justin G. Sanders
`Mind Law Firm
`2424 S.E. Bristol Street, Suite 300
`Newport Beach, CA 92660
`UNITED STATES
`jsanders@mindlawfirm.com, jsartain@mindlawfirm.com Phone:949-250-5800
`Applicant Information
`
`Application No
`Opposition Filing
`Date
`Applicant
`
`77927300
`10/19/2010
`
`Publication date
`Opposition
`Period Ends
`
`06/22/2010
`10/20/2010
`
`Brooke Medlock
`1839 S 139th Street
`Omaha, NE 68144
`UNITED STATES
`Goods/Services Affected by Opposition
`
`Class 020.
`All goods and services in the class are opposed, namely: pillows
`
`Grounds for Opposition
`
`The mark is merely descriptive
`Genericness
`
`Trademark Act section 2(e)(1)
`Trademark Act section 23
`
`Attachments
`
`ANSOG.11134 - Notice of Opposition.pdf ( 8 pages )(39653 bytes )
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`

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`ANSOG.11134 - Exhibit A.pdf ( 4 pages )(310500 bytes )
`ANSOG.11134 - Exhibit B.pdf ( 3 pages )(192266 bytes )
`ANSOG.11134 - Exhibit C.pdf ( 5 pages )(46983 bytes )
`ANSOG.11134 - Exhibit D (part 1).pdf ( 12 pages )(483461 bytes )
`ANSOG.11134 - Exhibit D (part 2).pdf ( 12 pages )(2365199 bytes )
`ANSOG.11134 - Exhibit D (part 3).pdf ( 12 pages )(448835 bytes )
`ANSOG.11134 - Exhibit D (part 4).pdf ( 12 pages )(721534 bytes )
`ANSOG.11134 - Exhibit D (part 5).pdf ( 4 pages )(430699 bytes )
`ANSOG.11134 - Exhibit D (part 6).pdf ( 3 pages )(224491 bytes )
`ANSOG.11134 - Exhibit D (part 7).pdf ( 14 pages )(821766 bytes )
`
`Certificate of Service
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`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
`
`/Justin G. Sanders/
`Justin G. Sanders
`10/19/2010
`
`

`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`Application Serial No.: 77/927,300
`Mark:
`THE FACELIFT PILLOW
`
`__________________________________________
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`CYNTHIA CALLENDAR,
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`an individual,
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`) Opposition No.: _______________
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`Opposer,
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`BROOKE MEDLOCK,
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`an individual,
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`Applicant.
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`__________________________________________)
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`NOTICE OF OPPOSITION
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`Opposer Cynthia Callendar (“Opposer”) believes that she will be damaged by
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`
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`registration of the trademark THE FACELIFT PILLOW as shown in the above-referenced
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`trademark application Serial No. 77/927,300 (the “Application”) and hereby opposes the same.
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`The Application was published for opposition on June 22, 2010. Opposer obtained a
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`30-day extension of time up until August 21, 2010, and then subsequently obtained a further
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`60-day extension of time up until October 20, 2010. Therefore, this Opposition is timely.
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`As grounds for opposition, Opposer alleges that:
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`PARTIES
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`1.
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`Opposer is an individual and a citizen of the United States, having an address at
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`1870 Jasmine Joy Court, Las Vegas, Nevada 89117.
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`2.
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`Opposer, directly or through affiliates, has developed and is in the process of
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`developing pillow products to be used for various purposes, including for reducing facial
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`wrinkling, by strategically lifting a user’s face, as a substitute for or prevention of the need for
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`Notice of Opposition - 1
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`a face-lift procedure, as well as for use in post-operative face-lift recoveries. As such, Opposer
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`has a real commercial interest in the term “facelift pillow” and the exclusive right to use such a
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`term granted to competitors in connection with identifying similar pillow products.
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`Furthermore, Opposer has an interest in using the term generically or, at the very least,
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`descriptively in connection with said pillow products.
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`3.
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`Upon information and belief, Brooke Medlock (“Applicant”) is an individual
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`and a citizen of the United States, having an address at 1839 S. 139th Street, Omaha, Nebraska
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`68144.
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`GENERAL ALLEGATIONS
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`4.
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`Applicant filed the Application on February 3, 2010, for the mark THE FACE
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`LIFT PILLOW, subsequently amended to THE FACELIFT PILLOW for “pillows” in
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`International Class 20, alleging intended use in commerce in the United States.
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`5.
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`On May 5, 2010, through an Examiner’s Amendment, the Application was
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`amended to include the disclaimer statement, “No claim is made to the exclusive right to use
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`‘PILLOW’ apart from the mark as shown.”
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`2010.
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`6.
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`7.
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`The Application was published for opposition in the Official Gazette on June 22,
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`Upon information and belief, Applicant is the current owner of at least one
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`related Internet domain, www.myfaceliftpillow.com (the “Website”), as evidenced by the
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`WHOIS search results provided through GoDaddy.com. A true and correct copy of said
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`WHOIS search results is appended to this Notice of Opposition as Exhibit A.
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`8.
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`Upon information and belief, through at least the Website, Applicant has
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`described at least one of her pillow products, expressly referred to as “The Facelift Pillow,” as
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`being “an alternative to facelift surgery.” True and correct copies of screenshot captures of
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`pages of the Website as they appeared on August 28, 2010 and September 14, 2010,
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`respectively, retrieved from Google’s cached images of the Website, is appended to this Notice
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`of Opposition as Exhibit B (certain highlights added by Google).
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`9.
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`Upon information and belief, through another website that is currently, or at
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`Notice of Opposition - 2
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`least at one time was, owned and operated by Applicant or an affiliate of Applicant’s,
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`www.startechnologies.mobi, at least one of Applicant’s products, expressly referred to as “The
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`Facelift Pillow,” is again described as an alternative to facelift surgery. True and correct copies
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`of screenshot captures of pages of the www.startechnologies.mobi website as they appeared on
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`September 12, 2010, retrieved from Yahoo!’s cached images of that website, is appended to
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`this Notice of Opposition as Exhibit C (certain highlights added by Yahoo!).
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`10.
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`Upon information and belief, at least one of Applicant’s products, expressly
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`referred to as “The Facelift Pillow,” purports to reduce pressure on the user’s face so that the
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`formation of facial wrinkles is reduced or eliminated.
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`11.
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`Upon information and belief, the reduction of pressure referred to in paragraph
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`10 above is accomplished by at least a portion of the user’s face being at least partially
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`lifted/elevated by the pillow product so as to reduce the amount of contact between the user’s
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`face and the pillow or underlying sleep surface.
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`12.
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`Upon information and belief, it is common for people to use either traditional or
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`specially designed pillows to lift (i.e., elevate) and/or strategically support their face as an
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`alternative to, or after receiving, a surgical face-lift procedure.
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`13.
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`Upon information and belief, there are currently numerous pillow products
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`being marketed and sold in the United States by various entities for the expressly stated
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`purpose of lifting and/or strategically supporting a person’s face as an alternative to, or after
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`receiving, a surgical face-lift procedure, in at least four instances of which such third parties
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`expressly refer to such pillows using the phrase “facelift pillow” or a common alternate spelling
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`thereof (i.e., “face lift pillow” or “face-lift pillow”). True and correct copies of screenshot
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`captures of certain discovered websites currently advertising such products are appended to this
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`Notice of Opposition as Exhibit D (highlights added).
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`GROUNDS FOR OPPOSITION
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`
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`A. Applicant’s Proposed Mark is Generic as Applied to Applicant’s
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`Intended Goods and is Not Entitled to Registration.
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`14.
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`The allegations set forth in paragraphs 1-13 of this Notice of Opposition are
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`Notice of Opposition - 3
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`incorporated as though fully set forth herein.
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`15.
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`Generic terms are terms that the relevant purchasing public understands
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`primarily as the common or class name for the goods or services. In re Dial-A-Mattress
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`Operating Corp., 240 F.3d 1341, 57 USPQ2d 1807 (Fed. Cir. 2001); In re American Fertility
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`Society, 188 F.3d 1341, 51 USPQ2d 1832 (Fed. Cir. 1999); In re Merrill Lynch, Pierce, Fenner
`
`& Smith, Inc., 828 F.2d 1567, 4 USPQ2d 1141 (Fed. Cir. 1987); H. Marvin Ginn Corp. v. Int'l
`
`Ass'n of Fire Chiefs, Inc., 782 F.2d 987, 228 USPQ 528 (Fed. Cir. 1986). Generic terms are by
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`definition incapable of indicating a particular source of the goods or services, and cannot be
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`registered as trademarks; doing so “would grant the owner of the mark a monopoly, since a
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`competitor could not describe his goods as what they are.” In re Merrill Lynch, 828 F.2d at
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`1569, 4 USPQ2d at 1142.
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`16.
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`Applicant’s goods are a genus of “pillow,” as stated in her identification of
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`goods.
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`17.
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`A species of pillow that Applicant intends to identify as a “facelift pillow” is, in
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`at least one instance, a pillow meant to function as an alternative to surgical face-lift
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`procedures.
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`18.
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`The term “facelift pillow” is immediately understood by the relevant purchasing
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`public as primarily being the common or class name for pillows configured for use in
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`connection with, or as an alternative to, surgical face-lift procedures.
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`19.
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`The term “facelift pillow” and, hence, the proposed THE FACELIFT PILLOW
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`mark, is a generic name for at least one of Applicant’s intended goods, cannot function as a
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`trademark, and is not entitled to registration pursuant to Sections 2(e)(1) and 23 of the Lanham
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`Act, 15 U.S.C. §§ 1052(e)(1), 1091, as applied for in the Application.
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`
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`B. Applicant’s Proposed Mark is Merely Descriptive as Applied to
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`Applicant’s Intended Goods and is Not Entitled to Registration.
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`20.
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`The allegations set forth in paragraphs 1-13 and 14-19 of this Notice of
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`Opposition are incorporated as though fully set forth herein.
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`21.
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`A mark is merely descriptive if it describes an ingredient, quality, characteristic,
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`Notice of Opposition - 4
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`function, feature, purpose or use of the specified goods and/or services. TMEP §1209.01(b); In
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`re Steelbuilding.com, 415 F.3d 1293, 1297, 75 USPQ2d 1420, 1421 (Fed. Cir. 2005); In re
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`Gyulay, 820 F.2d 1216, 1217-18, 3 USPQ2d 1009, 1010 (Fed. Cir. 1987). A term is merely
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`descriptive if it conveys an immediate idea of the ingredients, qualities, or characteristics of the
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`identified goods and/or services. See In re Steelbuilding.com, 415 F.3d 1293, 1297, 75
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`USPQ2d 1420, 1422 (Fed. Cir. 2005); In re Dial-A-Mattress Operating Corp., 240 F.3d 1341,
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`1346, 57 USPQ2d 1807, 1812 (Fed. Cir. 2001). “A mark may be merely descriptive even if it
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`does not describe the ‘full scope and extent’ of the applicant’s goods or services.” In re
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`Oppedahl & Larson LLP, 373 F.3d 1171, 1173, 71 USPQ2d 1370, 1371 (Fed. Cir. 2004)
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`(citing In re Dial-A-Mattress Operating Corp., 240 F.3d 1341, 1346, 57 USPQ2d 1807, 1812
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`(Fed. Cir. 2001)); TMEP §1209.01(b). It is enough if the term describes only one significant
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`function, attribute or property. In re Oppedahl, 373 F.3d at 1173, 71 USPQ2d at 1371; TMEP
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`§1209.01(b).
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`22.
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`As an alternative to the claim stated in paragraphs 14-19 herein, Opposer asserts
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`that Applicant’s proposed THE FACELIFT PILLOW mark is the mere combination of the
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`merely descriptive term “facelift,” which is immediately understood to mean either a cosmetic
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`procedure for improving one’s facial appearance or the actual lifting/elevating of one’s face,
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`and the generic term “pillow,” and is, therefore, not entitled to registration pursuant to Section
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`2(e)(1) of the Lanham Act, 15 U.S.C. § 1052(e)(1).
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`23.
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`The term “facelift pillow” immediately describes a function, feature or
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`characteristic of the goods intended to be marketed by Applicant.
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`24.
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`Even if Applicant’s intended pillow products are designed to be used in other
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`contexts or for other purposes unrelated to face-lift procedures or the actual lifting of one’s
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`face, the proposed mark is still merely descriptive because it describes a significant aspect of at
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`least one of Applicant’s goods.
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`25.
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`Because Applicant’s THE FACELIFT PILLOW mark is comprised entirely of a
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`merely descriptive term, the Application is not entitled to federal registration.
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`26.
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`Opposer would be damaged by registration of Applicant’s proposed THE
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`Notice of Opposition - 5
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`FACELIFT PILLOW mark because such registration would constitute at least prima facie
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`evidence of Applicant’s exclusive right to use the proposed mark, which would be inconsistent
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`with and detrimental to Opposer’s planned use of the generic, or at least merely descriptive,
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`term in connection with Opposer’s own pillow products.
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`
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`WHEREFORE, Opposer requests that Application Serial No. 77/927,300 be rejected,
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`and that no registration be issued in connection with this application, and that this opposition be
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`sustained in favor of Opposer.
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`
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`Opposer hereby appoints Justin G. Sanders (USPTO Registration No. 59,398, Cal. Bar
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`No. 258,801) and Jeromye V. Sartain (USPTO Registration No. 54,423, Cal. Bar No. 222,081)
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`of Mind Law Firm, P.C., as her attorneys in the matter of the above-identified Opposition, to
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`prosecute the Opposition, to transact all business with the Patent and Trademark Office and any
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`United States courts connected with this Opposition and to sign her name to all papers which
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`may hereafter be filed in connection with the Opposition and to receive the official
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`Respectfully submitted,
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`Mind Law Firm, P.C.
`Jeromye V. Sartain (Cal. Bar No. 222,081)
`Justin G. Sanders (Cal. Bar No. 258,801)
`
`/Justin G. Sanders/
`_________________________________
`
`By: Justin G. Sanders
`
`2424 S.E. Bristol Street, Suite 300
`Newport Beach, California 92660
`Telephone: 949-250-5800
`Facsimile: 866-258-5653
`
`Attorneys for Opposer Cynthia Callendar
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`communications relating to the same.
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`Dated: October 19, 2010
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`Notice of Opposition - 6
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`CERTIFICATE OF TRANSMISSION
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`I hereby certify that a true and complete copy of the foregoing Notice of Opposition is
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`being electronically transmitted to the Trademark Trial and Appeal Board on October 19, 2010.
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`/Justin G. Sanders/
`_________________________________
`Justin G. Sanders
`Mind Law Firm, P.C.
`Attorney for Applicant
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`Dated: October 19, 2010
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`Notice of Opposition - 7
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and complete copy of the foregoing Notice of Opposition has
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`been served on Applicant’s attorney of record by mailing said copy on October 19, 2010, via
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`/Justin G. Sanders/
`_________________________________
`Justin G. Sanders
`Mind Law Firm, P.C.
`Attorney for Applicant
`
`First Class Mail, postage prepaid to:
`
`
`Indhira A. LaPuma
`Suiter Swantz PC LLO
`14301 FNB Parkway, Suite 220
`Omaha, Nebraska 68154
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`Dated: October 19, 2010
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`Notice of Opposition - 8
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`
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`EXHIBIT A
`EXHIBIT A
`
`
`
`

`
`WhoIs Search Results
`
`Username / Customer#
`
`Password
`
`USD
`
`empty
`
`Create Account | Forgot Password
`
`Deals of the Day
`
`24/7 Sales & Support
`
`(480) 505-8877
`Hablamos Español
`
`Products
`
`Domain
`Auctions
`
`Marketplace
`
`Support &
`Community
`
`Our
`Commercials
`
`Bob's
`Video Blog
`
`My
`Account
`
`Domains
`
`Hosting
`
`Email
`
`Site Builders
`
`Business
`
`SSL & Security
`
`Resellers
`
`WHOIS Domain Check
`
`Show All My Products
`
`MYFACELIFTPILLOW.COM
`
`6 Facts YOU MUST know
`when dealing with any problem.
`PLUS ... a smoking HOT blonde.
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`
`Check to add these alternate MYFACELIFTPILLOW domain names.
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`Check to add these similar MYFACELIFTPILLOW.COM domain names.
`
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`$11.99*/yr
`
`FREEMYFACELIFTPIL...
`
`$11.99*/yr
`
`BESTMYFACELIFTPIL...
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`Registrant:
`The Facelift Pillow Company LLC
`
`1839 South 139th Street
`Omaha, Nebraska 68144
`United States
`
`Registered through: GoDaddy.com, Inc. (http://www.godaddy.com)
`Domain Name: MYFACELIFTPILLOW.COM
`Created on: 15-Mar-10
`Expires on: 15-Mar-11
`Last Updated on: 08-Jun-10
`
`Administrative Contact:
`Medlock, Brooke Elizabeth brookemedlock@gmail.com
`The Facelift Pillow Company LLC
`1839 South 139th Street
`Omaha, Nebraska 68144
`United States
`4029687096
`
`Technical Contact:
`Medlock, Brooke Elizabeth brookemedlock@gmail.com
`The Facelift Pillow Company LLC
`1839 South 139th Street
`Omaha, Nebraska 68144
`United States
`4029687096
`
`Domain servers in listed order:
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`
`

`
`
`
`EXHIBIT B
`EXHIBIT B
`
`
`
`

`
`Facelift - Anti Wrinkle Pillow - Anti aging skin - Testimonials
`
`This is Google's cache of http://www.myfaceliftpillow.com/testimonials.html. It is a snapshot of the page as it appeared on Aug 28, 2010 16:10:56 GMT. The current
`page could have changed in the meantime. Learn more
`
`These terms only appear in links pointing to this page: myfaceliftpillow
`
`Text-only version
`
`The Facelift Pillow™ | FAQs |
`
`Contact Us |
`
`Store |
`
`Testimonials
`
`Testimonials
`
`“You have a very innovative invention, one that clearly and
`effectively provides a pillow that reduces pressure on the user's
`face so that the formation of facial wrinkles is reduced or
`eliminated. Furthermore, we are impressed with the ingenuity of
`your design, most notably your inclusion of the layer of material
`which decreases the pressure on the user's face."
`
`Lambert&Lambert
`
`TM
`I see the wrinkles around my
`"When I use The Facelift Pillow,
`TM
`eyes and mouth diminish, and since using The Facelift Pillow
`no new wrinkles have appeared."
`
`Linda, Omaha, Nebraska
`
`today from our convenient and
`Purchase The Facelift Pillow
`secure online shopping cart to experience the results firsthand!
`
`TM
`
`Web Design by HIT. All rights reserved. Login
`
`Copyright 2010 HIT Web Design and Little Luxuries, LLC
`
`http://webcache.googleusercontent.com/search?q=cache:4LU4jQ2B4pMJ:www.myfaceliftpillow.com/testimonials.html+myfaceliftpillow&cd=7&hl=en&ct=clnk&gl=us[9/29/2010 2:54:20 PM]
`
`

`
`Facelift - Anti Wrinkle Pillow - Anti aging skin - FAQ
`
`This is Google's cache of http://www.myfaceliftpillow.com/faq.html. It is a snapshot of the page as it appeared on Sep 14, 2010 18:42:28 GMT. The current page
`could have changed in the meantime. Learn more
`
`These search terms are highlighted: face pillow These terms only appear in links pointing to this page: lift
`
`Text-only version
`
`The Facelift Pillow™ | FAQs |
`TM
`
`Contact Us |
`
`Store |
`
`Testimonials
`
`Frequently Asked Questions
`
`Q: Is The Facelift Pillow comfortable?
`TM
`A: Yes, The Facelift Pillow is just as comfortable as a regular pillow, but has added benefits for your
`face and is luxurious to sleep on.
`
`TM
`Q: Is The Facelift Pillow still effective if I sleep on my side?
`TM
`A: Yes, The Facelift Pillow is specifically designed for people who sleep on their side or their stomach.
`
`Q: How soon will I begin to see results?
`TM
`A: Most people begin to see results after just one night of sleeping on The Facelift Pillow. For information
`about the results our clients enjoy click here to navigate to our testimonials page.
`
`Still Have Questions?
`Feel free to visit our contact us page or fill out a contact form for more information so that we assist you.
`
`Web Design by HIT. All rights reserved. Login
`
`Copyright 2010 HIT Web Design and Little Luxuries, LLC
`
`http://webcache.googleusercontent.com/search?q=cache:mJdXMc8mxwcJ:www.myfaceliftpillow.com/faq.html+face+lift+pillow&cd=34&hl=en&ct=clnk&gl=us[9/29/2010 2:51:14 PM]
`
`

`
`
`
`EXHIBIT C
`EXHIBIT C
`
`
`
`

`
`Facelift - Anti Wrinkle Pillow - Anti aging skin - FAQ
`
`You have reached the cached page for http://startechnologies.mobi/faq.html
`
`Below is a snapshot of the Web page as it appeared on 9/12/2010. This is the version of the page that was used for ranking your search results. The page may
`have changed since it was last cached. To see what might have changed (without the highlights), go to the current page.
`
`You searched for: facelift pillow We have highlighted matching words that appear in the page below.
`
`Yahoo! is not responsible for the content of this page.
`
`Evolution | FAQs | Contact Us | Store | Testimonials | Lavender & Silk
`
`Web Design by HIT. All rights reserved. Login
`
`Frequently Asked Questions
`
`Q: Is The Facelift Pillow comfortable?
`
`A: Yes, The Facelift Pillow is just as comfortable as a regular pillow, but has added benefits for your face and is luxurious to sleep
`on.
`
`Q: Is The Facelift Pillow still effective if I sleep on my side?
`
`A: Yes, The Facelift Pillow is specifically designed for people who sleep on their side or their stomach.
`
`Q: How soon will I begin to see results?
`
`A: Most people begin to see results after just one night of sleeping on The Facelift Pillow.
`enjoy click here to navigate to our testimonials page.
`
`For information about the results our clients
`
`Still Have Questions?
`
`Feel free to visit our contact us page or fill out a contact form for more information so that we assist you.
`
`Name:
`
`Email:
`
`Phone:
`
`Comments:
`
`Submit
`
`Reset
`
`We would love to hear from you. Feel free to send us any questions or comments.
`
`TM
`
`TM
`
`http://74.6.117.48/...q=facelift+pillow&d=4636829645734379&mkt=en-US&setlang=en-US&w=37f576b9,2797b3cd&icp=1&.intl=us&sig=ZlIWtlNWJBJaVZ7X9xhNzw--[10/5/2010 2:10:25 PM]
`
`

`
`Facelift - Anti Wrinkle Pillow - Anti aging skin - FAQ
`
`TM
`
`TM
`
`TM
`
`http://74.6.117.48/...q=facelift+pillow&d=4636829645734379&mkt=en-US&setlang=en-US&w=37f576b9,2797b3cd&icp=1&.intl=us&sig=ZlIWtlNWJBJaVZ7X9xhNzw--[10/5/2010 2:10:25 PM]
`
`

`
`Facelift - Anti Wrinkle Pillow - Anti aging skin - Home
`
`You have reached the cached page for http://startechnologies.mobi/index.html
`
`Below is a snapshot of the Web page as it appeared on 9/12/2010. This is the version of the page that was used for ranking your search results. The page may
`have changed since it was last cached. To see what might have changed (without the highlights), go to the current page.
`
`You searched for: startechnologies.mobi facelift We have highlighted matching words that appear in the page below.
`
`Yahoo! is not responsible for the content of this page.
`
`Evolution | FAQs | Contact Us | Store | Testimonials | Lavender & Silk
`
`Introducing A New Beauty Solution
`
`Web Design by HIT. All rights reserved. Login
`
`Experience the loveliness of The Facelift Pillow. The Facelift Pillow is an effortless alternative to an expensive facelift. The Facelift
`Pillow restores youthful appearance to the facial skin while allowing you to sleep comfortably on your side.
`
`Soothe your spirit and rest your head effortlessly as wisdom and well being finally meet. Waking up feeling good about yourself is true
`bliss. Ultimately this is priceless. We all deserve to treat ourselves to the little the luxuries that life can afford. Feel healthy and nourished
`after sleeping on your Facelift Pillow.
`
`The Facelift Pillow is an innovative, patented design, and most people will see results within 24 hours. It usually takes two to four weeks
`to achieve maximum results, along with continued usage to maintain.
`
`This patent was designed in response to a topic that Oprah Winfrey hosted on her show about the number one beauty concern in
`America, which is facial wrinkles. The patent was designed for people who cannot afford a facelift, but desire the effects of one.
`
`The Science Behind The Facelift Pillow
`
`One of the primary causes of facial wrinkles is the pressure exerted by your pillow, especially if you sleep on your side.
`
`As people age, facial skin begins to thin out and lose elasticity, which creates less ability for the facial skin to "undo" sleeping hours of
`frequent pressing upon the facial skin. Using a common pillow, people experience facial pressing in the same areas of the face, repeatedly
`and consistently during sleep. Gravity, combined with pressure from the pillow contact, creates a regular routine of pressing of the delicate
`facial skin, which causes wrinkles.
`
`Order Your Facelift Pillow For True Beauty Rest
`
`Sleep comfortably and turn back the hands of time with The Facelift Pillow. Feel free to contact us with any questions at
`contact@myfaceliftpillow.com
`
`Embrace the bliss of becoming a beautiful and healthier you!
`
`Name:
`
`http://74.6.117.48/...ies.mobi+facelift&d=4787342478410525&mkt=en-US&setlang=en-US&w=2d68ea38,85505a8e&icp=1&.intl=us&sig=FiNuP9HDYs9h9V0ZEne05A--[10/5/2010 2:09:23 PM]
`
`

`
`Facelift - Anti Wrinkle Pillow - Anti aging skin - Home
`
`Email:
`
`Phone:
`
`Comments:
`
`Submit
`
`Reset
`
`We would love to hear from you. Feel free to send us any questions or comments.
`
`TM
`
`TM
`
`TM
`
`TM
`
`TM
`
`TM
`
`TM
`
`TM
`
`http://74.6.117.48/...ies.mobi+facelift&d=4787342478410525&mkt=en-US&setlang=en-US&w=2d68ea38,85505a8e&icp=1&.intl=us&sig=FiNuP9HDYs9h9V0ZEne05A--[10/5/2010 2:09:23 PM]
`
`

`
`EXHIBIT D
`EXHIBIT D
`
`

`
`Ads By Google Weekend Facelift Mini Face Lift Feather Facelift Face Lift in a Jar
`
`Google Search
`
`HOME » Health and Fitness
`
`Four Tips for a Swift Face Lift RecoverySwift Face Lift Recovery
`
`
`By Amber C. Smith
`
`Article Word Count: 555 [View Summary] Comments (0)
`
`Ads by Google
`Want to Get a Face Lift? Non-Surgical Facial Rejuvenation Available Here. Visit Us For
`Info. www.LaserEyeCenter.com
`
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`
`Facelift Without Surgery New, tighten wrinkles, lines & any loose skin. Non surgical
`facelift. www.naturalfaceliftsystem.com
`
`Remember when your mother or grandmother had
`a face lift and spent months recovering? Thankfully,
`this type of prolonged recovery is no longer the
`norm. In fact, face lift recovery can be faster and
`less painful than you've ever imagined.
`
`Ads by Google
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`Face Lifts, Brow Lifts, Otoplasty,
`Rhinoplasty and Blepharoplasty.
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`
`Four Tips for a Swift Face Lift Recovery
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`The time line for your face lift recovery depends on
`your specific procedure. For instance, a mini face lift
`often has a shorter recovery time than a full face
`lift. On average, though, most of your stitches
`should be removed within five days of your surgery,
`and all puffiness and swelling should be gone within
`two to three weeks.
`
`Four T