Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
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`ESTTA Tracking number:
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`ESTTA808271
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`Filing date:
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`03/20/2017
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91232780
`
`Party
`
`Correspondence
`Address
`
`Defendant
`National Electronics, Inc.
`
`LESLIE J. LOTT
`LOTT & FISCHER, PL
`POST OFFICE DRAWER 141098
`CORAL GABLES, FL 33114-1098
`
`Submission
`
`Filer's Name
`
`Filer's e-mail
`
`Signature
`
`Date
`
`teas@lottfischer.com
`
`Answer
`
`s/Neda Lajevardi/
`
`ljlott@lottfischer.com, nlajevardi@lottfischer.com, kclayman@lottfischer.com
`
`s/Neda Lajevardi/
`
`03/20/2017
`
`Attachments
`
`ANSWER TO OPP 91232780 2017.03.20.pdf(27304 bytes )
`
`

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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`Opposition No.: 91232780
`
`Serial No. 87/031,314
`
`Filed: May 10, 2016
`
`Mark: RIVIERA and Design
`
`
`
`
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`GENERAL MOTORS, LLC
`
`
`
` Opposer,
`
`
`v.
`
`NATIONAL ELECTRONICS, INC.,
`
`
`
`
`
`
`
`
` Applicant.
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`APPLICANT NATIONAL ELECTRONICS, INC.’S ANSWER
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`Applicant, NATIONAL ELECTRONICS, INC. (“National Electronics” or
`
`“Applicant”), by and through undersigned counsel, hereby responds to Opposer
`
`GENERAL MOTORS, LLC’S (“GM”) Notice of Opposition (“the Opposition”) as
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`follows:
`
`1.
`
`2.
`
`Applicant admits the allegations in Paragraph 1 of the Opposition.
`
`Applicant is without knowledge or information sufficient to form a belief
`
`as to the truth of the allegations contained in Paragraph 2 of the Opposition, and therefore
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`denies same.
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`3.
`
`Applicant is without knowledge or information sufficient to form a belief
`
`as to the truth of the allegations contained in Paragraph 3 of the Opposition, and therefore
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`denies same.
`
`4.
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`Applicant is without knowledge or information sufficient to form a belief
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`as to the truth of the allegations contained in Paragraph 4 of the Opposition, and therefore
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`denies same.
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`5.
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`Applicant is without knowledge or information sufficient to form a belief
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`
`
`1
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`

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`as to the truth of the allegations contained in Paragraph 5 of the Opposition, and therefore
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`denies same.
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`6.
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`7.
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`8.
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`9.
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`10.
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`11.
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`12.
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`13.
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`Applicant denies the allegations in Paragraph 6 of the Opposition.
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`Applicant denies the allegations in Paragraph 7 of the Opposition
`
`Applicant denies the allegations in Paragraph 8 of the Opposition.
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`Applicant denies the allegations in Paragraph 9 of the Opposition.
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`Applicant denies the allegations in Paragraph 10 of the Opposition.
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`Applicant denies the allegations in Paragraph 11 of the Opposition.
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`Applicant denies the allegations in Paragraph 12 of the Opposition.
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`Applicant is without knowledge or information sufficient to form a belief
`
`as to the truth of the allegations contained in Paragraph 13 of the Opposition, and
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`therefore denies dame.
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`14.
`
`Applicant denies the allegations in Paragraph 14 of the Opposition.
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`WHEREFORE, Applicant requests that the Notice of Opposition be dismissed
`
`with prejudice.
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`
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`Date: March 20, 2017
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`Respectfully submitted,
`
`LOTT & FISCHER, PL
`
`/s/Neda Lajevardi
`Leslie J. Lott
`Neda Lajevardi
`LOTT & FISCHER, PL
`P.O. Drawer 141098
`Coral Gables, FL 33114-1098
`(305) 448-7089
`
`Attorneys for Applicant
`National Electronics, Inc.
`
`2
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`

`

`
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`
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`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that the foregoing was served upon counsel for Opposer
`by delivering a true and correct copy of same via Electronic Mail on March 20, 2017 as
`follows:
`
`Julianne Abelman, Esq.
`Erica R. Halstead, Esq.
`Abelman Frayne & Schwab
`666 Third Avenue
`New York, New York 10017
`E-Mail: jabelman@lawabel.com; ehalstead@lawabel.com
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`/s/Neda Lajevardi
`Neda Lajevardi
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`3
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