`ESTTA438351
`ESTTA Tracking number:
`10/28/2011
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91197815
`Defendant
`Tesco Stores Ltd.
`FRANK S. BENJAMIN
`MCKENNA LONG & ALDRIDGE LLP
`303 PEACHTREE ST STE 5300
`ATLANTA, GA 30308-3265
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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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`mlaip@mckennalong.com
`Other Motions/Papers
`Frank S. Benjamin
`mlaip@mckennalong.com
`/Frank S. Benjamin/
`10/28/2011
`ConsentMotiontoAmendandDismiss77044437.pdf ( 5 pages )(186032 bytes )
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`
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the Matter of Application Serial No. 77l044,437
`For the mark: FRESH & EASY and Design
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`fresh &easy
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`
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`Filed: November 15, 2006
`Published: June 15, 2010
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`<
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`Tesco Stores Ltd.
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`Applicant.
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`Opposition No. 91197815
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`\-—/\-"\—/\—/\./\-._/\_/\-_/
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`J
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`CONSENT MOTION TO AMEND AND DISMISS WITHOUT PREJUDICE
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`Applicant, Tesco Stores Ltd., and Opposer, Apple Inc., jointly move the Board under 37
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`CFR. §2.l33(a) and T_B_M_P_ §§5l4.01 and 514.02 to amend the description of the goods and
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`services of Application Number 77/044,437 (the “Application”) and, if all of the requested
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`amendments are entered, to dismiss Opposition No. 91197315 without prejudice.
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`The parties respectfully request that the Board grant this motion to amend the description
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`of the goods and services for the Application as set forth below. The requested amendments
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`involve deletions or further limitations on the goods and services, and not expansions or other
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`changes. As such, all of the requested amendments should be granted.
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`In Classes 16, 35 and 36 of the Application, Tesco requests that the goods and services be
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`amended as follows:
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`Class 16:
`-:
`-
`:. --
`:.
`-
`--=;--- :.
`-
`--
`;parchmentpaper;
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`paper napkins; paper tablecloths; paper doilies; paper filters for coffee makers; paper towels;
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`toilet paper; disposable diapers; paper tissues; paper handkerchiefs; paint brushes; paper
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`coasters; glue for stationery or household use; calendars; writing paper; envelopes; pens; pencils;
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`non-electric erasers; plastic sandwich bags; general feature magazines; and magazines featuring
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`food, lifestyles and a wide variety of consumer goods.
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`Class 35: Retail store services featuring a wide variety of consumer goods; Retail store
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`services featuring pre-paid telephone cards and gift cards, magnetically encoded and not
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`magnetically encoded, clothing, food, beverages and groceries; Retail store services, available
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`through computer communications and interactive television, featuring a wide variety of
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`consumer goods, pre-paid telephone cards and gift cards, magnetically encoded and not
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`magnetically encoded, clothing,
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`food, beverages and groceries; supermarkets;
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`retail store
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`services featuring a wide variety of consumer goods of others; retail variety stores;
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`promoting the sale of credit card accounts through the administration of incentive award
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`programs; promoting the sale of goods and services of others by awarding purchase points for
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`credit card use; promotion of financial and insurance services, on behalf of third parties.
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`Class 36: Insurance agencies in the field of home, accident, life, health and car; financial
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`Services, namely banking, credit, mortgage, investment, loan, estate, savings programs; assisting
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`others with the completion of financial transactions for stocks, bonds, securities and equities;
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`financial services, namely money lending; savings account services; savings and loan services;
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`banking services; administration of savings accounts;
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`financial services, namely, savings
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`programs; cash card services; issuing credit cards; insurance administration; insurance carrier
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`services; and insurance services, namely, writing property and casualty insurance.
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`Pursuant to this request and in accordance with 37 C.F.R. §2.135, Classes 9 and 38 shall
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`be deleted in their entirety from the Application:
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`All other classes of goods and services in the Application shall remain unchanged as a
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`result of this Consent Motion to Amend.
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`[Remainder of page intentionally left blank.]
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`If the Board enters all of the foregoing amendments, the parties stipulate that the above-
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`identified opposition proceeding be dismissed without prejudice.
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`Dated: October @, 2011
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`Respectfully submitted,
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`
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`Frank S. Benjamin
`Attorney for Applicant, Tesco Stores Ltd.
`McKenna Long & Aldridge LLP
`303 Peachtree St, NE
`Suite 5300
`
`Atlanta, Georgia 30308
`(404) 527-4986
`(404) 527-4193 fax
`fbenj amin@mckennal ong. com
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`jlétfdld--}°"’-°"
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`Alicia Grahn Jones
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`Attorney for Opposer, Apple Inc.
`Kilpatrick Townsend & Stockton LLP
`1100 Peachtree Street
`Suite 2800
`
`Atlanta, Georgia 30309
`(404) 815-6164
`(404) 541-3292 fax
`alj ones@kilpatricktownsend. corn
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`CERTIFICATE OF SERVICE
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Apple Inc.
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`V.
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`Tesco Stores Ltd.
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`Opposer,
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`Applicant.
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`\—/\-../\.J\_/%/\-_/&/\-_/
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`J
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`Opposition No. 91197815
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`I hereby certify that the foregoing CONSENT MOTION TO AMEND AND DISMISS
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`WITHOUT PREIUDICE has been served on Opposer by depositing said copy with the United
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`States Postal Service as First-Class Mail, postage prepaid, in envelopes addressed to:
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`Joseph Petersen
`Kilpatrick Townsend & Stockton LLP
`3 1 West 52“ Street, 14”‘ Floor
`New York, New York 10019
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`Alicia Grahn Jones
`Kilpatrick Townsend & Stockton LLP
`1100 Peachtree Street
`Suite 2800
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`Atlanta, Georgia 30309
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`This W5 | day of October, 2011.
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`Donna Dubin
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`McKenna Long & Aldridge LLP
`303 Peachtree St., NE
`Suite 5300
`
`Atlanta, Georgia 30308
`(404) 527-4986
`(404) 527-4198 fax
`
`ATLANTA:53363l5.1