Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA1204704
`
`Filing date:
`
`04/22/2022
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding no.
`
`91247128
`
`Party
`
`Correspondence
`address
`
`Submission
`
`Filer's name
`
`Filer's email
`
`Signature
`
`Date
`
`Attachments
`
`Plaintiff
`doTERRA Holdings, LLC
`
`JAMES C. WATSON
`TRASKBRITT PC
`230 SOUTH 500 EAST
`SUITE 300
`SALT LAKE CITY, UT 84102
`UNITED STATES
`Primary email: trademark@traskbritt.com
`Secondary email(s): grbronson@traskbritt.com, cvdubois@traskbritt.com, jcwat-
`son@traskbritt.com, hdburton@traskbritt.com
`801-532-1922
`
`Testimony For Plaintiff
`
`Glenn R. Bronson
`
`grbronson@traskbritt.com, cvdubois@traskbritt.com, trademark@traskbritt.com
`
`/s/ Glenn R. Bronson
`
`04/22/2022
`
`2022-04-22 Decl of S Sorenson w Exs 1-17_Part133.pdf(5355447 bytes )
`2022-04-22 Decl of S Sorenson w Exs 1-17_Part134.pdf(6162274 bytes )
`2022-04-22 Decl of S Sorenson w Exs 1-17_Part135.pdf(6099891 bytes )
`2022-04-22 Decl of S Sorenson w Exs 1-17_Part136.pdf(4659990 bytes )
`2022-04-22 Decl of S Sorenson w Exs 1-17_Part137.pdf(4933798 bytes )
`2022-04-22 Decl of S Sorenson w Exs 1-17_Part138.pdf(5565439 bytes )
`2022-04-22 Decl of S Sorenson w Exs 1-17_Part139.pdf(2618434 bytes )
`
`

`

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`Ifyou want to see morefromInsider Picks, we're collecting emailsfor
`anupcoming newsletter, You'll be thefirst to hear about the stuffwe
`cover. Clickliere to sign up.
`
`Disclosure: This post is brought toyou by Business Insider's Insider
`Picks team. We aimto highlight products aid services you mightfind
`interesting, and ifyou biy them, we get a sinall share ofthe revenue
`fromthe salefrom our connnerce partners. Wefrequently receive
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`recommended, We operate independentlyfrom our advertising sales
`team. We welcome yourfeedback. Have somethingyou think we
`should know about? Email us at insiderpicks@businessinsider.com.
`
`Read the original article on Insider Picks. Copyright 2019, Follow Insider Picks on Twitter.
`
`MORE FROM INSIDERPICKS:
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`* Ttested out furniture from Amazon's newprivate-label brands — and the quality is
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`There’s no better wayto get readyto crush next year’s goals than with some newgear.
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`RhoneReign Short Sleeve Crew Tee
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`This timeof year, it’s getting dark before you get a chance to escape from workat night
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`Bythe time youfinish themillionth hang clean of the workoutandstill have burpees
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`Jumpropes don’t seem like a difficult piece of gear to pick out and enjoy. But a bad
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`Sea to Summit DryLite Towel
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`Corpse pose is arguablythe best part of yoga class—butlying proneafter a session of
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`This “ropeless” jump ropeis perfect for anyone whotravels and wants to keep up their
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`Nike Windrunner Jacket
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`Leaving the gym wet post-workout or post-showeris a painful experience on a cold
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`READ NEXT
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`DOT_000117
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`

`

`EXHIBIT 14
`
`Opposition No. 91247128
`
`dōTERRA HOLDINGS, LLC, Opposer v. MTMS HOLDINGS, LLC, Applicant
`
`Party Offering Exhibit: dōTERRA HOLDINGS, LLC, Opposer
`
`
`
`
`
`

`

`https://blog.fitbit.com/diy-essential-oils-stress/
`
`03/02/2022
`se fitbit
`
`STRESS
`
`OCTOBER 1, 2021
`
`Why You Should Try Aromatherapy
`Today to Help With Stress
`
`BY KELSEY MALONEY
`
`
`
`It’s no secret that aromatherapy has been on the rise in recent years and showsno sign of slowing
`down. With its self-care productslike rollerballs, diffusers, and bath bombs, it’s been getting a lot of
`buzz in the wellness world for promising quality sleep, less stress, and deeper focus.
`
`But althoughit’s officially hit the mainstream, manyarestill left wondering what exactaromainesgpy is
`DOT_003131
`
`

`

`and howit can benefit them. Keep reading to learn the ins and outs of aromatherapy, how it can help
`with daily stress, plus advice on DIY essential oils.
`
`What is aromatherapy?
`
`Although aromatherapy mayfeel like a new trend, cultures all over the world have been usingit for
`centuries. It’s an ancient practice—used by priests, who were also doctors, for magical and religious
`ceremonies. Fast forward to today, and it has evolvedinto a thriving component of herbal medicine.
`
`Aromatherapyis the therapeutic use of essential oils, which are extracts of natural compounds derived
`from aromatic plants that are highly volatile, meaning that they easily evaporate at room temperature.
`Oncethe aromatic oil is captured, it is combined with a carrier oil to produce the final product.
`
`“There are thousands ofdifferent plant compounds captured in essential oils,” says Dr. Kara Fitzgerald,
`ND. “When they enter our bodies, these volatile compounds have biological effects such as
`antioxidant, anti-inflammatory, antimicrobial, and more.”
`
`The most common wayto use essential oils is by inhalation via an oil diffuser, or “topical application of
`single or combination essential oils that have been appropriately diluted in a carrier oil,” explains Dr.
`Fitzgerald.
`
`How does aromatherapy help with stress?
`
`Several essential oils have proven beneficial effects for stress and anxiety, a popular example being
`lavender. “Lavender essential oil has some of the most robust scientific data behind it,” says Dr.
`Fitzgerald. “One particular type of lavender essential oil preparation called Silexan™ has been shown
`in multiple human studies to significantly reduce anxiety.”
`
`Aromasare intricately connected to our emotions through olfaction (our sense of smell) by direct neural
`pathways to emotional processing centers in our brains. In addition, essential oils do more than just
`offer an aroma. “Someof the ways that we know lavender exerts its effects are by gently toning down
`the activity of a particularly stimulatory neuron receptor called the NMDA receptor,” says Dr. Fitzgerald.
`“This helps turn down any over-stimulation of the nervous system.”
`
`It also supports healthy serotonin levels, the neurotransmitter responsible for a calm, stable mood, as
`well as feelings of well-being and happiness. It does this via the same mechanism of several anti-
`anxiety medications—by slowing how quickly the body eliminates serotonin, explains Dr. Fitzgerald.
`
`DIY aromatherapyfor stress relief
`
`Interested in making your ownessential oils? You’re in the right place. Along with lavender, other
`essential oils that are knownto help with stress include rosemary, cedarwood, and German
`chamomile.
`
`DOT_003132
`DOT_003132
`
`

`

`TwoofDr. Fitzgerald’s go-to aromatherapyrecipes include:
`
`1. Adding 4 drops of lavender essential oil, 2 drops of German chamomile, and 2 drops of rosemary
`essential oils to a diffuser.
`2. Adding 8 drops each of lavender and cedarwood essential oils to 6 tablespoons of a carrier oil like
`jojoba for an effective, relaxing massage oil.
`
`If interested, you can even make your ownessential oils from plants by usingastill or oil press.
`However, there are plenty of ready-made oils available in shops or online. “Remember that purity and
`authenticity matter hugely—the market for essential oils isn’t well regulated and many products
`(especially cheaper ones) can be adulterated or synthetic,” says Dr. Fitzgerald, which is why she
`recommends doing some basic due diligence on the companythat’s selling the essential oil.
`
`“Ask about their raw material sources, as well as how they test for purity and potency,” she says. “It’s
`through this process that | have come to trust certain brands such as Young Living and DoTerra.”
`
`The takeaway? If used correctly, aromatherapy can be hugely beneficial to your daily stress and
`anxiety levels.
`
`This information is for educational purposes only andis not intended as a substitute for medical
`diagnosis or treatment. You should not use this information to diagnose or treat a health problem or
`condition. Always check with your doctor before changing yourdiet, altering your sleep habits, taking
`supplements, or starting a new fitness routine.
`
`KELSEY MALONEY
`
`
`
`A New Jersey native, Kelsey Maloneyis an Associate Editor at Fitbit currentlyliving
`out her California dream in San Francisco. After receiving her Bachelorof Art's
`degreein Journalism, she backpackedfor a year to several countries around the
`world, including to her favorite city - Cape Town, South Africa. She then made the
`leap to the West Coast to pursue her writing and editing career, formerly at Sunset
`Magazine. Kelsey is a travel and hot yoga enthusiast with an adoration for live
`music, the great outdoors, Annie’s macaroni and cheese and a goodIPA.
`
`SEARCH
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`DOT_003134
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`

`EXHIBIT 15
`
`Opposition No. 91247128
`
`dōTERRA HOLDINGS, LLC, Opposer v. MTMS HOLDINGS, LLC, Applicant
`
`Party Offering Exhibit: dōTERRA HOLDINGS, LLC, Opposer
`
`
`
`
`
`
`
`

`

`Q search oursite
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`home / media / direct selling dominates the aromatherapy and essential oils market
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`y
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`;
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`3
`
`WB Direct Sales (63%)
`
`| Others (37%)
`
`_
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`Consumers needio ieel and smell Ine ois. aie
`
`Major market participants, including dO|ERRAand
`YoungLiving, are hedgingtheir betsin Asia,
`specificallu, China, Japan, Taiwan, Hong Kong,
`singapore and Malausia
`
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`Over $7.5 billion
`
`Over$4 billion
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`Aromatherapy and Essential Oils
`Market
`
`February 3, 2016 Press Release
`
`market potential and increasing adoption rates
`
`san Antonio, 1X- Verify Markets’ analysis of
`
`the Aromatherapy and Essential Oils Market
`
`showsthat the global market was valued at
`
`over $7.5 billion in 2015 . Fueled by
`
`exponential growth in the United States,
`
`companies are nowrealizing the global
`
`reg dso
`
`bocea au Fe
`
`bere
`
`nl
`
`in the Asian markets. Major market participants, including dOTERRA and Young Living, are
`
`hedging their bets in Asia, specifically, China, Japan, Taiwan, Hong Kong, Singapore and
`
`Malaysia. This growth strategy will pay off in dividends as key players are planning for
`
`market sat