`ESTTA663310
`ESTTA Tracking number:
`03/26/2015
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`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91211873
`Defendant
`Green Ivy Holdings LLC
`JOSEPH R ENGLANDER
`SHUTTS & BOWEN LLP
`200 E BROWARD BLVD , STE 2100
`FORT LAUDERDALE, FL 33301 1972
`UNITED STATES
`ptomail@shutts.com
`Other Motions/Papers
`Daniel J. Barsky
`ptomail@shutts.com, dbarsky@shutts.com, mlerner@ssbb.com, jm-
`cardle@ssbb.com
`/daniel j. barsky/
`03/26/2015
`Motion.pdf(26758 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
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`OPPOSITION NO: 91211873
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`Serial Nos.: 85775379, 85775380, and
`85775382
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`Marks: GREEN IVY, GREEN IVY
`SCHOOLS, and GREEN IVY LEARNING
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`GREEN IVY EDUCATIONAL
`CONSULTING, LLC,
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`Opposer,
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`-against-
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`GREEN IVY HOLDINGS LLC,
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`Applicant.
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`APPLICANT’S UNOPPOSED MOTION FOR ENLARGMENT OF TIME
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`Applicant, Green Ivy Holdings LLC (“Applicant”), hereby requests an extension to and
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`including April 2, 2016 to respond to Opposer’s Motion for Sanctions, filed on March 6, 2015
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`(D.E. 24), and states:
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`Opposer filed and served, via U.S. Mail only, Opposer’s Motion for Sanctions on March
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`6, 2015. Pursuant to TBMP 502.02(b), a response to the Motion for Sanctions is due on March
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`26, 2015.
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`Undersigned counsel was one of the trial counsel in the patent infringement matter styled
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`Advanced Ground Information Systems, Inc. v. Life360, Inc., pending in the United States
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`District Court for the Southern District of Florida, Case No. 9:14-cv-80651-MIDDLEBROOKS,
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`which was tried from March 9, 2015 through and including March 13, 2015. Undersigned
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`counsel was first able to review the Motion for Sanctions on March 16, 2015. Therefore,
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`Applicant requests an enlargement of time to respond to the Motion for Sanctions of one (1)
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`week, to and including April 2, 2015.
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`Counsel for Applicant and Opposer corresponded via email and spoke via telephone
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`regarding the Motion for Sanctions and Applicant’s request for an extension of time. Opposer
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`has no opposition to the relief sought herein.
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`WHEREFORE, Applicant requests the Board enter an Order extending its time to
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`respond to Opposer’s Motion for Sanctions to and including April 2, 2015, and for such other
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`and further relief as deemed appropriate.
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`Dated: April 2, 2015
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`SHUTTS & BOWEN LLP
`Counsel for Applicant
`Green Ivy Holdings LLC
`1100 CityPlace Tower
`525 Okeechobee Boulevard
`West Palm Beach, FL 33401
`561-835-8500(ph)/561-650-8530(fax)
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`By: /s/ Daniel J. Barsky
`Daniel J. Barsky
`Florida Bar No. 25713
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that a true and correct copy of the foregoing was served this 26th
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`day of March, 2015, via e-mail and United States First Class Mail, postage prepaid, on:
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`Mark Lerner, Esq.
`Jennifer Philbrick McArdle, Esq.
`Satterlee Stephens Burke & Burke LLP
`Attorneys for Opposer
`230 Park Avenue
`New York, NY 10169
`mlerner@ssbb.com
`jmcardle@ssbb.com
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`/s/ Daniel J. Barsky
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`Daniel J. Barsky
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