`ESTTA466270
`ESTTA Tracking number:
`04/10/2012
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`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91204122
`Defendant
`Liang, Michael
`DAVID YAN, ESQ.
`LAW OFFICES OF DAVID YAN
`13620 38TH AVE STE 11E
`FLUSHING, NY 11354-4232
`
`davidyanlawfirm@yahoo.com
`Other Motions/Papers
`David Yan
`davidyanlawfirm@yahoo.com
`/David Yan/
`04/10/2012
`Motion to Enlarge Time to File Answer.pdf ( 3 pages )(10763 bytes )
`Facsmile Receipt.pdf ( 1 page )(32150 bytes )
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`Proceeding
`Party
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`Correspondence
`Address
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`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`
`In re Application Serial No. 85/213,453
`Filed: January 8, 2011
`For Mark: NYC BEER LAGER and Design
`Published in the Official Gazette: December 6, 2011
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`v.
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`MICHAEL LIANG,
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`EMPIRE STATE BUILDING COMPANY L.L.C.,
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`Commissioner for Trademarks
`Attn: Trademark Trial and Appeal Board
`P.O. Box 1451
`Alexandria, VA 22313-1451
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`Opposition No.: 91204122
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`MOTION TO ENLARGE TIME
`TO FILE ANSWER
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`Opposer,
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`Applicant.
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`Defendant, Michael Liang, has recently retained the undersigned to represent him before
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`The Trademark Trial and Appeal Board of the United States Patent and Trademark Office in
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`connection with the Opposition filed by Empire State Building Company, L.L.C. against the
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`registration of the NYC BEER LAGER and Design mark.
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`The undersigned is a sole practitioner. The undersigned is very busy in the 2011 tax
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`season as a tax counsel. In addition, the undersigned is engaged in several litigation matters,
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`including a multi-million dollar personal injury matter, in the extensive depositions, EBT, and
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`discovery proceedings these days on behalf of his victim clients. Therefore, the undersigned
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`cannot finish on or before the due day on April 10, 2012 the answer to the Opposition filed by
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`the Opposer against the registration of the NYC BEER LAGER and Design mark. In addition,
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`the undersigned will be out of the country for 10 days in the month of May, 2012. In order to
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`meaningfully prepare the answer to the said opposition, the undersigned will have to arrange
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`time in next 60 days to complete the answer.
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`THEREFOR, defendant, via the undersigned counsel, moves this tribunal of the
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`Trademark Trial and Appeal Board to enlarge the time for 60 days until June 11, 2012 to allow
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`defendant to file the answer to opposition to the registration of the NYC BEER LAGER and
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`Design mark.
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`Dated: Flushing, New York
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`April 10, 2012
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`Respectfully submitted,
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`
` /David Yan/
`David Yan, Esq.
`Attorney for Defendant
`136-20 38th Avenue, Suite 11E
`Flushing, New York 11354
`Telephone: (718) 888-7788
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`AFFIRMATION OF SERVICE
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`I hereby certify that, on April 10, 2012, I caused a true and correct copy of the foregoing
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`motion to enlarge time to file answer to the opposition to be sent by the U.S. Post First Class
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`Mail, postage prepared, to the plaintiff’s Attorney of Record, Maya L. Tarr, Esquire, Cowan
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`Liebowitz, & Latman, P.C., located at 1133 Avenue of the Americas, New York, NY 10278.
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`Dated: Flushing, New York
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`April 10, 2012
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` /David Yan/
` David Yan
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`3
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`136420 38”‘ Avenue. $uite1*|E
`Flushing. NY11354
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`Tel: ?1s—aa:}77aa
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`F-'.-‘ax: 718-38343370 (Not far Service)
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`
`
`Fromi David Yan
`Maya L. Terr, Esquire
`T9‘
`Ccawan Liebowitz 84 Latman PC.
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`Fax:
`{212)5T&fl671
`Pages: 4
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`4/10/2012
`Date:
`Phmm (212) 790-9200
`__u_jfi
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`Re‘
`Empire State Building Co LLC V
`EH3:
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`Michael Liang
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`'3 “Gent
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`II! Far Review
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`E? Pleaae Ctumment
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`El Please Reply
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`U Please Recycle
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`
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`Moti.ot1 to Exflarge of"Fime to file :mswe.1'toth<3 opposition.
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