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Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA663310
`ESTTA Tracking number:
`03/26/2015
`
`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 )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`
`Signature
`Date
`Attachments
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`OPPOSITION NO: 91211873
`
`Serial Nos.: 85775379, 85775380, and
`85775382
`
`Marks: GREEN IVY, GREEN IVY
`SCHOOLS, and GREEN IVY LEARNING
`
`GREEN IVY EDUCATIONAL
`CONSULTING, LLC,
`
`Opposer,
`
`
`
`
`-against-
`
`GREEN IVY HOLDINGS LLC,
`
`Applicant.
`
`APPLICANT’S UNOPPOSED MOTION FOR ENLARGMENT OF TIME
`
`Applicant, Green Ivy Holdings LLC (“Applicant”), hereby requests an extension to and
`
`
`
`
`
`
`
`including April 2, 2016 to respond to Opposer’s Motion for Sanctions, filed on March 6, 2015
`
`(D.E. 24), and states:
`
`Opposer filed and served, via U.S. Mail only, Opposer’s Motion for Sanctions on March
`
`6, 2015. Pursuant to TBMP 502.02(b), a response to the Motion for Sanctions is due on March
`
`26, 2015.
`
`Undersigned counsel was one of the trial counsel in the patent infringement matter styled
`
`Advanced Ground Information Systems, Inc. v. Life360, Inc., pending in the United States
`
`District Court for the Southern District of Florida, Case No. 9:14-cv-80651-MIDDLEBROOKS,
`
`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,
`
`Applicant requests an enlargement of time to respond to the Motion for Sanctions of one (1)
`
`week, to and including April 2, 2015.
`
`

`
`Counsel for Applicant and Opposer corresponded via email and spoke via telephone
`
`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.
`
`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
`
`and further relief as deemed appropriate.
`
`Dated: April 2, 2015
`
`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)
`
`By: /s/ Daniel J. Barsky
`Daniel J. Barsky
`Florida Bar No. 25713
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing was served this 26th
`
`day of March, 2015, via e-mail and United States First Class Mail, postage prepaid, on:
`
`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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`
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`
`
`/s/ Daniel J. Barsky
`
`Daniel J. Barsky
`
`
`
`2

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