Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA914976
`
`Filing date:
`
`08/10/2018
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91230510
`
`Party
`
`Correspondence
`Address
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Attachments
`
`Plaintiff
`PRL USA Holdings, Inc.
`
`DANIEL I SCHLOSS
`GREENBERG TRAURIG LLP
`200 PARK AVENUE, 34TH FLOOR
`NEW YORK, NY 10166
`UNITED STATES
`Email: schlossd@gtlaw.com, lippmans@gtlaw.com, biancoc@gtlaw.com
`
`Plaintiff's Notice of Reliance
`
`Daniel I. Schloss
`
`schlossd@gtlaw.com, biancoc@gtlaw.com, hasana@gtlaw.com
`
`/Daniel I. Schloss/
`
`08/10/2018
`
`91230510 Opposer Notice of Reliance - Discovery Deposition Ex-
`cerpts.pdf(672783 bytes )
`
`
`
`ESTTA Tracking number:
`
`ESTTA914976
`
`Filing date:
`
`08/10/2018
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91230510
`
`Party
`
`Correspondence
`Address
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Attachments
`
`Plaintiff
`PRL USA Holdings, Inc.
`
`DANIEL I SCHLOSS
`GREENBERG TRAURIG LLP
`200 PARK AVENUE, 34TH FLOOR
`NEW YORK, NY 10166
`UNITED STATES
`Email: schlossd@gtlaw.com, lippmans@gtlaw.com, biancoc@gtlaw.com
`
`Plaintiff's Notice of Reliance
`
`Daniel I. Schloss
`
`schlossd@gtlaw.com, biancoc@gtlaw.com, hasana@gtlaw.com
`
`/Daniel I. Schloss/
`
`08/10/2018
`
`91230510 Opposer Notice of Reliance - Discovery Deposition Ex-
`cerpts.pdf(672783 bytes )
`
`
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`IN THE MATTER OF APPLICATION
`Mark:
`
`POLO KING
`Applicant:
`
`Brasilio Machado
`Serial No.:
`
`87/019,978
`Published in
`the Official Gazette: September 20, 2016
`
`PRL USA HOLDINGS, INC.,
`
`
`
`
`
`
`
`
`Opposer,
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`
`
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`
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`
`
`v.
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`
`
`
`BRASILIO MACHADO,
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`
`
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`
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`
`
`Applicant.
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`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Opposition No. 91230510
`
`OPPOSER’S NOTICE OF RELIANCE ON PORTIONS
`OF DISCOVERY DEPOSITION OF APPLICANT BRASILIO MACHADO
`
`
`
`
`Pursuant to 37 C.F.R. §§ 2.120(k)(1), 2.120(k)(3), and 2.122(g), Opposer, PRL USA
`
`Holdings, Inc., by its undersigned attorneys, hereby gives notice that it will rely on certain
`
`portions of the discovery deposition of Applicant Brasilio Machado. Attached herein as Exhibit
`
`1 are excerpts from Applicant’s deposition transcript as indicated below:
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`
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`Page Numbers
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`Line Numbers
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`40
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`NY 247386450v4
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`17-23
`1-25
`1-25
`1-4, 22-25
`1-16, 25
`1-25
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`1-22
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`41
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`1-5
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`Dated: August 10, 2018
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`
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`Respectfully submitted,
`
`
`
`
`
`By: /Daniel I. Schloss/
`Daniel I. Schloss
`GREENBERG TRAURIG, LLP
`200 Park Avenue, 38th Floor
`New York, New York 10166
`Tel: (212) 801-2256
`Fax: (212) 801-6400
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies on this 10th day of August, 2018 that a true and correct copy of
`the foregoing Opposer’s Notice of Reliance on Portions of Discovery Deposition of Applicant
`Brasilio Machado is being delivered via e-mail to Applicant at his email addresses of record for
`this proceeding, namely, brasilio@machadolaw.net and brasilio@me.com.
`
`
`
`_/Daniel I. Schloss/________
`Daniel I. Schloss
`
`
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`NY 247386450v4
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`2
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`EXHIBIT 1
`EXHIBIT 1
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`NY 247386450V4
`NY 247386450v4
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`3
`3
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`
`
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Page 1
`
` In re: U.S. Application Serial NO. 87019978
`
` Mark: POLO KING
`
` Published: September 20, 2016
`
` ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
`
` PRL USA HOLDINGS, INC., Opposition No. 91230510
`
` Opposer,
`
` -against-
`
` BRASILIO MACHADO,
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` Applicant.
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` ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
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` DEPOSITION OF: BRASILIO MACHADO
`
` DATE: October 18, 2017
`
` TIME: 10:29 a.m. - 12:00 p.m.
`
` PLACE: Greenberg Traurig, LLP
`
` 333 Southeast Second Avenue
`
`17
`
` Suite 4400
`
` Miami, Florida
`
` REPORTER: Chloe Leroux, FPR
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`212-267-6868
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`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
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`
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`Page 14
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` A. I opened my own firm.
`
` Q. And that's the firm that you still operate?
`
` A. Correct.
`
` Q. What types of matters do you handle in your
`
` practice?
`
` A. Mostly family law, immigration, civil
`
` litigation, and personal injury.
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`212-267-6868
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`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
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` Q. How many?
`
` A. One.
`
` Q. Any other lawyers with you?
`
` A. No.
`
` Q. Is it a busy practice?
`
` A. I don't know what busy is to you.
`
` Q. Well, does it keep you occupied full time
`
` during the week?
`
` A. Absolutely, I dedicate myself to all my
`
` businesses.
`
` Q. Can you describe the current activities of
`
` Polo King Corporation?
`
` A. At this point, Polo King Corporation is
`
` involved in trademark litigation with your client.
`
` Q. Well, does it have any employees?
`
` A. No, just me.
`
` Q. So you're an officer of the corporation?
`
` A. That's correct.
`
` Q. The trademark application for Polo King, as
`
` you know, is in your name, individually?
`
` A. Yes.
`
` Q. Why is that?
`
` A. Because I registered and put it in my own
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` name.
`
` Q. So was there the intention to assign the
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` application to your company?
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` A. Haven't thought of that yet.
`
` Q. Okay. Who are the other current officers of
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`Page 16
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` Polo King Corporation?
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` A. Natasha Jaraba.
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` Q. What's her title?
`
` A. She's the vice president.
`
` Q. What are her current responsibilities for Polo
`
` King Corporation?
`
` A. At this point, none.
`
` Q. Why is that?
`
` A. Because the company is waiting for the final
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` determination of the trademark, so we can proceed with
`
` what we're going to be doing in business.
`
` Q. The company is waiting for resolution of this
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` proceeding?
`
` A. That is correct.
`
` Q. Is it otherwise thinking about launching other
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` brands?
`
` A. No.
`
` Q. Is it otherwise making any preparations to
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` manufacture and sell products?
`
` A. Please repeat your question.
`
` Q. Is the company currently taking any concrete
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` steps to manufacture or sell products or to arrange for
`
`212-267-6868
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`www.veritext.com
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`Page 17
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` the manufacture or sale of products?
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` A. No. The company is waiting for resolution of
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` the trademark decision, and then we'll move to the next
`
` step.
`
` Q. Do you recall filing a federal trademark
`
` application before the current one that's being posed?
`
` A. An application for myself?
`
` Q. Yes.
`
`212-267-6868
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`www.veritext.com
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` A. No.
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` Q. Did you file a trademark for After Dark
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` clothing?
`
` A. Yes, I did.
`
` Q. Did that application proceed to registration?
`
` A. No.
`
` Q. Why?
`
` A. I think there was somebody that already owned
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` that name, I think. I'm not sure.
`
` Q. So you were contacted by the owner of
`
` something else, who owned a trademark that they felt was
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` being infringed by After Dark?
`
` A. I believe so.
`
` Q. So did you drop the application as part of the
`
` settlement?
`
` A. I can't remember.
`
` Q. Do you recall filing a trademark application
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`212-267-6868
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` for Fabrik, F-a-b-r-i-k, with a K at the end?
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` A. I don't recall.
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` Q. Did you have an address, at one point, at 3130
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`Page 19
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` Bird Avenue?
`
` A. Yes.
`
` Q. Was that a home or an office?
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` A. It was my hone.
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` Q. I'll represent the application for the mark
`
` Fabrik was filed in 2001, for shirts, pants, dresses,
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` underwear, and footwear, for men and women. Does that
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` refresh your recollection?
`
` A. Yes.
`
` Q. What do you recall about that application?
`
` A. It was a name that I was seeing if I could
`
` use, to make a new brand for my clothing store.
`
` Q. When you say make a new brand, you mean rename
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` the clothing store, or it would be the name of products
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` sold by the store?
`
` A. A new clothing line.
`
` Q. A new clothing line, okay. Did that
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` application proceed to registration?
`
` A. No, I don't think so.
`
` Q. Why?
`
` A. I don't remember.
`
` Q. Do you remember if there was a third party
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`212-267-6868
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`Page 20
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` that objected to it?
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` A. I don't remember if there was an objection at
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` all.
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` Q. Was there a clothing line called Fabrik, that
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` you ultimately commercialized?
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` A. No.
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` Q. When did you decide to apply for the mark Polo
`
` King?
`
` A. Sometime before I applied, I guess.
`
` Q. Fair enough. Why did you decide to apply for
`
` the mark Polo King?
`
` A. Because there was a need, in the field of
`
` polo, for clothing that, actually, polo players desire,
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` that are not on the market.
`
` Q. What type of clothing do you mean?
`
` A. Pants, shirts, hats, boots.
`
` Q. So when you say boots, do you mean boots used
`
` in playing the sport of polo?
`
` A. Riding boots.
`
` Q. How about pants? Are those pants used by
`
` players while playing polo?
`
` A. Absolutely.
`
` Q. Are they pants that would just be general
`
` clothing, for fashion purposes?
`
` A. It could be used as fashion, but they're not
`
` designed for fashion.
`
` Q. Are they designed to be uniforms?
`
` A. No. They're designed to be riding pants.
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` Q. Do you recall receiving a letter that I sent
`
` you in May of 2016?
`
` A. I recall receiving a letter from you.
`
` Q. What did you do when you received the letter?
`
` A. I read it.
`
` Q. Did you do anything else after reading it?
`
` A. I don't think so.
`
` Q. Did you consult anyone?
`
` A. No.
`
` Q. Did you respond to the letter?
`
` A. I don't believe so.
`
` Q. Why didn't you respond to the letter?
`
` A. Because I don't have to.
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`www.veritext.com
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`Page 26
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` Q. So how did you decide the name, to identify
`
` those new products, should be Polo King?
`
` A. I liked the name.
`
` Q. Why?
`
` A. Because it relates to polo, the sport of polo.
`
` It's a catchy name.
`
` Q. Had you ever heard the phrase or the name Polo
`
` King anywhere else?
`
` A. I don't remember.
`
` Q. Are you familiar with my client, Ralph Lauren?
`
` A. Familiar in what way?
`
` Q. Do you know the Ralph Lauren Corporation?
`
` Have you seen its products in the marketplace?
`
` A. I've seen some of his products, yes.
`
` Q. Ralph Lauren the company and Ralph Lauren the
`
` individual, are you familiar with, generally, each of
`
` those, the individual and the company name?
`
` A. I'm familiar with Ralph Lauren and his
`
` products.
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` Q. When do you recall having encountered any
`
` mention of Ralph Lauren or his products?
`
` A. When, I don't remember.
`
` Q. It would have been before you filed your
`
` application for the mark Polo King, correct?
`
` A. Yes.
`
` Q. Are you familiar with Ralph Lauren's Polo line
`
` of clothing?
`
` A. I'm familiar with Ralph Lauren clothing.
`
` Q. Are you aware that Ralph Lauren has used the
`
` mark Polo for a long time?
`
` A. Polo by Ralph Lauren, yes.
`
` Q. When you first planned to launch Polo King,
`
` how did you envision -- well, how did you plan to sell
`
` the new products, that would be branded as Polo King?
`
` A. With the online marketplace and through
`
` retailers.
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`Page 30
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` Q. In responding to some of the discovery
`
` requests that we served, you mentioned that, and I'm
`
` quoting, the mark was sketched, parentheses, rough
`
` draft, close paren, by the applicant and draft submitted
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` to an artist, to have a final artistic professional look
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` design.
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`Page 31
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` Can you describe that process in greater
`
` detail and, particularly, when you say the mark was
`
` sketched in rough draft by you?
`
` A. I wrote it. I drew on a piece of paper how I
`
` wanted it to look, the letters.
`
` Q. A logo?
`
` A. Not a logo.
`
` Q. Typeface?
`
` A. It's the typeface, the letters, stylized. I
`
` did a little styling of the letters, to look nice.
`
` Q. Do you have a copy of that?
`
` A. No.
`
` Q. You do not?
`
` A. No.
`
` Q. What artist was it given to?
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` A. A friend of mine, that is a better drawer than
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` I am.
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` Q. And what did your friend do with the sketch
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` that you gave him or her?
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` A. This is not a very formal process,
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` Mr. Schloss. This is something very simple, where I'll
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` sit next to you and I'll say let's write this in a nice
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` type font, and you draw that, and I say maybe I want
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` this letter a little bigger or this one a little
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` smaller. That's it.
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`Page 32
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` Q. In some of the pleadings that you filed in
`
` this case, you referred to a batch of hats that you had
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` manufactured. Do you remember that?
`
` A. Yes.
`
` Q. And you said that those hats were distributed
`
` in order to gauge interest, is that correct?
`
` A. Correct.
`
` Q. Where did you distribute the hats?
`
` A. At games, polo matches.
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`212-267-6868
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`Veritext Legal Solutions
`www.veritext.com
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`Page 33
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` Q. Polo matches in Wellington?
`
` A. Yes.
`
` Q. Anywhere else?
`
` A. No. I gave some to a few friends.
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`Page 34
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` Q. I also wanted to clarify one other response
`
` that we got in response to request for admission. We
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` had a request for admission that said: Applicant does
`
` not currently manufacture, sell, or offer to sell
`
` products under any mark?
`
` And your response was: Denied.
`
` So do you currently sell or manufacture or
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` offer to sell products under another mark, other than
`
` Polo King?
`
` A. Other than Polo King?
`
` Q. Yeah.
`
` A. I don't recall that.
`
` Q. Do you sell products under the mark Polo King?
`
` A. I manufacture products under Polo King.
`
` Q. The hats that we discussed?
`
` A. Correct.
`
` Q. Anything else?
`
` A. No.
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`Page 36
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` Q. Did you sell and get money for any products
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` that say Polo King on them?
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` A. Not yet, we haven't gotten to that stage yet,
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` but we will.
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`Page 40
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` Q. Riding boots are sold differently than rain
`
` boots. Would that be a correct statement?
`
` A. I don't know if that's a correct statement.
`
` Riding boots and rain boots, as I'm concerned, can be
`
` sold in the same place. As a matter of fact, I think
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` they are sold in the same place.
`
` Q. Well, in any event, your application for Polo
`
` King doesn't say riding boots. It just says boots, so
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`Page 41
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` that could encompass other types of boots, correct?
`
` A. Yes.
`
` Q. So it could encompass rain boots or boots that
`
` have nothing to do with the sport of polo, right?
`
` A. Correct.
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`
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