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`ESTTA Tracking number:
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`ESTTA839209
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`Filing date:
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`08/13/2017
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding
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`91235942
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`Party
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`Correspondence
`Address
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`Defendant
`The Upper Deck Company
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`POLLIE GAUTSCH, ESQ.
`G&A LEGAL, APC
`665 SAN RODOLFO 124-209
`SOLANA BEACH, CA 92075
`Email: pollie@gandalegal.com
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`Submission
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`Filer's Name
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`Filer's email
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`Signature
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`Date
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`Answer
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`Pollie Gautsch
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`pollie@gandalegal.com
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`/polliegautsch/
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`08/13/2017
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`Attachments
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`Answer to Opposition for Raise the Cat 8-13-17.pdf(98920 bytes )
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`In the Matter of Application Serial nos. 87314571 and 87314582 in Int’l Class 25 and published in
`the Official Gazette July 4, 2017.
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`Dennis Grove
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`Opposer,
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`-against-
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`The Upper Deck Company
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`Applicant.
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`Opposition No. 91235942
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`ANSWER TO NOTICE OF OPPOSITION
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`Commissioner for Trademarks
`Attention Trial and Appeal Board
`PO Box 1451
`Alexandria, VA 22313-1451
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`Dear Sir/Madam:
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`Applicant, The Upper Deck Company (hereinafter “Applicant”) hereby responds to the Notice of
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`Opposition as follows:
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`1. Applicant is without sufficient information to form a belief as to matters set forth in this para-
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`graph.
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`2. Applicant is without sufficient information to form a belief as to matters set forth in this para-
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`3. Applicant is without sufficient information to form a belief as to matters set forth in this para-
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`4. Applicant is without sufficient information to form a belief as to matters set forth in this para-
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`graph.
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`graph.
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`graph.
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`5. Applicant admits the allegations of this paragraph.
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`6. Applicant admits the allegations of this paragraph.
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`7. Applicant admits the allegations of this paragraph.
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`8. Applicant admits the allegations of this paragraph.
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`9. Applicant admits the allegations of this paragraph.
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`10. Applicant admits the allegations of this paragraph.
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`11. Applicant is without sufficient information to form a belief as to matters set forth in this
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`paragraph.
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`12. Applicant is without sufficient information to form a belief as to matters set forth in this
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`paragraph.
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`13. Applicant is without sufficient information to form a belief as to matters set forth in this
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`paragraph.
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`14. Applicant is without sufficient information to form a belief as to matters set forth in this
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`paragraph.
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`15. Applicant is without sufficient information to form a belief as to matters set forth in this
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`paragraph.
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`16. Applicant is without sufficient information to form a belief as to matters set forth in this
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`paragraph.
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`17. Applicant is without sufficient information to form a belief as to matters set forth in this
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`paragraph.
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`18. Applicant is without sufficient information to form a belief as to matters set forth in this
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`paragraph.
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`AFFIRMATIVE DEFENSES
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`Applicant hereby gives notice that it may rely on any affirmative defenses that may become
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`available or appear proper during discovery, and hereby reserves its right to amend this Answer to assert
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`any such defenses.
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`WHEREFORE, Applicant prays that this opposition be dismissed, and that the subject applica-
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`tion proceed to registration and for such other and further relief as may be appropriate.
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`Dated August 13, 2017
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`Respectfully submitted,
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`G&A Legal, a professional corporation
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`BY:___________________
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`Pollie A. Gautsch, Esq.
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`665 San Rodolfo #124/209
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`Solana Beach, CA 92075
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`(858) 345-1067
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`Attorneys for Applicant
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`CERTIFICATE OF SERVICE
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`I hereby certify that I served a copy of the foregoing Answer to Notice of Opposition on the At-
`torney of Record for the Applicant by mailing it via First Class Mail postage prepaid, on the
`14th day of August 2017 at the address indicated below:
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`Ryan D. Artis
`Riverside Law LLP
`1285 Drummers Lane
`Wayne, PA 19087
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`BY:___________________
`Pollie A. Gautsch, Esq.
`665 San Rodolfo #124/209
`Solana Beach, CA 92075
`(858) 345-1067
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`Attorneys for Applicant
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`!
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