`
`ESTTA Tracking number:
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`ESTTA842254
`
`Filing date:
`
`08/28/2017
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`Party
`
`Correspondence
`Address
`
`91235681
`
`Defendant
`Bkon LLC
`
`JUSTIN C. ALLEN
`RIVERSIDE LAW LLP
`300 CONSHOHOCKEN STATE RD
`CONSHOHOCKEN, PA 19428-3801
`Email: dockets@riversidelaw.com
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Answer
`
`Ryan D. Artis
`
`dockets@riversidelaw.com
`
`/Ryan D. Artis/
`
`08/28/2017
`
`Attachments
`
`206038.602960-Answer to Opposition.pdf(175902 bytes )
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of Application
`Serial No. 86/166,421
`
`Mark: RAIN
`
`Published in the Official Gazette
`On March 21, 2017
`
`RAIN INTERNATIONAL LLC,
`
`v.
`
`BKON LLC,
`
`Opposer,
`
`Applicant.
`
`
`
`
`
`
`
`
`
`Opposition No. 91235681
`
`
`
`
`
`
`
`
`
`
`
`ANSWER TO NOTICE OF OPPOSITION
`
`Applicant, Bkon LLC (hereinafter “Applicant”) hereby responds to the Notice of
`
`Opposition as follows:
`
`
`
`1.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`
`
`2.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`3.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`
`
`
`
`
`
`4.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`Attorney Docket No. 206038.602960
`
`
`in this paragraph.
`
`5.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`
`
`6.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`
`
`7.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`
`
`8.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`9.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`10.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`11.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`12.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`13.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`14.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`
`
`2
`
`
`
`15.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`Attorney Docket No. 206038.602960
`
`
`in this paragraph.
`
`16.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`17.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`18.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`19.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`20.
`
`Applicant is without sufficient information to form a belief as to matters set forth
`
`in this paragraph.
`
`
`
`AFFIRMATIVE DEFENSES
`
`Applicant hereby gives notice that it may rely on any affirmative defenses that may
`
`become available or appear proper during discovery, and hereby reserves its right to amend this
`
`Answer to assert any such defenses.
`
`
`
`
`
`
`
`
`
`3
`
`
`
`WHEREFORE, Applicant prays that this opposition be dismissed, and that the subject
`
`application proceed to registration and for such other and further relief as may be appropriate.
`
`Attorney Docket No. 206038.602960
`
`
`
`
`
`
`Date: August 28, 2017
`
`
`
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`
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`
`
`
`
`
`
`
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`
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`Respectfully submitted,
`
`
`
`
`
`
`
`
`
` By:
`
`/Ryan D. Artis/
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ryan D. Artis
`Reg. No. 67,798
`Attorney for Applicant,
`Bkon LLC
`
`Riverside Law LLP
`Glenhardie Corporate Center
`1285 Drummers Lane, Suite 202
`Wayne, PA 19087
`215-268-3888 (main)
`215-268-3871 (fax)
`518-708-6044 (direct)
`E-Mail: dockets@riversidelaw.com
`
`
`
`
`
`
`
`
`
`
`
`4
`
`
`
`Attorney Docket No. 206038.602960
`
`
`Certificate of Service
`
`I, Lisa Stanton, hereby certify that a true and complete copy of the foregoing NOTICE OF
`OPPOSITION has been served upon the following individual via First Class mail on August 28,
`2017:
`
`Attorney for RAIN INTERNATIONAL LLC:
`
`Perry S. Clegg
`Clegg Law
`P.O. Box 1198
`Salt Lake City, UT 84110
`
`
`/Lisa Stanton/
`
`Lisa Stanton, Paralegal
`Riverside Law LLP
`Glenhardie Corporate Center
`1285 Drummers Lane, Suite 202
`Wayne, PA 19087
`
`
`
`
`
`
`
`
`5
`
`

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