Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA997599
`
`Filing date:
`
`08/26/2019
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91240209
`
`Party
`
`Correspondence
`Address
`
`Defendant
`Rum Dogs, Inc.
`
`MICHAEL SCHWAB
`MORITT HOCK & HAMROFF LLP
`1407 BROADWAY
`NEW YORK, NY 10018
`UNITED STATES
`trademark@moritthock.com, mschwab@moritthock.com,
`bbloom@moritthock.com, msarney@moritthock.com, tbalducci@moritthock.com
`212-239-2000
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Other Motions/Papers
`
`Michael Schwab
`
`mschwab@morrithock.com, chay@moritthock.com
`
`/Michael Schwab/
`
`08/26/2019
`
`Attachments
`
`OKOJUMO Stip 82619.pdf(72142 bytes )
`
`

`

`HANBEV.7543M
`
`TRADEMARK
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`MONSTER ENERGY COMPANY
`
`Opposition N0.: 91240209
`
`Opposer,
`
`Serial N0.: 87/601,976
`
`V.
`
`Mark: OKOJUMO
`
`RUM DOGS, INC,
`
`Applicant.
`
`STIPULATED RES QUEST TO AMEND APPLICATION AND STIPULATED
`CONTINGENT WITHDRAWAL OF OPPOSITION WITHOUT PREJUDICE
`
`Commissioner for Trademarks
`PO. Box 1451
`
`Alexandria, VA 22313—1451
`
`Dear Sir/Madam:
`
`Opposer, Monster Energy Company (“Opposer”), and Applicant, Rum Dogs,
`
`Inc.
`
`(“Applicant”), through their undersigned counsel, jointly file this Stipulated Request to Amend
`
`Application and Stipulated Contingent Withdrawal of Opposition Without prejudice. The parties
`
`have entered into a settlement agreement.
`
`By and through this filing, Applicant, Ruin Dogs, Inc. (“Applicant”), hereby moves
`
`pursuant to 37 CPR. § 2.133(a) to amend the translation for U.S. Trademark Application Serial
`
`No. 87/601,976 for the mark OKOJUMO (the “Application”). The translation should be amended
`
`as follows:
`
`The word “OKOJUMO” means “giant sea serpent spiri ” in the Carib dialect.
`
`

`

`Applicant submits that
`this translation is accurate. Opposer, Monster Energy Company
`(“Opposer”), hereby consents to the foregoing amendment.
`0
`
`Applicant submits that the foregoing amendment is in compliance with the applicable rules.
`
`Additionally, contingent upon the Board’s approval of Applicant’s motion to amend the
`
`Application as set forth above, Opposer notices the withdrawal of its opposition to Application
`
`Serial No. 87/601,976, with Applicant’s consent.
`
`WHEREFORE, the parties request that this Stipulated Request to Amend Application be
`
`accepted,
`
`that the Board instruct the Commissioner for Trademarks to enter the requested
`
`amendment in the Application, and the Opposition be dismissed without prejudice.
`
`Respectfully submitted this Zéwday of
`. I
`/,.
`
`
`
`, 2019.
`
`
`
`
`M; a...
`
`
`
`
`Moritt Hock & Hamroff L LP
`1407 Broadway
`New York, New York 10018
`Telephone: (212) 239—2000
`
`mschwabttihnoritthockcom
`
`kstctinatc'iistctinalawcom
`Attorney for Applicant
`Rum Dogs, Inc.
`
`Jonathan A. Menkes
`
`Jason A. Champion
`Brian M.Z. Reece
`Knobbe Martens Olson & Bear LLP
`2040 Main Street, 14th Floor
`Irvine, California 92614
`
`Telephone: (949) 760—0404
`
`jonathan.menkes@knobbe.com
`
`jason.championchknobbecom
`brianreece knobbecom
`
`
`
`efilingchknobbecom
`Attorneys for Opposer
`Monster Energy Company
`
`

`

`
`CERTIFICATE OF SERVICE
`
`I hereby certify that I served a copy of the foregoing STIPULATED REQUEST TO
`AMEND APPLICATION AND STIPULATED CONTINGENT WITHDRAWAL OF
`
`OPPOSITION WITHOUT PREJUDICE upon Opposer’s counsel by electronic mail on
`3235’ [”6“
`, addressed as follows:
`
`Jonathan A. Menkes, Esq.
`Jason A. Champion, Esq.
`Brian M.Z. Reece, Esq.
`Knobbe Martens Olson & Bear LLP
`
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`
`efiling@knobbe.corn
`MEC.TTAB@knobbe.com
`
`fl
`
`/A\r
`
`1’
`
`

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