Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA637805
`ESTTA Tracking number:
`11/08/2014
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91214673
`Plaintiff
`Edge Games, Inc.
`REV DR TIM LANGDELL
`EDGE GAMES INC
`530 SOUTH LAKE AVENUE , 171
`PASADENA, CA 91101
`UNITED STATES
`uspto@edgegames.com, tim@edgegames.com
`Reply in Support of Motion
`Tim Langdell
`tim@edgegames.com, uspto@edgegames.com
`/Tim Langdell/
`11/08/2014
`ReplyToApplicantsResponseToAmendedMotCompel08Nov14.pdf(61738 bytes )
`
`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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`

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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`____________________________________
`}
`}
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`EDGE GAMES, INC.,
`}
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`Opposer.
`}
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`}
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`v.
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`}
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`}
`FUTURE PUBLISHING LIMITED
`}
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`
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`Applicant.
`
`____________________________________}
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`Opposition No 91214673
`
`Applications Serial Nos. 85153958
`and 85153981
`
`Mark “EDGE”
`
`REPLY TO APPLICANT’S RESPONSE TO OPPOSER’S AMENDED MOTION
`TO COMPEL DISCOVERY AND MOTION TO TEST SUFFICIENCY OF
`RESPONSE TO ADMISSION REQUESTS AND MOTION FOR SANCTIONS
`AND/OR SUMMARY JUDGMENT
`
`
`
`
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`Opposer was making a periodic check of the status of this case online and was
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`surprised to discover that Applicant had made two filings (this one, and another Reply
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`Brief in support of Motion) that Opposer was not aware of. Opposer notes that Applicant
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`alleges this Response was served on Opposer via First Class Mail, but on investigating
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`this at the building Opposer receives its mail, we can find no trace of the document
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`arriving with us. This is to note, then, that Opposer is filing this Reply to Applicant’s
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`Response promptly upon first discovery of Applicant’s filing, and thus asks that the
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`Board consider it timely.
`
`I. REALITY CHECK: DESPITE APPLICANT’S OUTRAGEOUS
`ALLEGATIONS, THE FACT REMAINS APPLICANT HAS FAILED TO
`FULLY RESPOND TO VIRTUALLY ANY DISCOVERY REQUESTS.
`It is a simple fact, proven by the evidence filed, and not countered by anything filed
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`by Applicant, that Applicant failed/refused to properly respond to virtually any of
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`Opposer’s Request for Documents, Request for Admissions or Interrogatories. Indeed,
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`Applicant failed to even produce a single page of a single document that was requested of
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`it (or which it intends to rely on in these proceedings), while at the same time
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`outrageously stating that Opposer’s Motion is “completely frivolous and devoid of
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`

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`merit.” The arrogance of Applicant in the face of a clear breach of its obligations to
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`comply with Discovery is absolutely stunning. One can only hope the Board will respond
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`to Applicant by granting Opposer’s motion and severely punishing Applicant for its
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`incredible behavior by issuing appropriate sanctions against Applicant.
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`II. IT IS NOT DISPUTED THAT OPPOSER’S FIRST MOTION TO COMPEL
`WAS UNTIMELY, BUT ITS AMENDED MOTION (OR “SECOND”
`MOTION) WAS TIMELY AND VALID
` Applicant seeks to style Opposer’s Amended Motion to Compel as frivolous and
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`vexatious on the basis that Opposer’s first Motion to Compel was untimely. It is not
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`disputed that Opposer’s first Motion was untimely, and Opposer has already apologized
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`for that, pointing out that it was thought to be valid at the time for very good reasons that
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`Opposer set forth in previous filings.
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`But Opposer made clear when filing its Amended Motion to Compel that this is, if
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`necessary, to be considered a new motion that is timely if the Board does not permit this
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`amendment to the original motion to be considered, in all, a timely motion. Thus all of
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`Applicant’s criticisms of Opposer’s Amended Motion to Compel (or, in the alternate,
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`Second Motion to Compel) were validly dealt with before Applicant filed its Response.
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`II. OPPOSER DID MAKE A GOOD FAITH EFFORT TO CONFER.
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`Applicant protests that while Opposer gave Applicant time to respond to and confer
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`with Opposer over its request that Applicant serve proper and full responses to Discovery
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`or else Opposer would be compelled to file a Motion to Compel, Applicant alleges that
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`Opposer didn’t give Applicant sufficient time to respond before the instant Amended
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`Motion to Compel (Second Motion to Compel) was filed. This is nonsense: as the
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`correspondence between the parties confirms, Opposer would have been happy to receive
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`a solid commitment from Applicant that it would shortly be serving proper, full and
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`complete responses to Discovery requests, and instead of giving that assurance, Applicant
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`merely stated that it was very busy and would get around to responding to Opposer when
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`it had time to do so, clearly stating that Applicant was giving Opposer and this
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`Opposition before the Board, as low priority as it could (see Exhibit A attached hereto).
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`Most important, to this day Applicant has still not properly and fully responded to the
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`Discovery requests nor has Applicant conferred with Opposer. It is absolute nonsense for
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`

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`Applicant to suggest that the reason it still has not properly and fully responded to
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`Discovery is because it was “distracted” by having to respond to the Amended Motion to
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`Compel. Despite Applicant promising that it would properly and fully respond to
`Discovery soon – just not as swiftly as Opposer had requested – the reality is that
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`Applicant has still not given virtually any proper and full responses to Discovery
`even almost two months after it was due to respond in September. And it remains
`clear that Applicant refuses to take part in Discovery until the Board compels it to
`do so.
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`Applicant is clearly playing games with Opposer and with the Board. It is a matter of
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`record that Applicant failed to produce even one page of even one document in response
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`to Opposer’s extensive and entirely valid Request for Production of Documents,
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`Applicant also failed to properly respond to virtually any of the Request for Admissions
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`(primarily stating excuses as to why it would not respond), and refused to respond to any
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`of Opposer’s Interrogatories, stating falsely that they were too many in number and not
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`even attempting to respond to any of them.
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`It is not true that Opposer asked Applicant to respond with fully responsive
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`Responses within 24 hours. Rather, the record shows that Applicant was due to give such
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`full Responses by or about September 15, 2014 and failed to do so. Applicant should not
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`have required Opposer to inform it of its obligations before Applicant adheres to them.
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`Further, it was clear from correspondence between the parties, as well as from the (albeit
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`untimely filed) first Motion to Compel, that Opposer rightly and fairly desired fully
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`responsive Responses from Applicant as early as well over a month before the deadline it
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`set for Applicant before the instant Amended Motion (Second Motion) would be filed. It
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`is thus preposterous for Applicant to suggest that it was only given 24 hours to compile
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`and serve proper Discovery responses. Moreover, as the attached correspondence
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`showed, Opposer was being as lenient as it could reasonably be expected to be, and was
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`asking for just a commitment to provide fully responsive Responses, and Applicant
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`refused to give that commitment to Respond, let alone the Responses themselves.
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`With respect, this situation bears no resemblance to the Hot Tamale case that
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`Applicant refers to. Here, it is a matter of record that Applicant gave Opposer to believe
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`that it had no intention of properly participating in Discovery, which was followed by
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`

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`Applicant serving documents that were essentially totally non-responsive to Discovery
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`requests, together with a formal request by Opposer to the Board and to Applicant that
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`Applicant be required to serve proper and full Responses, and all this well over a month
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`before Opposer finally, in quite reasonable and understandable frustration, filed its
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`Amended (Second) Motion to Compel. And we say again, to this day, despite what
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`Applicant states, it has still not served on Opposer any responses to the Discovery
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`Requests and has not provided any reasonable or acceptable basis for having so failed to
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`comply with the requirements of Discovery.
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`III. APPLICANT FAILS TO JUSTIFY WHY IT DID NOT PROPERLY AND
`FULLY RESPOND TO OPPOSER’S DISCOVERY REQUESTS AND
`CONSEQUENTLY OPPOSER’S MOTION SHOULD BE GRANTED
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`Opposer notes that Applicant does not respond to any of the points raised by Opposer
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`in its Amended (Second) Motion to Compel as to why Applicant has so far failed
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`(refused) to respond to virtually any Discovery request:
`First Request For Production of Documents: Applicant gives no response at all to
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`Opposer’s grounds for compelling Applicant to respond to Opposer’s First Request For
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`Production of Documents. Opposer noted that none of Applicant’s excuses as to why it
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`refused to produce even a single sheet of paper were valid, and since Applicant fails to
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`justify why it completely failed to respond to the document production requests, the
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`Board should compel Applicant to respond, denying Applicant the right to object to any
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`of the Production Requests and should sanction Applicant for its persistent refusal to
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`respond.
`First Request For Admissions. Applicant gives no response at all to Opposer’s
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`grounds for compelling Applicant to respond to Opposer’s First Request for Admissions.
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`Accordingly, the Board should compel Applicant to respond properly and fully, denying
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`Applicant the right to object to any of the Requests, and should sanction Applicant for its
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`persistent failure to respond.
`Opposer’s First Interrogatories. Applicant gives no response to Opposer’s grounds
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`to compel response, namely that Opposer’s Interrogatories did not exceed the maximum
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`number permitted by the Board regulations. Since the number of Interrogatories did not
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`exceed those permitted, and since Applicant gives no justification at all for why it refused
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`

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`to respond to even a single Interrogatory, the Board should compel Applicant to respond
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`fully and completely to the Interrogatories, denying them the right to object to any of
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`them, and should sanction Applicant for its persistent refusal to respond to this Discovery
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`request.
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`IV APPLICANT’S CITES AND EXHIBITS RELATING TO MATTERS
`INVOLVING OTHER PARTIES SHOULD BE GIVEN NO WEIGHT
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`It is clear that while Applicant is obviously in the wrong (after all, Applicant has yet
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`to be properly responsive to virtually any of Opposer’s Discovery Requests), Applicant is
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`trying to sway the Board’s opinion on this Motion by resorting to outrageous ad hominem
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`attacks on the character of Reverend Langdell. With respect, we trust that the Board will
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`give no weight to these references to unrelated cases involving third parties such as Razer
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`Pacific, Electronic Arts or Future Publishing. While we trust that the Board will disregard
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`all such references (and associated exhibits), Opposer gives some brief responses to the
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`absurd allegations and statements made in Applicant’s ad hominem attack.
`The Razer Cancelation. First, what is transpiring in another matter before the TTAB
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`is not relevant to this opposition – at least it is not relevant in the manner that Applicant is
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`seeking to make it relevant. While it is true that in that matter, too, Opposer’s opponent
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`Razer has also failed to be responsive to any of Opposer’s Discovery Requests, the fact
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`remains that the Board has certainly not ruled any of Opposer’s points in regard to
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`Razer’s failures as being without merit (let alone frivolous or vexatious). In that other
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`matter, Opposer has every right to file a Motion to Compel Discovery since Razer has
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`(like Future here) failed to be responsive. And no doubt the Board will eventually rule in
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`that other matter, too, that Razer must comply with Discovery else this entire process of
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`Opposition or Cancelation would be a nonsense if one party is permitted by the Board to
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`completely ignore its responsibilities in the Discovery process.
`The Electronic Arts matter(s). Everything Applicant’s states and exhibits in regard
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`to the matters involving this third party are of no relevance to the current proceedings and
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`are clearly solely designed to cast Opposer and its CEO in a poor light in the hope that
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`the Board will side with Applicant even though Opposer has merit on its side. In regard
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`to the TTAB proceedings, all three parties to that proceeding (Electronic Arts, Future
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`Publishing and Opposer) filed numerous filings, and it is a gross distortion of the facts to
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`

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`suggest that only Opposer filed such filings, or that Opposer filed an excessive number.
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`While it is true that the Board criticized one of the very last filings Opposer did in that
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`action (Applicant’s quote from May 2013), that was restricted to one particular issue and
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`the Board was not critical of any of the other many tens of filings that all parties –
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`including Opposer —had done in that action over the four years since its inception in
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`2009. Whether or not Opposer has ever failed to tell the truth is not in question in this
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`matter before us, it is a simple matter of whether Applicant has certain obligations to be
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`fully and completely responsive to Discovery (which it does) and whether it has complied
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`with those obligations (which Applicant clearly has not). That said, what Applicant states
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`is a deliberate false and misleading version of events in the Electronic Arts matter. The
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`fact remains that Opposer (and its CEO Reverend Langdell) were eventually found not to
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`be guilty of anything alleged or suspected during that case, and on the contrary, evidence
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`was produced that showed that it was Electronic Arts that had filed fraudulent, fake
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`evidence with the court, and that it was Marvel’s Vice President, Walter Bard, who had
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`committed perjury before the Court.
`The British case involving Applicant. This has no relevance whatsoever to the
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`instant proceedings and it is quite outrageous that Applicant would include quotes and
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`cites and exhibits from those proceedings. Clearly, again, Applicant’s goal is to color the
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`Board’s opinion of Opposer and its CEO, and such malicious tactics should be ignored,
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`given no weight, and Applicant should be criticized for attempting such underhand
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`tactics. While this is not the place to re-litigate a matter that took place before a British
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`Court, should the Board be minded to give any weight to it then the Board should note: It
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`was later shown that Future Publishing had deliberately mislead the UK Court into
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`thinking that Opposer had presented a computer disk into evidence described in one way,
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`when in fact it was later proven Opposer had introduced the evidence in a different way.
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`Only because Future Publishing deliberately mislead the Court did the Court ever make a
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`comment that there was anything “absurd” about Opposer’s argument or evidence. What
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`Applicant cites regarding the email exchanges is out of context since in later proceedings
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`and evidence filings it was proven that Opposer’s version of events was in fact entirely
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`truthful and accurate.
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`

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`The International Game Association. This too is not relevant. But for the record,
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`the Board of that organization made a decision to terminate membership based on the
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`provisional opinion (not decision, just opinion) voiced by the Judge in the Electronic Arts
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`case in 2010. The final decision by the Judge held that Reverend Langdell was not found
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`to have committed any unethical behavior nor had he acted without integrity. This is not
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`the venue for Opposer to explain in any detail why the Game Association did not reverse
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`its decision once the Court clarified that it did not finally rule the way the Association
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`had anticipated it would rule. That is a complex issue, and has no relevance to this case.
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`But certainly it would be grossly unfair and wrong for any conclusion to be drawn that
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`just because the game association misunderstood a court “opinion” as a court “ruling”
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`and failed to act when the ruling came out contrary to the opinion, should not be taken as
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`saying anything of any consequence regarding Opposer or its officer’s integrity or
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`honesty. It does not.
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`V APPLICANT’S REQUESTED SANCTIONS SHOULD BE DENIED
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`There is no reasonable basis here for the Board to sanction Opposer at all, and
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`certainly not by requiring Opposer to seek leave of the Board before filing any further
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`motion or paper in this proceeding. First, as to the cited case law (International Finance
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`Corp. V. Bravo Co) that was a totally different situation where a party had filed three
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`motions to compel, each time giving frivolous grounds and being warned not to repeat
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`the behavior. Here we have a totally different situation: there is one Motion to Compel
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`(or, at most, two if the Board wishes to regard the Amended Motion as a new Second
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`Motion). And here, unlike in International Finance Corp, Opposer has clear and
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`completely valid grounds for ask the Board to compel Discovery given that Applicant has
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`almost completely failed to respond to any of Opposer’s discovery requests, has failed to
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`produce even a single page of any document, has given nothing but invalid excuses for
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`not responding to the Admissions asked, and has given a totally invalid reason for not
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`responding to any of Opposer’s Interrogatories. Worse, Applicant is so arrogant that no
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`where in this Response does it even attempt to justify why it has failed to respond to
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`virtually any of the quite valid and reasonable Discovery Requests so far posed by
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`Opposer.
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`

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`As to the argument that Opposer should be sanctioned because it has either failed to
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`give Applicant ample time to confer on the issue of Applicant’s almost complete failure
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`to comply with Discovery, or on the basis that Opposer is “trying to run up costs,” these
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`are clearly absurd allegations that the Board should treat with the contempt they deserve.
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`As was clarified above, Applicant knew since early September that Opposer was – quite
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`reasonably – requiring Applicant to give fully responsive Responses to all of its
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`Discovery requests. There was far more than ample time in the two months that passed in
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`which Applicant could have conferred, but instead Applicant refused to confer and
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`simple wrote emails (see Exhibits hereto) stating that it would deal with its Discovery
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`failures in due course, but even now a month or so later Applicant has done absolutely
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`nothing about curing its failure to comply with Discovery.
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`Equally, there is no basis whatsoever for sanctioning Opposer by requiring it to serve
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`all documents by U.S. certified mail, nor any reasonable basis to require Opposer to have
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`to have all signatures notarized, nor that Opposer would need Board permission before
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`filing any future motion.
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`As stated above, the cited case of International Finance Corp does not support a
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`request that Opposer be required to seek Board permission in future before filing any
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`motion. Not only are the two cases entirely different, if anything that cited case should be
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`taken as ruling that unless a party has clearly frivolously filed at least three Motions to
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`Compel under circumstances similar to that in the cited case, then there should be no
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`sanctions given. Here, there is only one motion, two at most if the Amended Motion is
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`counted as a Second Motion, thus according to the cite the threshold to incur sanctions
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`has not yet been met – not, we say again, that Opposer’s behavior here can be remotely
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`compared with the poor behavior of the party in the cited case that lead to sanctions.
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`Since Applicant ultimately confirmed receipt of all documents served by Opposer,
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`and even served its Replies based on receiving what Opposer served in a timely manner
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`(they served on September 15, 2014 rather than claiming they had a right not to serve
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`because of any failure of service on them by Opposer), there is no reasonable argument
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`that Opposer should be sanctioned by being required to serve future documents by
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`certified mail, or that Opposer should have to get all signatures notarized. All this would
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`

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`do is cause Opposer unnecessary and unfair increased costs and time of dealing with this
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`matter, which would be grossly unfair.
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`VI APPLICANT’S APPLICATION IS ON THE BASIS OF INTENT TO USE
`(1B), HENCE ITS VERY APPLICATION IS AN ADMISSION THAT IT HAS
`NO BASIS TO SUCCESSFULLY DEFEND THIS OPPOSITION.
`
`Opposer fears that with all the “fog of war” being thrown up by Applicant as it
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`deliberately refuses to comply with Discovery, that it will be overlooked by the Board
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`that it is almost certain that Applicant cannot possibly prevail in this Opposition.
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`Applicant applied on the basis of Intent To Use (1B), and thus cannot prevail in this
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`opposition on the basis of prior use, or priority of use over that claimed by Opposer.
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`Clearly, Applicant also cannot prevail based on any claim to own an earlier registered
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`mark for the same goods/services (and hasn’t sought to do so). Thus there is no likely
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`basis on which Applicant can prevail in these proceedings. This, we propose, is the
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`reason that Applicant is being so difficult and failing to comply with any Discovery
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`requests since Applicant is well aware that if it is actually compelled to respond to the
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`production, admission and interrogatories, then it will become immediately obvious that
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`Applicant has no case. And that, indeed, when Applicant is finally compelled to respond,
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`it will be reasonable and proper for Opposer to file a Motion for Summary Judgment
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`since it will be obvious there is no possibility that Applicant can possibly prevail.
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`VII OPPOSER’S MOTION SHOULD BE GRANTED AS SHOULD ITS
`REQUEST FOR SANCTIONS
`
`In summary, the simple fact remains that to this day Applicant has not come even
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`remotely close to complying with its obligations to respond fully and completely to the
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`various Discovery requests that Opposer made in August, 2014. Despite the smokescreen
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`of ad hominem attacks that Applicant has thrown up to try to persuade the Board to side
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`with Applicant, the fact remains that to this day Applicant has still not produced a single
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`page of even one document, when a reasonable full response to the Request for
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`Production would have generated at least several hundreds of pages of documents to be
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`produced and handed over to Opposer. Further, Applicant failed to answer virtually any
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`of the Request for Admissions, and in its response it failed to justify any of the reasons it
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`gave for so failing to respond. Last, Applicant did not respond to any of Opposer’s Initial
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`

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`Interrogatories, and in its response failed to justify or explain why it refused to respond at
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`all when the number of interrogatories did not exceed the number permitted.
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`It is clear that Applicant is not going to respond fully and completely to
`Opposer’s Discovery requests unless the Board compels Applicant to do so. This,
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`then, is a very good example of when it is entirely right and proper for a party to file a
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`Motion to Compel Discovery, and consequently, the Board should grant Opposer’s
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`motion and compel Applicant to fully and completely respond to all Opposer’s
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`production requests, requests for admission and all of its interrogatories.
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`Further, the Board should sanction Applicant and send a message to it that it is not
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`acceptable to play these games with Opposer and the Board whereby it claims to be
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`harassed when in fact it is deliberately failing to be responsive to Discovery. At a
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`minimum, then, Applicant should be not only compelled to fully and completely comply
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`with all Discovery to-date, but Applicant should also be ordered to promptly and fully
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`comply with all future discovery requests by Opposer, and Applicant should be denied
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`the right to object to any current or future requests by Opposer, but rather be required to
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`respond fully without objection. Beyond those sanctions, it seems fair and reasonable
`
`that Applicant be further sanctioned, in such way as the Board sees fit, including but not
`
`limited to requiring Applicant to seek permission of the Board before filing any future
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`motion, and including, if the Board sees fit, granting summary judgment in Opposer’s
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`favor for Applicant’s clear refusal to take part in Discovery.
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`Last, since Opposer is not receiving service copies from Applicant, we ask that
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`Applicant be further sanctioned by being required to serve all future documents by
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`certified mail.
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`Respectfully submitted this day November 8, 2014,
`
`
`
`By: /Rev Dr Tim Langdell/___________________
`
`Rev Dr Tim Langdell, CEO Opposer in Pro Per/Se
`Edge Games, Inc.
`530 South Lake Avenue, 171
`Pasadena, CA 91101
`Tel: 626 449 4334; Fax: 626 844 4334; Email: tim@edgegames.com
`
`

`
`EXHIBIT A
`EXHIBIT A
`
`
`
`

`
`From: Tim <tim@edgegames.com>
`Date: September 24, 2014 at 11:54:45 AM PDT
`To: "Phillips, Robert N. (Rob)" <RobPhillips@ReedSmith.com>
`Cc: Tim Langdell <tim@edgegames.com>
`Subject: Re: Future Plc: Edge
`
`Mr Phillips
`
`Given your client's complete failure to be responsive to discovery, using groundless
`objections to avoid giving any meaningful responses or producing even a single
`document, and since all we asked for by today was an indication that your client is
`willing to start properly participating in Discovery, your email below falls pitifully short
`of being an acceptable response. It would have taken less time to confirm willingness to
`participate than to write the unresponsive email you wrote.
`
`We are thus filing the Amended Motion. You are reminded that discovery is not stayed
`pending the Motions.
`
`Sincerely
`For Opposer
`
`
`
`Sent from my iPhone 6 with apologies for any errors due to Apple's auto-correct or my
`mis-typing.
`
`
`
`No acceptable
`response has
`ever been
`received.
`
`On Sep 24, 2014, at 11:42 AM, Phillips, Robert N. (Rob)
`<RobPhillips@ReedSmith.com> wrote:
`
`Dear Mr. Langdell:
`
`Again, we will have a response for you either today or tomorrow as originally stated.
` Your self-imposed deadline of Noon is arbitrary and unreasonable, and disregards the
`Board's requirement that the parties make a good faith attempt to resolve discovery
`disputes. We have other pressing matters, and cannot immediately drop everything to
`satisfy your demands. You will have our response in due course.
`
`Robert N. Phillips | Reed Smith LLP
`101 Second Street - Suite 1800 San Francisco, CA 94105
`Direct: 415.659.5953 | Reception: 415.543.8700 | Fax: 415.391.8269
`robphillips@reedsmith.com | www.reedsmith.com
`
`
`
`-----Original Message-----
`From: Tim [mailto:tim@edgegames.com]
`Sent: Tuesday, September 23, 2014 1:59 PM
`
`

`
`To: Phillips, Robert N. (Rob)
`Cc: Tim Langdell
`Subject: Re: Future Plc: Edge
`
`Mr Phillips
`
`You are very well aware what you just did with the recent filings, hence the notice we
`have given you to at least affirm you will actually start complying with discovery is more
`than adequate. Indeed, the reasonable response would have been to respond in your email
`below that you intend to start giving fully responsive, no evasive, responses.
`
`You have until noon tomorrow, failing which we will file the Amended Motion so as to
`seek the Board's ruling that you must start complying with discovery requests in a fully
`responsive manner.
`
`Sincerely.
`For Edge
`
`
`
`Sent from my iPhone 6 with apologies for any errors due to Apple's auto-correct or my
`mis-typing.
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`CERTIFICATE OF SERVICE
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` hereby certify that a true copy of the foregoing REPLY TO APPLICANT’S
`RESPONSE TO OPPOSER’S AMENDED MOTION TO COMPEL DISCOVERY AND
`MOTION TO TEST SUFFICIENCY OF RESPONSE TO ADMISSION REQUESTS
`AND MOTION FOR SANCTIONS AND/OR SUMMARY JUDGMENT in respect to
`Opposition No. 91214673 was served on Applicant via first class mail, postage prepaid,
`this day November 8, 2014:
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`Robert N. Phillips
`Reed Smith LLP
`101 Second Street, Suite 1800
`San Francisco
`CA 94105
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`_/Rev Dr Tim Langdell/________
`Rev. Dr. Tim Langdell