throbber
Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA1231969
`
`Filing date:
`
`08/29/2022
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding no.
`
`91242213
`
`Party
`
`Correspondence
`address
`
`Submission
`
`Filer's name
`
`Filer's email
`
`Signature
`
`Date
`
`Attachments
`
`Plaintiff
`Audemars Piguet Holding S.A.
`
`JOHN A GALBREATH
`GALBREATH LAW OFFICES PC
`2516 CHESTNUT WOODS CT
`REISTERSTOWN, MD 21136
`UNITED STATES
`Primary email: jgalbreath@galbreath-law.com
`Secondary email(s): jgalbreath@verizon.net
`410-628-7770
`
`Testimony For Plaintiff
`
`John A. Galbreath
`
`jgalbreath@galbreath-law.com, jgalbreath@verizon.net
`
`/John A. Galbreath/
`
`08/29/2022
`
`Ex. 51-Pulvirent Rebuttal Testimony.pdf(2362952 bytes )
`Ex. 52-Pulvirent Rebuttal Testimony.pdf(222183 bytes )
`Ex. 53-Pulvirent Rebuttal Testimony.pdf(353569 bytes )
`Ex. 54-Pulvirent Rebuttal Testimony.pdf(2505376 bytes )
`Ex. 55-Pulvirent Rebuttal Testimony.pdf(1610632 bytes )
`Ex. 56-Pulvirent Rebuttal Testimony.pdf(1773006 bytes )
`Ex. 57-Pulvirent Rebuttal Testimony.pdf(133564 bytes )
`Ex. 58-Pulvirent Rebuttal Testimony.pdf(72048 bytes )
`Ex. 59-Pulvirent Rebuttal Testimony.pdf(3495569 bytes )
`Ex. 60-Pulvirent Rebuttal Testimony.pdf(254385 bytes )
`Ex. 61-Pulvirent Rebuttal Testimony.pdf(3126216 bytes )
`Ex. 62-Pulvirent Rebuttal Testimony.pdf(5137965 bytes )
`Ex. 63-Pulvirent Rebuttal Testimony.pdf(306324 bytes )
`
`

`

`
`
`EXHIBIT 400EXHIBIT 400
`
`
`
`EXHIBIT 51EXHIBIT 51
`
`OFFERED BY AUDEMARS PIGUET
`
`OPPOSITION 91242213
`
`
`
`AUDEMARS PIGUET v. HAAS OUTDOORSAUDEMARS PIGUET v. HAAS OUTDOORS
`
`

`

`Echoing the foundation logo, the caseback is engraved
`with the inscription Royal Oak Offshore Arnold’s
`All-Stars - Limited Edition, A discreet reminder that
`
`=|
`
`.
`
`this exceptional series comprises just 350 watches.
`
`Pink gold and crocodile leather
`Pink gold case and hands, brown dial, dark brown
`crocodile leather strap: warm and subtle colours
`sublimating rare and precious materials.
`
` Limited edition
`
`An exceptional chronograph
`The Royal Oak Offshore Arnold's All-Stars Chronograph
`houses the exclusive Audemars Piguet selfwinding
`Calibre 3126. This movement combines the qualities
`of sturdiness, reliability and rating precision:
`
`* up to 60 hours’ power reserve thanks to a
`mainspring which, by supplying constant force over a
`longer time-span, ensures enhanced rating accuracy;
`* a cross-through balance-cock reinforcing the
`reliability of the movement;
`* a balance-stop mechanism serving to immobilise
`the seconds hand and thus enabling time-setting to
`the nearest second;
`
`*
`
`® a variable-inertia balance equipped with eight inertia-
`blocks enabling precise and stable adjustment;
`
`* fast date correction with an integrated security
`system avoiding any risk of date disc blockage
`when the adjustment occurs at midnight;
`
`* bidirectional automatic winding of the mainspring
`by means of a 22-carat gold rotor mounted on a
`ball-bearing mechanism.
`
`The traditional 3840 chronograph is integrated into
`this base calibre.
`
`

`

` The “After-School All-Stars” Foundation
`
`"Kids who have no place to go ‘end up going, nowhere. Kids with some place to go end up going
`places.” Such is the motto of the “After-School All-Stars” Foundation which, under the aegis of
`Arnold Schwarzenegger, 4 longstanding friend of the Manufacture, offers extra-curricular activities
`for middle-school children. The aim is to provide pro-active support for 7- to 14-year-olds who,
`particularly in underprivileged citcles, are often left to their own devices after school, and thus to
`help them resist violence, gangs and drugs.
`Help with homework and tutoring, games combining leisure and learning opportunities, personal
`enrichment programmes: all
`these activities target well-defined goals. These include getting
`organised with schoolwork and acquiring independentlearning skills, a fun-oriented approach to
`literature, maths and science, developing personal talents as well as anger management, conflict
`resolution and money management. In a nutshell, nurturing the self-confidence of these young
`citizens and encouraging their successes, whetherin the family, at school or in society.
`
`www.afterschoolallstars.org
`
`

`

`
`
`Technical specifications
`
`Royal Oak Offshore
`Arnold's All-Stars Chronograph
`Reference
`261580R.00.A801CR.01
`Limited edition of 350
`
`Movement
`Calibre: 3126/3840, selfwinding
`Total diameter: 11,5 lignes (26 mm)
`Thickness: 7.16 mm
`59 jewels
`365 parts
`Power reserve: up to 60. hours
`Cadence of the balance: 21,600 vibrations per hour
`Variable-inertia balance with eight inertia-blocks and
`flat balance-spring
`Geneva-type mobile balance-spring stud-holder
`Three-position winding crown
`Finishing: all parts decorated by hand; mainplate
`rhodium-plated, bevelled and stippled; bridges adorned
`with “cdtes de Genéve” motif
`
`Functions
`Hours and minutes
`Small seconds
`Chronograph with central seconds hand,
`30-minute and 12-hour counters
`Tachometric scale around the flange
`Date
`
`Case
`18-carat pink gold
`Diameter: 48 mm
`Thickness: 14.6 mm
`Water-resistance: 100 m
`Caseback engraved with the inscription Royal Oak Offshore
`Armold’s All-Stars — Limited Editien
`
`Dial
`Brown, with exclusive “Maga Tapisserie” pattern
`Snailed hour-circle
`Luminescent pink gold hour and minute hands; pink gold
`central chronograph seconds hand
`
`Strap
`Large square-scale hand-sewn brown crocodile leather with
`18-carat pink gold buckle
`
`
`
`
`
`
`
`

`

`
`
`ROYAL OAK OFFSHORE ARNOLD'S
`
`ALL-STARS CHRONOGRAPH
`
`In tribute to the “After-School All-Stars” Foundation created by Arnold Schwarzenegger,
`
`Audemars Piguet has created the Royal Oak Offshore Arnold’s All-Stars Chronograph, a new
`
`addition to the ultra-sporty Royal Oak Offshore collection. This limited edition features
`
`an imposingly sized pink gold case, a design in tune with the collection codes, and has
`
`adopted the exclusive Audemars Piguet selfwinding movement, endowed for the occasion
`
`with chronograph functions.
`
`“axtreme sports” watch,
`
`The design codes
`
`The Royal Oak Offshore Arnold's All-Stars Chronograph
`picks up all the signature features of the Royal Oak
`Offshore collection:
`
`* a “strongbox” case designed to protect the mechanism
`from any external stresses and strains:
`
`* an octagonal bezel secured with hexagonal screws;
`* a visible water-resistance seal between the bezel
`and the case;
`
`* exclusive guilloché “Méga Tapisserie” dial motif;
`
`* perfectly integrated case and bracelet.
`
`An XXL watch
`
`The case dimensions are impressive:
`48 mm in diameter.
`
`Down to 100 m
`
`Water-resistance worthy of this luxury
`
`

`

`
`
`AP
`AUDEMARSPIGUET
`
`Le maitre de l’horlogerie depuis 1875
`
`Audemars Piguet (Marketing) SA
`Route de France 16 - P.0. Box 16 - 1348 Le Brassus - Switzerland
`Telephone: + 41 21 845 14 00 - Fax: + 41 21.845 1.01
`www. audemarspiquet.com
`
`001491
`
`

`

`EXHIBIT 405
`
`EXHIBIT 52
`
`
`
`OFFERED BY AUDEMARS PIGUETOFFERED BY AUDEMARS PIGUET
`
`OPPOSITION 91242213
`
`AUDEMARS PIGUET v. HAAS OUTDOORS
`
`

`

`The Jaeger-LeCoultre Reverso Watch Turns 80 - The New York Times
`
`Page 3 sur 3
`
`Another reasonfor the Reverso’s enduring status is its unisex appeal. In
`Europe, where the companyseesits biggest sales, the watch sells about equallyto
`men and women.
`
`“It speaks to both,” Mr. Lambert said. “Menget to enjoy the technical aspect
`of having two sides on which to display complications. But the watch still looks
`elegant and sophisticated, something women really appreciate.”
`
`The company “hasreally hit a sweet spot with the current Reversos,”said
`Thomas Mao, a curator for watch collections who is an adviserfor the watch
`aficionadosite PuristSPro.com. The timepiece is “appealing to both the serious
`watch enthusiast, with magnificent manufacture movements, and the aesthete
`who appreciates classical, low-key yet stylish design,” he said.
`
`Those characteristics are present in the two models introducedthis year for
`the anniversary. The Tribute to 1931 watch runs with a Jaeger-LeCoultre Caliber
`822 ultra-thin, manually wound movement, manufactured in-house, that
`measures 2.94 millimeters, or a tenth of an inch, in depth. The plain, almost
`austerely simple dial features just the word Reverso, without the usual Jaeger-
`LeCoultre logo, an elegant nod to the original design.
`
`At the other end of the spectrumin terms of complexity, a new minute
`repeater chiming model, the Reverso Répétition Minutes 4 Rideau, reinvents the
`traditional function of the protective case back, turning it into a sliding curtain
`that activates the watch’s chimes.
`
`Both watches speak to a rediscovered awareness among the wealthyof the
`charms of discretion in an age of austerity.
`
`“During turbulent socioeconomic times, the wealthy don’t necessarily want
`to flaunt their wealth,” Mr. Mao said.
`
`a
`A version of thie a
`icle appears in painton December 4, 2071, on Pace ST14 of the New York adition
`
`with the headline:
`The Only Way To Pub The in Feverse.
`
`© 2018 The New York Times Company
`
`a
`FIGLES REMAINING
`
`https://www.nytimes.com/201 1/12/04/fashion/the-jaeger-lecoultre-reverso-watch-turns-80.html
`
`002088
`16.10.2018
`
`

`

`EXHIBIT 410
`
`EXHIBIT 53
`
`OFFERED BY AUDEMARS PIGUET
`
`
`
`OPPOSITION 91242213OPPOSITION 91242213
`
`AUDEMARS PIGUET v. HAAS OUTDOORS
`
`

`

`This Sporting Life; An affinity between the sporting and the elegantn...
`
`http://search.proquest.com/docview/1460550834/141FB8376422A...
`
`The two watches that triggered the now-irreversible taste for huge watches back in the early-to-mid-1990s were IWC's Portuguese, the reissue of a 1930s
`model based on a pocket watch as a dress watch, and the revival of Panerai, a purely military diving watch. They were, however, defined by specific,
`immutable roles, Wearing either out of context--as many do--is no longer considereda faux pas.
`
`Defining a true "sports watch"is as simple as explaining that they tell the time like any watch, only they are able to do it in extreme conditions. It is an
`indisputable example of form following function. For dress watches,it is the opposite. They need to exude suavity, which accounts for the appearance of so
`many "ultra-thins," with slim cases that won't withstand. the rigors of sport.
`
`Combining the two enabled ownersto survive society's casual and formal dress codes with a single watch.
`
`Less than five years after the Royal Oak appeared, Genta supplied a design to Audemars Piguet's rival watch house, Patek Philippe. It, too, wanted a
`timepiece that its clients could wear while sky-diving, swimming, playing golf or tennis, hang-gliding or anything else they might care to pursue, without
`having to takeit off for dinner.
`
`Patek Philippe's response wasthe sublime Nautilus, which begat a simpler modelcalled the Aquanaut. Genta again produced a robust design that suggested
`the impermeability of a ship's porthole, while exhibiting constructional details worthy offine jewelry. It evolved over the decades beyondits stainless-steel,
`time-only-display origins into a family of watches in various metals and hosting the most extreme of complications. It may seem like missing the original
`point, but is it any different from a Range Rover, with its roots in a vehicle designed to cross deserts or mountains, sporting a leather interior,
`air-conditioning and chrome wheels?
`
`As with so manythings discovered belatedly, the earliest examples of the Audemars Piguet Royal Oak and Patek Philippe Nautilus, the original 1970s debut
`models, now appear in auctions with elevated prices due to scarcity. Fetching frightening sumsis the large version of the Nautilus, affectionately referred to
`as the "Jumbo,” currently the watch du jour, especially for Italian enthusiasts. Recent auction results in the U.K. have turned up 1970s-80s Jumbosfor
`£8,000-£10,000 ($12,500-$15,500/[euro]9,300-[euro]11,600), if one is brave enough to compete, but vintage watch specialists online ask $20,000-$35,000
`(Leuro]14,900-[euro]26,000) for the earliest examples. Oddly, some steel versions fetch more than their gold or steel-and-gold counterparts.
`
`Whytherarity? It wasn't just the idea of paying gold-watchpricesfor stainless-stee! models that hampered the early adoption of the Royal Oak and the
`Nautilus.
`
`Forty years ago, oversized watches weren't merely rare, they were considered freakish. Both have benefited, retroactively, from the changein tastes
`toward huge timepieces.
`
`Patek Philippe wisely reintroduced the Nautilus line in 2005, a year ahead of the watch's 30th anniversary. Second time around, the reception was ecstatic.
`As with the Royal Oak family, the Nautilus range includes models with moon phase, calendar and powerreserve, as well as the current Nautilus 5980/1
`featuring the company’s new in-house chronograph movement. The subject of a waiting list, the 5980/1 changes handsat a premium, as much as £6,000
`([euro]7,000) over the £34,460 (approx. [euro]40,000)retail price.
`
`Patek Philippe and Audemars Piguet don't have the marketentirely to themselves. The third memberof the classic triumvirate, their senior sparring partner
`Vacheron Constantin, produces the handsome Overseas,available in time-only models, world travelers or chronographs, with bracelets or straps. This would
`be the watch to wear if you believe that discretion is a virtue without parallel.
`
`Hublot, which gave the world the now de rigueur rubber strap, came back from the brink with the brilliantly conceived Big Bang series, unmistakably the
`bastard child of the Royal Oak, only edgier and probably aimed at wearers who would choose a Lamborghini over a Bentley, or a Black Russian over a glass
`of Masseto. Jean-Claude Biver, Hublot's former CEO, is one of the watch kingdom's mostinventive souls, and the Big Bangis his palette.
`
`Probably the hottest sport/dress watch brand at present, the Big Bang was enhanced by the introduction of colorful, gem-clad series called Tutti Frutti,
`specifically for its distaff clients. In 2012, and renewed for 2013, there is a tie-in with Ferrari, resulting in suitably attired models with automotive design
`details and the status of being officially sanctioned.
`
`Rolex, however, gets the last laugh, as it is the official timekeeper for the whole of Formula One, which must rankle with all of the brands--such as Hublot
`and Richard Mille--which have their own deals with teams or individual drivers.
`
`It's fitting, too, that another watch brand with a century's experience in sport watches, for which the term "thoroughbred"is no conceit, offers elegant
`timepieces able to suit more than one role. Hermés, with equestrian DNA,offers its own classic model, the aptly named Dressage, as weil as the Clipper,
`with nautical overtones.
`
`Other houses support other sports: Piaget has its Polo; TAG Heuer, the Golf Watch; Rolex, the Yacht-Master; and IWC, the Aquatimer; while Ralph
`Lauren--ever tasteful--choosesnot to discriminate: the model rangeit designed to keep companyin either milieu is called, simply, the Sporting Collection.
`The latest in the family?
`
`The Safari Chronometer, complete with "aged black" metal finish and canvasstrap, with a military look provided by its cream numbers on a black
`background. It suits perfectly the sort of chap who dresseslike Allan Quatermain regardless of the occasion.
`
`In these egalitarian times, such distinctions might seem pedantic--even with the generosity of spirit demonstrated by watches with dual personalities. But
`should confusionstill reign, note that nobody was ever thrownout of a restaurant or sports bar, casino or golf clubhouse, for wearing a classic watch ofeither
`genre. Patek Philippe's Calatrava? The David Niven of watches. The Rolex Explorer II? Clark Gable in stainless steel. A cynic might argue that the rest are
`mere Wayne Rooneys.
`
`Corrections & Amplifications
`
`Betweenthe time ofprint of this article in the Spring 2013 Watches & Jewelry special supplementin the Europe and Asia editions of The Wall Street Journal,
`Rory McIlroy has become an ambassador for Omega Watches and no longer has an association with Audemars Piguet.
`
`Credit: By Ken Kessler
`
`(c) 2013 Dow Jones & Company, Inc. Reproduced with permission of copyright owner. Further reproduction or distribution is prohibited without permission,
`
`2 of 3
`
`11/26/2013 3:14 PM
`002099
`
`

`

`This Sporting Life; An affinity between the sporting andthe elegant n...--
`
`http://search.proquest.com/docview/1460550834/141FB8376422A...
`
`Indexing (details)
`Title
`
`Cite
`
`Author
`Publication title
`Pages
`Publication year
`Publication date
`Year
`Section
`Publisher
`
`Place of publication
`Country of publication
`Publication subject
`Source type
`Languageof publication
`Documenttype
`ProQuest document ID
`Document URL
`
`Copyright
`
`Last updated
`Database
`
`This Sporting Life; An affinity between the sporting and the elegant now dominates
`the marketfor quality timepieces.
`Kessler, Ken
`Wall Street Journal (Online)
`n/a
`2013
`
`Nov 22, 2013
`2013
`
`Life and Style
`Dow Jones & CompanyInc
`New York, N.Y.
`United States
`Business And Economics
`
`Newspapers
`English
`News
`1460550834
`
`http://search. proquest. com/docview/1460550834?accountid=34685
`(c) 2013 Dow Jones & Company, Inc. Reproduced with permission of copyright
`owner. Further reproduction or distribution is prohibited without permission.
`2013-11-26
`
`National Newspapers Core
`
`About tags | Go to My Tags
`Tags
`Be thefirst to add a shared tag to this document.
`
`Add tags
`Sign in to My Research to add tags.
`
`Back to top
`
`
`Contact Us
`
`Accessibility
`
`Sitemap
`
`Privacy Policy
`
`Cookie Poticy
`
`Copyright © 2013 ProQuest LLC. All rights reserved. Terms and Conditions
`
`Spee.
`Bantimore CountyPublic Litnare
`Explore BCPL's
`other online
`databases...
`
`11/26/2013 3:14 PM
`002100
`
`

`

`EXHIBIT 54
`
`OFFERED BY AUDEMARS PIGUET
`
`OPPOSITION 91242213
`
`AUDEMARS PIGUET v. HAAS OUTDOORS
`
`
`
`EXHIBIT 406EXHIBIT 406
`
`

`

`EXHIBIT 411
`
`EXHIBIT 55
`
`OFFERED BY AUDEMARS PIGUET
`
`
`
`OPPOSITION 91242213OPPOSITION 91242213
`
`AUDEMARS PIGUET v. HAAS OUTDOORS
`
`

`

`
`
`
`
`
`
`
`
`
`
`RAMIN/THEWALLSTREETJOURNAL,STYLINGBYGABRIELRIVERA;ILLUSTRATIONBYMICHAEL F.MARTINSLOAN
`
`_
`
`Ce
`
`|
`
`BUCKLE LIST From left: Seamaster Aqua Terra ISOM Master Co-Axial Watch, $6,000, omegawatches.com; Royal Oak Offshore
`Chronograph Watch, $33,400, audemarspiquet.com; Classima 10214 Watch, $2,350, baume-et-mercier.com
`
`online at two collections—
`Audemars Piguet’s Royal Oak
`and Tag Heuer’s Carrera—to
`see plenty of watches with
`all three types of straps.
`One morestyle note:
`Leather comes in enough
`colors to rival a 64-box of
`Crayolas. The sameis true
`of rubber. If you’re looking
`for an eccentric pop of color
`on your wrist, leather or
`rubberare for you.
`On to practical concerns:
`Alwaystry a timepiece on
`before you buy to be sure
`the fit and general feel of
`the strap are comfortable,
`especially for those with
`metal bracelets.
`Metal bracelets usually
`
`consist of connected links. On
`somewrists, the narrow slit
`between eachlink will pinch
`the skin or pull wrist hair. If
`you experience either of these
`painful annoyances while
`trying on a watch, hunt for
`one with a metal bracelet that
`doesn’t threaten your wrist
`with torture or depilation.
`Notall metal bracelets use
`links, of course. Metal meshis
`an alternative. There are two
`kinds: elegant Milanese mesh
`and tougher-looking Shark
`Mesh,originally developed
`for dive watches. Leather,
`whetherthick or thin, does
`not generally pinch or grab,
`though it does wear out over
`time in ways metal won't.
`
`The next thing to con-
`sider is price. Rubber is
`the mostaffordable option,
`while metal almost always
`costs more than leather.
`A new watch with a metal
`bracelet will set you back
`anywhere from a few hun-
`dred to a few thousand dol-
`lars more than the same
`watch with a leather strap.
`If you eventually sour on
`your strap choice, changeit.
`With most contemporary
`watches and many vintage
`pieces, this can be done with
`the right equipment and a
`little patience. Well, maybe
`a lot of patience. If you slip
`and gouge the case, the re-
`pair bill might be hefty. To
`
`avoid the risk, you can al-
`ways take your watch to
`a professional, and have him
`or her swap the strap.
`If your horological budget
`is limited, swapping brace-
`lets and straps is a great
`wayto refresh the look of
`your watch, whether for a
`new season or that daunting
`job interview. And you’re not
`limited to buying a strap
`from the same brand that
`made your watch. Thousands
`of choices, including increas-
`ingly popular textile straps,
`are available in every price
`segment. In fact, I highly
`recommend strap-hopping.It
`may be the most fun a man
`can have with his watch.
`
`
`
`ENTS
`
`MORE PARTYTRICKS// RECENT TRENDS
`
`

`

`
`
`EXHIBIT 412EXHIBIT 412
`
`EXHIBIT 56
`
`
`
`OFFERED BY AUDEMARS PIGUETOFFERED BY AUDEMARS PIGUET
`
`OPPOSITION 91242213
`
`AUDEMARS PIGUET v. HAAS OUTDOORS
`
`

`

`r =
` ‘
`
`authorized dealer. While there are
`other legitimate online sellers, in-
`cluding individuals on sites like
`eBay, it’s easy to be fooled. Watch
`out for obvious red flags such as
`negative or outdated reviewson
`sites which include reviews. Also
`suspect are blurry photographs or
`ones that are clearly stolen from a
`brand’s website and don’t depict
`thetimepiece that’s actually being
`ow site is even
`
`S: zo3
`
`a little difficult, don’t buy. And
`while you might be tempted by,
`say, a Breitling Navitimer for
`$2,000—much less than the
`$8,000 to $48,000a brand-new
`one usually costs—if a price seems
`too goodto be true,it probably is.
`For further vigilance, always buy
`using PayPal or a credit card that
`offers protection on purchases.
`You may be able to reclaim some
`of your money ifyou’re duped.
`
`wal
`
`lished earlier this year, profits
`from the sale of fake watches (and
`other counterfeit goods) fund or-
`ganized crime,drug trafficking
`and terrorism.
`If you’re the sort of person
`who would never buy a cheap fake,
`the question becomes: Howdoyou
`avoid mistakenlypurchasing asu-
`oer fake? Regularreaders ofthis
`
`buying
`zolumnknow 1
`
`aewwatches onlyponeane or.
`
`ie
`
`Z :
`
`. mf
`
`

`

`DOCUMENT 55
`
`EXHIBIT 57
`
`
`
`OFFERED BY AUDEMARS PIGUETOFFERED BY AUDEMARS PIGUET
`
`OPPOSITION 91242213
`
`AUDEMARS PIGUET v. HAAS OUTDOORS
`
`

`

`DOCUMENT 53
`
`
`
`EXHIBIT 58EXHIBIT 58
`
`OFFERED BY AUDEMARS PIGUET
`
`OPPOSITION 91242213
`
`
`
`AUDEMARS PIGUET v. HAAS OUTDOORSAUDEMARS PIGUET v. HAAS OUTDOORS
`
`

`

`DOCUMENT 54
`
`EXHIBIT 59
`
`
`
`OFFERED BY AUDEMARS PIGUETOFFERED BY AUDEMARS PIGUET
`
`OPPOSITION 91242213
`
`AUDEMARS PIGUET v. HAAS OUTDOORS
`
`

`

`EXHIBIT 60
`
`OFFERED BY AUDEMARS PIGUET
`
`
`
`OPPOSITION 91242213OPPOSITION 91242213
`
`AUDEMARS PIGUET v. HAAS OUTDOORS
`
`DOCUMENT 52
`
`

`

`MICHAEL CONNELLY
`
`and thecall list analysis had been discontinued. It was a sub-
`tle form of tunnel vision. They now had the bird in hand—
`Foster—so there was no needto finish going through hundreds
`of phonecalls and numbers that did not have any direct ties to
`their suspect.
`Bosch openedhis laptop and looked up Nelson Grant & Sons
`Jewelers. With Google mapshe located its Sunset Boulevard ad-
`dress in the upscale Sunset Plaza shopping district and learned
`that the store openedat ten o’clock each morning.
`Hedecided to visit the store as soon as it opened, but that
`wouldn’t be for nearly an hour. He opened the business’s website
`and determined that the shop dealt in manylines of jewelry and
`watchesas well as handledestate sales.But he could notfind any
`references to Audemars Piguet watches,
`|
`He then Googled the watchmaker and found several online
`dealers. He clicked on one ofthese and soon’ was looking at an
`array of watches manufactured by the Swiss company. He fur-
`ther refined his search to ‘the Royal Oak Offshore model and
`soon was looking at a watch with a $14,000 price tag.
`Bosch whistled. The discrepancy between what Harrick paid
`a year ago for the same model and the current¢ online retail price
`was nearly ten thousand dollars.
`Hewent back to the manufacturer’s website-and clicked on
`thelist of certified Audemars Piguet dealers. There were only
`three shops and service'centersin the United States and the clos-
`est to L.A.was in LasVegas. Bosch pulled up two numbersfor
`the service center andthen went back to the phone logs from
`the murder book. Scanning the call logs for matches was easy
`and quick because ofthe 702 area code for Las Vegas. Bosch
`found two’calls connected to the service center.On Thursday,
`February 5—thesame day Lexi Parks called Nelson Grant &
`
`206
`
`

`

`’. MICHAEL CONNELLY
`
`“Audemars Piguet,” the man said, pronouncing it quite dif-
`ferently than. Bosch. had. “We are not a dealer. But on occasion
`"we sell AP watchesthrough estate sales. We had twolast year
`_ but they sold. They.re collector’s items and they go quickly
`
`- whenweget them.”
`' “So they would have been used.”
`“We prefer.to say estate owned.”
`“Gotit. Estate owned. You know, now that you mentionit,I
`think I was in here last year and saw one.It wasa ladies’ watch?
`_ Wasthat back in December when you hadit?”
`“Uh,yes, I believe so. That wasthe last one we had.”
`“A Royal Oak,right?”
`“Actually, the model was a RoyalOak Offshore, Are you a
`
`collector, sir?” -
`“A collector? In a way, yeah. So I haveafriend. Vincent Har-
`rick? You know him? He was the one who bought that AP
`watch back in December,right?”
`The man looked suspicious and confused at the same time.
`“I’m not at liberty to discuss ourclients, sir. Is there a watch
`here that we do havethat I can show you?”
`He gestured with his arm across the glass top of the counter.
`Bosch looked at himwithout answering. There was something
`off. As soon as Bosch mentioned Harrick and the watch bought
`in December, theman seemed to grow nervous. He had made a
`furtive glance behind him at the doorto the back room.
`Bosch decided topush things a bit and to gauge the man’s re-
`' actions.
`“So whodied?”he asked.
`“Whatare you talking about?” the man replied,his voiceal-
`most shrill.
`- “To havean estate sale, somebody’s gotta die, right?”
`
`212
`
`

`

`EXHIBIT 61
`
`
`
`OFFERED BY HAAS OUTDOORSOFFERED BY HAAS OUTDOORS
`
`OPPOSITION 91242213
`
`AUDEMARS PIGUET v. HAAS OUTDOORS
`
`

`

`7/22/22, 10:47 AM
`
`https:/Avww.sec.gov/Archives/edgar/data/7 1691/000100547701001357/0001005477-01-001357-0004 txt
`Securities registered pursuant to Section 12(g) of the Act:
`
`Not Applicable
`(Title of class)
`
`Indicate by check mark whether the registrant (1) has filed all reports
`required
`to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934
`during
`the preceding 12 months and (2) has been subject to such filing requirements
`for
`the past 90 days. Yes
`
`[X| No
`
`|_|
`
`Indicate by check mark if disclosure of delinquent filers pursuant to Item
`405
`to the
`of Regulation S-K is not contained herein, and will not be contained,
`best of registrant's Knowledge,
`in definitive proxy or information statements
`incorporated by reference in Part III of this Form 10-K or any amendment to
`this
`Form 10-K.
`
`|X|
`
`The aggregate market value of Class A Common Stock held by non-affiliates as
`of
`February 16, 2001, was approximately $5.8@ billion. As of such date,
`non-affiliates held 93,2708 shares of Class B Common Stock. There is no active
`market for such stock.
`
`The. number. ofoutstanding. shares.of each class of the registrant's common _
`stock
`as of February 16, 2001, was as follows: 161,310,881 shares of Class A Common
`Stock and 847,158 shares of Class B Common Stock.
`
`Document incorporated by reference
`
`Part
`
`Proxy Statement for the 2001 Annual Meeting of Stockholders..............
`IIt
`
`INDEX TO THE NEW YORK TIMES COMPANY
`
`2000 FORM 10-K
`
`https:/Awww.sec.gov/Archives/edgar/data/7 1691/000100547701001357/0001005477-01-001357-0001.txt
`
`277
`
`

`

`7/22/22, 10:47 AM
`
`<TABLE>
`
`<CAPTION>
`
`https://www.sec.gov/Archives/edgar/data/7 169 1/000100547701001357/0001005477-01-001357-0001.txt
`
`PART I
`
`1. Business
`Oe eee meee ee mee meee eee eer etree veneer ernereesereresneeseese
`
`cece eee
`
`1
`
`Introduction... . cc ccc cee etre cee ee eect eee eee eae
`
`tte cece eens
`
`1
`
`NQ@WSPAPErS.. ce cee ee ee eee eee eee erence eee eee een etene
`oe @ pe &@
`@
`@
`© ee ee eo
`1
`The New York
`TIMES... cc cc cc ee ee ere eee eee eee tee eee tare eees
`
`1 C
`
`Urculation... cece cece cece c erence reer ereeeees
`eee eeee
`1
`
`AdVertising. .. ccc ccc ccc eec ee eee eee rete eee eees
`
`Production and
`DIStPiDUTION. .. cece ccc cece ee eee rere eee eer eee eeees
`
`2
`
`Related
`BUSINESSES. oc cc ce ce eee ee eee ee eee renee reece eees
`
`3
`
`New England Newspaper
`GROUP... cee ee eee ee tee ee eet eee eee eee etter eeeenes
`Circulation: The
`(CH We)0)
`Circulation:
`
`WOPCESTER. .. cece cee ee ee ere eee eee ene eee eee e tee ee eenee
`
`oeseeevee
`
`3/177
`
`4 A
`
`dVertiSing. .. cc cece cee eee ee eee eee eres eenes
`cece eee
`
`5 P
`
`roduction and
`DiStPAbUtiON. ... cece cece eee ee eee eee e eee tees eeenee
`5
`
`Regional
`NGEWSPAPErS. ccc eee e cece ee eee ee ee eee eee eee eee erees
`https:/Awww.sec.gov/Archives/edgar/data/7 1691/000100547701001357/0001 005477-01-001357-0001.txt
`
`

`

`7/22/22, 10:47 AM
`
`https:/Avww.sec.gov/Archives/edgar/data/7 169 1/000 100547 70 1001357/0001005477-01-001357-0001.txt
`
`5
`
`Broadcasting... . cece eee e ee eee eeceeees veer e ee eee cece ee ees
`See w eee eee
`6
`
`Magazines............4.. cece eee Lee eee eee eee ee eee ee eee eee eee ee eens
`cece ee eecee cee
`7
`New York Times
`Digital........... See eect cence See eee eee eee cece eee Sees .
`7
`
`Forest Products Investments and Other Joint
`VENTUPe lL... eee cc cee eee tenes sete eee e
`en eees
`_ Forest Product
`INVESEMENTS . cc eee ee ce ee ee eee ee ee ee eee eee eee EEE eee Eee eee eeee
`
`8
`
`8
`
`Other Joint
`
`VENTURE. . ccc ccc cc ee ee eee eee ee ee ee rere eee eee eee eee eee eee eee eTee
`
`8
`
`Raw
`Materials... ccc ccc cc ee ee ee ee eee et ee eee eee eee eee tenet e ees cent ence
`sce ee eee
`8
`Competition
`
`EMPLOVC@S sc cece cee c cscs eee e eee e ee ence eee e eee e eee e nee n een e eee e een ees
`cece e ew eee
`10
`we ADORL ee
`RELAtionS...ccccccccccc cece eee cee cece eee eee eee ee ee ee ee eee eee ene eee eenes
`
`.
`
`wees
`
`12
`
`2.
`eT axe) Y=] pa=o
`cece eee eee renee
`11
`3.
`Legal
`PROCGCdINEGS. .. cece eee eee eee reer eee eee eeeeeee cece ee ewes cece cece eens
`see e eee
`12
`4.
`Submission of Matters to a Vote of Security
`HOLdErs.. cece cece eee eee ce eee eee eee eerste tenes
`Executive Officers of the
`Registrant... ... ccc cece cee eeeees sec eee eee beeen ee eee cece e eens
`
`12
`
`12
`
`5. Market for the Registrant's Common Equity and Related Stockholder
`Matters... ccc cece rece cccees
`13
`6. Selected Financial
`Data...... sneer wee reenter cere erene cee Lecce ee wee rere reese eee eteees
`
`PART II
`
`13
`
`7. Management's Discussion and Analysis of Financial Condition and Results
`hitps:/Awww.sec.gov/Archives/edgar/data/7 1691/000100547701 001357/0001005477-01-001357-0001.txt
`
`41177
`
`

`

`https:/Awww.sec.gov/Archives/edgar/data/7 169 1/000 100547701001357/0001005477-01-001357-0001 txt
`H22122, 10:47 AM
`of Operations.........
`13
`8. Financial Statements and Supplementary
`13
`DATA, Cece cc cece ee ee ete eee ee eee eee eee tae eee eeeee
`9. Changes in and Disagreements with Accountants on Accounting and
`Financial Disclosure..........
`13
`
`PART IIT
`
`18. Directors and Executive Officers of the
`RESISTPANt. .. Lee cc eee eee eee eee eee eee eee eens
`11. Executive
`Compensation... .. ccc cece evecceees vee e eee eee Lemme eee eee ee eee eee ene e eee eees
`wee e nee
`14
`12. Security Ownership of Certain Beneficial Owners and
`Management...... secre ere e ener ene rareceses
`14
`13. Certain Relationships and Related
`TRANSACTIONS... eee cece eee cence eee eeee Chee eee ee eee cence
`
`14
`
`13
`
`14. Exhibits, Financial Statement Schedules and Reports on Form 8-
`Kiceececcecevcceseeeecsteeveecs .
`14
`</TABLE>
`
`PART IV
`
`<PAGE>
`
`1
`
`ITEM 1. Business.
`
`INTRODUCTION
`
`PART I
`
`The New York Times Company (the "“Company") was incorporated on August 26,
`1896,
`under the laws of the State of New York. The Company is a diversified media
`company including newspapers, television and radio stations, magazines,
`electronic information and publishing, Internet businesses, and forest
`products
`investments. Financial information about industry segments is incorporated by
`reference to Note 16 to the Consolidated Financial Statements on page F-31 of
`this report.
`
`The Company currently classifies its businesses into the following segments:
`
`O
`
`the New England Newspaper
`Newspapers: The New York Times ("The Times");
`Group, consisting of The Boston Globe, a daily newspaper,
`the Boston
`https://www.sec.gov/Archives/edgar/data/7 169 1/000 10054770 1001357/000 1005477-01-001357-0001 txt
`
`5/177
`
`

`

`7/22/22, 10:47 AM
`https://Awww.sec.gov/Archives/edgar/data/7 169 1/000100547701001357/0001005477-01-001357-0001 txt
`Sunday Globe (both editions,
`"The Globe") and the Worcester Telegram &
`Gazette,
`in Worcester, Mass.
`(acquired January 7, 2000); 14 other daily
`newspapers in Alabama, California, Florida, Louisiana, North Carolina
`
`and
`
`New
`
`South Carolina ("Regional New

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.