Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
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`ESTTA Tracking number:
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`ESTTA959315
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`Filing date:
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`03/11/2019
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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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`91246089
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`Party
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`Correspondence
`Address
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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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`Defendant
`Ogle, Elrod & Baril PLLC
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`JACOB G. HORTON
`PITTS & LAKE, P.C.
`P.O. BOX 51295
`KNOXVILLE, TN 37950-1295
`docketing@pittslake.com, jhorton@pittslake.com, swebb@pittslake.com
`no phone number provided
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`Answer
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`Jacob G. Horton
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`docketing@pittslake.com, jhorton@pittslake.com, kself@pittslake.com
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`/Jacob G. Horton/
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`03/11/2019
`
`Attachments
`
`00520499.PDF(137600 bytes )
`
`
`
`ESTTA Tracking number:
`
`ESTTA959315
`
`Filing date:
`
`03/11/2019
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91246089
`
`Party
`
`Correspondence
`Address
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Defendant
`Ogle, Elrod & Baril PLLC
`
`JACOB G. HORTON
`PITTS & LAKE, P.C.
`P.O. BOX 51295
`KNOXVILLE, TN 37950-1295
`docketing@pittslake.com, jhorton@pittslake.com, swebb@pittslake.com
`no phone number provided
`
`Answer
`
`Jacob G. Horton
`
`docketing@pittslake.com, jhorton@pittslake.com, kself@pittslake.com
`
`/Jacob G. Horton/
`
`03/11/2019
`
`Attachments
`
`00520499.PDF(137600 bytes )
`
`
`
`
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`GLENN J. LERNER
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`Opposer,
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` OGLE, ELROD & BARIL PLLC.
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`Applicant.
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`Opposition No. 91246089
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`Mark: TURN YOUR WRECK INTO A
`CHECK
`Application No.: 87699851
`Published: October 30, 2018
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`ANSWER TO NOTICE OF OPPOSITION
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`In Response to the Notice of Opposition filed by Glenn J. Lerner (“Opposer”), Applicant
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`Ogle, Elrod & Baril, PLLC. (“Applicant”), having an address of Suite 700, 706 Walnut Street,
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`Knoxville, Tennessee 37902, responds as follows.
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`Applicant denies each and every allegation of the Notice of Opposition unless it is
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`expressly admitted herein.
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`In response to the preamble of the Notice of Opposition, Applicant denies that Opposer
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`will be damaged by the registration of Applicant’s trademark, “TURN YOUR WRECK INTO A
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`CHECK” shown in Application No. 87/699851.
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`1.
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`Applicant is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in paragraph 1, and, therefore, denies the same and demands strict proof
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`thereof.
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`2.
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`Applicant submits that the content of the United States Trademark Registration
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`No. 4,824,793 (“the ‘793 Registration”), United States Trademark Registration No. 4,446,411
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`1
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`(“the ‘411 Registration”), and United States Trademark Application Serial No. 86/671,095 (“the
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`‘095 Application) speak for themselves. As to the remaining allegations of paragraph 2,
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`Applicant is without knowledge or information sufficient to form a belief as to the truth of these
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`allegations, and, therefore, denies the same and demands strict proof thereof.
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`3.
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`Applicant is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in paragraph 3, and, therefore, denies the same and demands strict proof
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`thereof.
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`4.
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`Applicant is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in paragraph 4, and, therefore, denies the same and demands strict proof
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`thereof.
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`5.
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`Applicant is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in paragraph 5, and, therefore, denies the same and demands strict proof
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`thereof.
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`6.
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`Applicant denies that the services listed in Applicant’s U.S. Trademark
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`Application Serial No. 87/699,851 (“the ‘851 Application”) are identical to the services listed in
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`the ‘793 Registration. The identification of services listed in the ‘793 Registration is “Legal
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`services; Legal services in the field of personal injury and tort claims; Legal counseling and
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`advice to others; Providing information to others on legal services; Providing information to
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`others on legal services via the internet,” in Class 45. The identification of services listed in the
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`‘851 Application are “Legal services” in Class 45. Applicant denies that the services of
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`Applicant and Opposer are identical. Applicant admits the remaining allegations of paragraph 6.
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`7.
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`The allegations of paragraph 7 are denied.
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`2
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`8.
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`Applicant is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in paragraph 8, and, therefore, denies the same and demands strict proof
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`thereof.
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`9.
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`Applicant is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in paragraph 9, and, therefore, denies the same and demands strict proof
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`thereof.
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`PRAYER FOR RELIEF
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`Applicant denies that Opposer is entitled to any of the relief sought in its prayer for relief.
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`AFFIRMATIVE DEFENSES
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`Further answering the Notice of Opposition, and as additional defenses thereto, Applicant
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`asserts the following affirmative defenses, without assuming the burden of proof when the
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`burden of proof on any issue would otherwise rest with Opposer. Applicant expressly reserves
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`the right to amend its answer and defenses, and add additional defenses, as additional
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`information becomes available and/or is otherwise discovered.
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`FIRST AFFIRMATIVE DEFENSE
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`(Prior Good Faith Use – 15 U.S.C. 1115(b)(5))
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`1.
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`Applicant asserts the Affirmative Defense of prior good faith use of Applicant’s
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`“TURN YOUR WRECK INTO A CHECK” mark pursuant to 15 U.S.C. 1115(b)(5).
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`2.
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`The Applicant, Ogle, Elrod & Baril, PLLC., is a law firm specializing in personal
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`injury, motor vehicle accidents, spinal cord injuries, brain injuries, social security disability, and
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`faulty drugs and medical products. The Applicant has maintained a well-known and highly
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`successful practice throughout many portions of United States for many years, and at least as
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`early as 2006.
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`3.
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`Applicant has spent considerable time, effort, and expense promoting, advertising,
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`and popularizing its “TURN YOUR WRECK INTO A CHECK” trademark throughout the
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`United States, with the result that the purchasing public has come to know, rely upon, and
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`recognize Applicant’s “TURN YOUR WRECK INTO A CHECK” trademark as an indicator of
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`the source of the services offered and sold thereunder. Applicant has established valuable
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`goodwill in its “TURN YOUR WRECK INTO A CHECK” trademark.
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`4.
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`On November 28, 2017, the Applicant filed the ‘851 Application seeking
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`registration in the United States Patent and Trademark Office of its “TURN YOUR WRECK
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`INTO A CHECK” mark for use in connection with “legal services” in International Class 45.
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`5.
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`As reflected in the ‘851 Application, Applicant first used its “TURN YOUR
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`WRECK INTO A CHECK” mark anywhere at least as early as 2006, and first used its “TURN
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`YOUR WRECK INTO A CHECK” mark in interstate commerce at least as early as 2006.
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`Applicant has used its “TURN YOUR WRECK INTO A CHECK” continuously and exclusively
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`in connection with its services since at least as early as 2006. Thus, upon information and belief,
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`by virtue of its continuous and exclusive use of its “TURN YOUR WRECK INTO A CHECK”
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`mark in connection with its services, the Applicant has acquired and maintained common law
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`trademark rights in its “TURN YOUR WRECK INTO A CHECK” mark throughout at least a
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`portion of the United States since at least as early as 2006.
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`6.
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`At the time of Applicant’s first use of its “TURN YOUR WRECK INTO A
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`CHECK” mark, Applicant was unaware of, and had no knowledge of, any of the alleged marks
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`“IN A WRECK NEED A CHECK,” “IN A WRECK? NEED A CHECK?,” and “FROM
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`WRECK TO CHECK” (hereinafter, collectively, “Opposer’s alleged marks”) allegedly used by
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`Opposer.
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`7.
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`The application leading to issuance of the ‘411 Registration was filed on
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`November 2, 2012. The ‘411 Registration was issued on December 10, 2013.
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`8.
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`The application leading to issuance of the ‘793 Registration was filed on February
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`12, 2014. The ‘793 Registration was issued on October 6, 2015.
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`9.
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`The ‘095 Application was filed on June 23, 2015. The alleged basis for
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`registration of the alleged mark reflected in the ‘095 Application is that of “intent to use”
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`pursuant to Section 1(b) of the United States Trademark Act, 15 U.S.C. 1051(b). The ‘095
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`Application does not include an alleged date of first use of the alleged mark reflected therein.
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`10.
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`Applicant used its “TURN YOUR WRECK INTO A CHECK” mark prior to the
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`filing date of the application leading to issuance of the ‘411 Registration.
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`11.
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`Applicant used its “TURN YOUR WRECK INTO A CHECK” mark prior to the
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`filing date of the application leading to issuance of the ‘793 Registration.
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`12.
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`Applicant used its “TURN YOUR WRECK INTO A CHECK” mark prior to the
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`filing date of the ‘095 Application.
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`13.
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`As a result of Applicant’s continuous use of its “TURN YOUR WRECK INTO A
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`CHECK” mark, Applicant has acquired and maintained common law trademark rights in its
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`“TURN YOUR WRECK INTO A CHECK” mark prior to the constructive date of first use of
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`any of Opposer’s alleged marks pursuant to Section 7(c) of the United States Trademark Act, 15
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`U.S.C. 1057(c).
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`14.
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`As a result of Applicant’s continuous use of its “TURN YOUR WRECK INTO A
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`CHECK” mark, Applicant has acquired and maintained common law trademark rights in its
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`“TURN YOUR WRECK INTO A CHECK” mark prior to the first date of registration of any of
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`Opposer’s alleged marks.
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`15.
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`As a result of Applicant’s continuous use of its “TURN YOUR WRECK INTO A
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`CHECK” mark, Applicant has acquired and maintained common law trademark rights in its
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`“TURN YOUR WRECK INTO A CHECK” mark prior to the publication of the applications
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`leading to issuance of the ‘411 Registration and the ‘793 Registration.
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`16.
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`As a result of Applicant’s use of its “TURN YOUR WRECK INTO A CHECK”
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`mark, Applicant acquired common law trademark rights in its “TURN YOUR WRECK INTO A
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`CHECK” mark prior to any common law rights acquired by Opposer in any of Opposer’s alleged
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`marks in a common geographic area as that of Applicant’s common law rights in its “TURN
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`YOUR WRECK INTO A CHECK” mark.
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`17.
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`Given that the Applicant acquired common law trademark rights in at least a
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`portion of the United States in the “TURN YOUR WRECK INTO A CHECK” mark well before
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`the Opposer applied for registration of any of Opposer’s alleged marks, the Applicant has the
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`right to continued use of its “TURN YOUR WRECK INTO A CHECK” mark in its own
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`geographical region.
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`18.
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`To the extent Opposer has acquired any rights in Opposer’s alleged marks prior to
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`Applicant’s common law trademark rights in the “TURN YOUR WRECK INTO A CHECK”
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`mark, such rights were acquired in territories geographically remote from Applicant’s common
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`law trademark rights in the “TURN YOUR WRECK INTO A CHECK” mark. Therefore,
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`Applicant has the right to continued use of its “TURN YOUR WRECK INTO A CHECK” mark
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`in its own geographical region.
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`19.
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`Additionally, to extent Opposer did acquire any rights in Opposer’s alleged marks
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`prior to Applicant’s common law trademark rights in the “TURN YOUR WRECK INTO A
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`CHECK” mark, Applicant was without knowledge of the Opposer’s alleged prior use of any of
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`Opposer’s alleged marks.
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`SECOND AFFIRMATIVE DEFENSE
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`(Prior Use - 15 U.S.C. 1057(c))
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`Applicant is in the process of researching whether it is in possession of evidence
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`20.
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`establishing a more precise and earlier first-use date of its “TURN YOUR WRECK INTO A
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`CHECK” mark than the 2006 date claimed in its United States Trademark Application No.
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`87/699,851.
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`21.
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`To the extent evidence is uncovered in the course of discovery in this case
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`establishing that Applicant’s first-use date of its “TURN YOUR WRECK INTO A CHECK”
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`mark pre-dates the claimed first-use by Opposer of Opposer’s alleged marks, Applicant reserves
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`the right to assert as an Affirmative Defense that Applicant has superior trademark rights in its
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`“TURN YOUR WRECK INTO A CHECK” mark over Opposer through prior use of Applicant’s
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`mark.
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`THIRD AFFIRMATIVE DEFENSE
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`(No Likelihood of Confusion)
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`22.
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`During prosecution of the Applicant’s ‘851 Application, the U.S. Patent and
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`Trademark Office issued an Office Action on March 12, 2018 stating that the trademark
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`examining attorney had searched the USPTO’s database of registered and pending marks and had
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`found no similar registered marks that would bar registration under Trademark Act Section
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`2(d). TMEP §704.02; see 15 U.S.C. §1052(d).
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`23.
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`In an Office Action dated March 12, 2018, the trademark examining attorney for
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`the ‘851 Application found that United States Trademark Application Serial No. 87/663,272 for
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`the alleged mark “LET ME TURN THAT WRECK INTO A CHECK,” was a prior-filed pending
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`application that could, if allowed to register, form the basis for a refusal of registration of
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`Applicant's mark under Trademark Act Section 2(d). The Examiner indicated that, upon receipt
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`of the Response to the Office Action of March 12, 2018, action on the application was to be
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`suspended pending final disposition of the earlier-filed U.S. Trademark Application Serial No.
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`87/663,272.
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`24.
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`In a Response to Office Action dated September 12, 2018, the Applicant noted
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`that the USPTO’s online records for U.S. Trademark Application Serial No. 87/663,272 revealed
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`that an Office Action dated February 15, 2018 was issued in that application, and that no response
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`to that Office Action had been filed. Since the six-month deadline for responding to the February
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`15, 2018 Office Action had passed, United States Trademark Application Serial No. 87/663,272
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`was abandoned. Thus, United States Trademark Application Serial No. 87/663,272 was no longer
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`capable of forming a basis for a refusal of registration of Applicant's mark under Trademark Act
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`Section 2(d). Thereafter, the ‘851 Application was permitted to proceed toward allowance by the
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`examiner.
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`25.
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`The Applicant’s “TURN YOUR WRECK INTO A CHECK” mark was approved
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`for publication on the Principal Register on September 26, 2018.
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`26.
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`During the current prosecution of the “TURN YOUR WRECK INTO A CHECK”
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`before the U.S. Patent and Trademark Office, the trademark examining attorney did not find any
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`instances of likelihood of confusion between the Applicant’s mark and any other registered
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`trademarks or marks reflected in then-pending trademark applications.
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`27.
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`Applicant is unaware of any instances of actual confusion between Applicant’s
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`“TURN YOUR WRECK INTO A CHECK” mark and any of Opposer’s alleged marks. Opposer
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`has not alleged, or presented any evidence of, any actual confusion between Applicant’s “TURN
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`YOUR WRECK INTO A CHECK” mark and any of Opposer’s alleged marks.
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`28.
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`Applicant is in the process of determining whether a likelihood of confusion
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`exists between Applicant’s “TURN YOUR WRECK INTO A CHECK” mark and any of
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`Opposer’s alleged marks.
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`29.
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`To the extent the evidence uncovered in the course of discovery in this case
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`establishes that no likelihood of confusion exists between Applicant’s “TURN YOUR WRECK
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`INTO A CHECK” mark and Opposer’s alleged marks, Applicant reserves the right to assert the
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`Affirmative Defense of lack of likelihood of confusion between the Applicant’s “TURN YOUR
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`WRECK INTO A CHECK” mark and Opposer’s alleged marks.
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`FOURTH AFFIRMATIVE DEFENSE
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`(Lack of Standing)
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`30.
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`On information and belief, Opposer is not the original applicant of the ‘095
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`Application or the application leading to issuance of the ‘411 Registration.
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`31.
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`Applicant is in the process of determining whether ownership of Opposer’s
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`alleged marks was allegedly assigned to Opposer by a prior owner of the marks, and if so,
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`whether such assignment was valid and/or effective.
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`32.
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`To the extent evidence is uncovered in the course of discovery in this case
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`establishing that Opposer does not own one or more of Opposer’s alleged marks, or otherwise
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`lacks standing to oppose registration of Applicant’s “TURN YOUR WRECK INTO A CHECK”
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`mark, Applicant reserves the right to assert the Affirmative Defense of lack of standing.
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`FIFTH AFFIRMATIVE DEFENSE
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`(Invalidity/Unenforceability)
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`33.
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`On information and belief, Opposer is not the original applicant of the ‘095
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`Application or the application leading to issuance of the ‘411 Registration.
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`34.
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`Applicant is in the process of determining whether ownership of Opposer’s
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`alleged marks was allegedly assigned to Opposer by a prior owner of the marks, and if so,
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`whether such assignment was valid and/or effective.
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`35.
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`To the extent evidence is uncovered in the course of discovery in this case
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`establishing that any of the ‘411 Registration, the ‘793 Registration, or the ‘095 Application is
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`invalid and/or unenforceable, Applicant reserves the right to assert the Affirmative Defense of
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`invalidity and/or unenforceability.
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`SIXTH AFFIRMATIVE DEFENSE
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`(Laches)
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`36.
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`As and for a separate Affirmative Defense, the Applicant asserts that this
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`Opposition proceeding is barred by the doctrine of laches.
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`37.
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`On information and belief, Opposer knew of Applicant’s use of its “TURN
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`YOUR WRECK INTO A CHECK” mark long before the filing of the Notice of Opposition in
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`this case and failed to take any action to address any alleged harm that would result from
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`Applicant’s continued use of its “TURN YOUR WRECK INTO A CHECK” mark.
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`38.
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`On information and belief, Opposer unreasonably delayed in contacting Applicant
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`concerning Applicant’s use of its “TURN YOUR WRECK INTO A CHECK” mark and any
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`alleged harm Applicant’s use of its “TURN YOUR WRECK INTO A CHECK” mark would
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`cause Opposer.
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`SEVENTH AFFIRMATIVE DEFENSE
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`(Estoppel)
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`39.
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`As and for a separate Affirmative Defense, the Applicant asserts that this
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`Opposition proceeding is barred by the doctrine of estoppel.
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`40.
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`On information and belief, Opposer knew of Applicant’s use of its “TURN
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`YOUR WRECK INTO A CHECK” mark long before the filing of the Notice of Opposition in
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`this case and failed to take any action to address any alleged harm that would result from
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`Applicant’s continued use of its “TURN YOUR WRECK INTO A CHECK” mark.
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`41.
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`On information and belief, Opposer allowed Applicant to continue to use of its
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`“TURN YOUR WRECK INTO A CHECK” mark without objection.
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`42.
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`It is unequitable for Opposer to now object to Applicant’s continued use of its
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`“TURN YOUR WRECK INTO A CHECK” mark.
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`EIGHTH AFFIRMATIVE DEFENSE
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`(Unclean Hands)
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`43. As and for a separate Affirmative Defense, the Applicant asserts that this
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`Opposition proceeding is barred by the doctrine of unclean hands.
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`44.
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`On information and belief, Opposer knew of Applicant’s use of its “TURN
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`YOUR WRECK INTO A CHECK” mark long before the filing of the Notice of Opposition in
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`this case and failed to take any action to address any alleged harm that would result from
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`Applicant’s continued use of its “TURN YOUR WRECK INTO A CHECK” mark.
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`45.
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`On information and belief, Opposer allowed Applicant to continue to use of its
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`“TURN YOUR WRECK INTO A CHECK” mark without objection.
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`46.
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`It is unequitable for Opposer to now object to Applicant’s continued use of its
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`“TURN YOUR WRECK INTO A CHECK” mark.
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`NINTH AFFIRMATIVE DEFENSE
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`(Acquiescence)
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`47.
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`As and for a separate Affirmative Defense, the Applicant asserts that this
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`Opposition proceeding is barred by the doctrine of acquiescence.
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`48.
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`On information and belief, Opposer knew of Applicant’s use of its “TURN
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`YOUR WRECK INTO A CHECK” mark long before the filing of the Notice of Opposition in
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`this case and failed to take any action to address any alleged harm that would result from
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`Applicant’s continued use of its “TURN YOUR WRECK INTO A CHECK” mark.
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`49.
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`On information and belief, Opposer allowed Applicant to continue to use of its
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`“TURN YOUR WRECK INTO A CHECK” mark without objection, thereby acquiescing to
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`Applicant’s continued use of its “TURN YOUR WRECK INTO A CHECK” mark.
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`50.
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`It is unequitable for Opposer to now object to Applicant’s continued use of its
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`“TURN YOUR WRECK INTO A CHECK” mark.
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`PRAYER FOR RELIEF
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`Applicant respectfully requests that Opposition No. 91246089 be dismissed with
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`prejudice, and that Applicant’s Application No. 87/699,851 for its trademark “TURN YOUR
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`WRECK INTO A CHECK” be allowed to proceed to registration.
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`PITTS & LAKE, P.C.
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`/Jacob G. Horton/_______________________
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`Robert E. Pitts (Tenn. BOPR# 01610)
`rpitts@pittslake.com
`Andrew C. Lake (Tenn. BOPR# 29952)
`alake@pittslake.com
`Jacob G. Horton (Tenn. BOPR# 25467)
`jhorton@pittslake.com
`Paul A. Forsyth (Tenn. BOPR# 26307)
`pforsyth@pittslake.com
`Raymond E. Stephens (Tenn. BOPR# 15037)
`rstephens@pittslake.com
`P.O. Box 51295
`Knoxville, Tennessee 37950-1295
`Phone: (865) 584-0105
`Fax: (865) 584-0104
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`Attorneys for Applicant
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and exact copy of the foregoing is being
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`served on Opposer’s attorney of record by e-mail to:
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`Jennifer Whitelaw
`Whitelaw Legal Group
`3838 Tamiami Trail N., Suite 310
`Naples, Florida 34103
`ttabmail@whitelawfirm.com
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`This the 11th day of March, 2019.
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`/Jacob G. Horton/_______________
`Attorney for Applicant
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`14
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