Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA1121447
`
`Filing date:
`
`03/18/2021
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91251090
`
`Party
`
`Correspondence
`Address
`
`Plaintiff
`Transamerica Corporation
`
`BRUCE A MCDONALD
`SMITH GAMBRELL & RUSSELL LLP
`1055 THOMAS JEFFERSON ST NW #400
`WASHINGTON, DC 20007
`UNITED STATES
`Primary Email: bmcdonald@sgrlaw.com
`202-263-4362
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Attachments
`
`Other Motions/Submissions
`
`Bruce A. McDonald
`
`bmcdonald@sgrlaw.com
`
`/Bruce A. McDonald/
`
`03/18/2021
`
`2021.03.18 Notice of Pending Civil Action.pdf(33568 bytes )
`transamerica.pdf(3395215 bytes )
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`TRANSAMERICA CORPORATION,
`
`Opposer,
`
`v.
`
`CARL RAYMOND AMOS,
`
`Applicant.
`
`:
`:
`:
`:
`:
`:
`:
`:
`:
`
`Opposition No. 91251090
`U.S. Intent-to-Use App. 88232718
`JWAHMOSE GLASS SKYSCRAPER
`FINE OZ & Design
`
`NOTICE OF PENDING CIVIL ACTION
`
`The Board is hereby advised that Mr. Amos filed a civil action on March 17, 2021, styled
`
`Amos v. Aegon Netherlands Transamerica, No. 1:21-cv-00326-LO-IDD (E.D.Va.) (copy of
`
`complaint attached).
`
`Date: March 18, 2021
`
`Respectfully submitted,
`
`TRANSAMERICA CORPORATION
`
`by:
`
`_______________________________________________
`Bruce A. McDonald
`SMITH, GAMBRELL & RUSSELL, LLP
`1055 Thomas Jefferson St., Suite 400
`Washington, D.C. 20007
`Tel.:
`(202) 263-4362
`Email: bmcdonald@sgrlaw.com
`
`

`

`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on March 18, 2021, a copy of the foregoing
`
`NOTICE OF PENDING CIVIL ACTION was sent by email to Applicant at his address of
`
`record:
`
`Mr. Carl Raymond Amos
`8710 W. Hillsborough Ave., Suite 413
`Tampa, FL 33615
`ahmose_inc@hotmail.com
`
`_________________________________________________
`Bruce A. McDonald
`Attorney
`SMITH, GAMBRELL & RUSSELL, LLP
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 1 of 30 PageID# 1
`[P
`L
`
`In the United States Federal Court for the
`
`;
`
`Eastern District of Virginia
`
`Alexandria Division
`
`Carl Ra^otl9^Alrfe;
`
`ALLXniiUi^ir\. n
`Plaintiff (Applicant)
`
`Vs
`
`Case No.
`
`Aegon Netherlands TransAmerica
`
`(Aegon et. al., Aegon-TransAmerica)
`
`Defendants (Opposer)
`
`I MAR 1 7 2021 J
`
`CLERK, U.S. DISTRICT COURT
`ALEXANDRIA, VIRGINIA
`
`® HAtfV P 3: 51
`
`COURT
`ViRGii^'iA
`
`Motion for Change of Venue
`
`Plaintiff sues and prays for a Change of Venue and relief and denial of Defendants (Opposer) Dutch
`
`insurance giant Aegon Netherlands TransAmerica et. al. Opposition Class (042), to Amos' Trademark
`
`application, "Jwahmose Glass Skyscraper" (Jwahmose), serial number 88232718, Class (014), Doctrine of
`
`Unclean hands, Deception, Misrepresentation, Misdirection and Conspiracy to Defraud (See Appendix I,
`
`Exhibits C and D; See Appendices il and III).
`
`1. Plaintiff assert his right to practice his Federal Registered Architectural Works Copyrights by
`
`manufacturing souvenir coins featuring his trademark and other intellectual property using silver,
`
`gold, platinum, and other metals (precious or otherwise); there has been a Force Majeure silver and
`
`shortage or scarcity along with manipulated silver price suppression.
`
`2. Plaintiff Carl R. Amos asserts his rights to be able to practice his intellectual property, be it in coins
`
`or other lawful business practice, freely without interference and opposition as the owner of:
`
`• Registered Architectural Works Copyrights, Jwahmose Glass Skyscraper: Straight and Bent
`
`Pyramidal, Registration number: VAu0013336377, Date of creation 1994, and
`
`inn)
`
`• Patents currently in force.
`
`3. Defendant and Opposer's actions are spurious, reckless, inexplicable and suspicious Aegnon
`
`Netherlands recently sold its TransAmerica building, class (042), located In San Francisco, California.
`
`The true benefactor of Defendants Predatory actions are the de facto owners of the London Shard in
`
`the City of London, England, the Qatar State Bank, the British Crown and Plagiarist Architect Renzo
`
`Piano. Suspiciously none of de facto owners have dared to come forward publicly in support of
`
`Defendant Aegon-TransAmerica's Opposition campaign, instead their hands remain hidden, as
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 2 of 30 PageID# 2
`
`proxy and secret agent Aegon TransAmerica fraud, misrepresentation ^misdirection and deception
`
`seeks to block and destroy Plaintiffs Trademark Application.
`
`4. Defendant Aegon et. al. through stealth and misrepresentation is attempting to defend and to
`
`appease and protect theft, of their true lords and masters and ultimate benefactor Qatar State Bank
`
`et. al.
`
`5. Plaintiff Carl R. Amos has been robbed and swindled out of over $6 billion USD. The Silver, Gold, and
`
`precious metal Trademark applications class (014), conceived and created by Plaintiff Carl R. Amos
`
`potential market value are worth multiple billions.
`
`6. Plaintiff asks US Federal Court to look into already adjudicated and denied claims and spurious
`
`campaign of Defendant Aegon-TransAmerica et.al. (see Appendices I and II)
`
`7. Plaintiff requests quash and dismiss Defendants Opposition due to doctrine of Unclean hands.
`
`8. Further Defendant Opposition has deceived TTAAB and is currently using TTAAB, as platform to
`
`continue his Denied Opposition and campaign of misrepresentation acting as predator and parasite,
`
`secret agent/proxy for Qatar, the State Bank of Qatar, and powerful British Crown, United Kingdom.
`
`9. Plaintiff accusation has factual basis, the real players Qatar State Bank owners of the London Shard
`
`and British United Kingdom, plagiarist Architect Renzo Piano etal. refuse to step forward publicly
`
`and through collusion and international conspiracy and stealth, has inserted and now positioned
`
`apparently as subcontractor and legal defense Dutch giant Aegon Netherlands TransAmerica to
`
`defend its $ 6 billion theft of Plaintiffs Amos Registered 1994 Architectural Works Copyrights by
`
`naked deception.
`
`10. London Shard (Jwahmose) is now the tallest building in Europe, (see Appendix II).
`
`11. Prior to Brexit, the UK had to obey EU and WlPO law regarding intellectual property. Post Brexit,
`
`they have sovereign immunity and no obligation to follow any EU or WlPO laws.
`
`12. Aegon TransAmerica denied once, has been given a Mulligan and new platform in previous venue to
`
`re-adjudicate, infinite litigation, double jeopardy clause applies as further defense for Plaintiff right
`
`to not be subjected to endless repeated and duplicate litigation.
`
`13. Plaintiff Amos is owner of the Registered Architectural Works Copyrights for the London Shard, see
`
`Exhibit A, awarded by US Copyright Office to Amos, and the USPTO issued patents currently in force.
`
`Amos famous 'Mark' is shown in the Dec 6,1999, National Science Foundation exhibit as Carl Amos
`
`Exhibit of Glass Building, Exhibit B,
`
`www.ncsa,illinois.edu/People/tcoffin/ACCESS/Amos/Amos09.html. Amos' non-monetary silver,
`
`gold, and other precious metal coin trademark is class 014, whereas the Opposer's class is 042. The
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 3 of 30 PageID# 3
`
`London Shard is verbatim theft, plagiarism, copyright infringement, and patent infringement; a
`
`structure built without Amos' knowledge or permission from 2009-2012 in London, Brittan, UK.
`
`Amos has losses, exceed 6 billion USD that benefits the Qatar State Bank and United Kingdom.
`
`14. See Appendix I, the December 22,2020, Opposition No.91251090, Transamerica Corporation vs. Carl
`
`Amos. Before Wellington, Shaw, and Lebow, Administrative Trademark Judges. By the Board:
`
`We find a genuine dispute of material fact remains as to the similarity of the marks for
`
`purposes of likelihood of confusion and dilution. Additionally, we note that Opposer does
`
`not argue how its goods or services are related to Applicant's non-monetary coins or point
`
`to evidence for purposes of demonstrating a relationship. As to the failure to function claim,
`
`a genuine dispute remains as to the extent and manner in which Applicant is currently using
`
`his mark on the goods. In its brief, Opposer argues Applicant's "expressed intent is to use
`
`the claimed mark not as a trademark but to designate his ownership of the architectural
`
`design of the London Shard." However, on the summary judgment record before us, we find
`
`a genuine dispute of material fact remains with respect to Applicant's intent in using his
`
`mark. Moreover, we cannot conclude that, based on such use identified by Opposer,
`
`consumers will not perceive the mark as a source-identifier for the identified goods,
`
`including non-monetary coins. Accordingly, Opposer's motion for summary judgment on its
`
`claims of priority and likelihood of confusion, dilution, and failure to function is denied.
`
`15. The proper venue for Registered Architectural Works Copyrights and its related Trademark and in
`
`force Patents, is in Federal Court for the Eastern District of Virginia.
`
`In conclusion the Plaintiff and Applicant Carl R. Amos, in consideration of the antecedent and Supra, is
`
`suing and further requests a Change of Venue to and before, the United States Federal Court the
`
`Eastern District of Virginia, Alexandria Division .
`
`Respertfully submitted,
`
`by.
`
`Carl R. Amos
`
`Date
`
`03/14/2021
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 4 of 30 PageID# 4
`
`Appendix I
`
`UNITED STATES PATENT AND TRADEMARK OFFICE:
`
`Trademark Trial and Appeal Board
`
`P.O. Box 1451 Alexandria, VA 22313-1451
`
`General Contact Number: 571-272-8500
`General Email: TTABInfo@uspto.gov
`
`Carl Raymond Amos (Carl R. Amos)
`
`Applicant
`
`vs.
`
`Opposition no. 91251090
`
`TransAmerica,
`
`Aegon Netherlands et.al.
`
`Opposer
`
`Amended Motion for Chance of Venue
`
`February 18,2021 update: Applicant received erratic call from Opposer Bruce McDonald, counsel
`
`TransAmerica, Aegon Netherlands et.al. and Opposer has agreed to Litigate in US Federal Court
`
`for the Eastern District of Virginia Rocket Docket.
`
`Also Opposer further threatened Motions. However, he is not afraid to litigate case in US Federal
`
`Court.
`
`The Applicant requests a change of venue to move from the TTAB to United States Federal Circuit
`
`Court before the Eastern District of Alexandria, Virginia. Further, the Applicant Amos requests the
`
`move due to the Adjudicated and Denied Opposition case No. 91251090.
`
`Reasons for Transfer are:
`
`Lack of Proper Venue.
`
`Registered Architectural Works Copyrights Patents are prohibited defenses.
`
`Not in TTAB prevue: and beyond its statute and scope and authority.
`
`Grande Fishing Expeditions are generally not tolerated in Rocket Docket.
`
`Doctrine of unclean hands.
`
`Opposer's actions are reckless mysterious and suspicious.
`
`True Benefactors of Opposer's actions are Qatar State Bank et.al and Great Britain (UK).
`
`Amos is owner of Registered Architectural Works Copyrights for London Shard, Exhibit A,
`
`awarded by USA Copyright Office to Amos and issued patents currently in force.
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 5 of 30 PageID# 5
`
`Appendix I
`
`• Amos famous 'Mark' is shown in the Dec 6, 1999, National Science Foundation exhibit as
`
`Car! Amos Exhibit of Glass Building, Exhibit B,
`
`www.ncsa.illinois.edu/People/tcoffin/ACCESS/Amos/Amos09.htm I.
`
`• Amos* non-monetary silver and gold precious metal coin trademark is Class 014 whereas
`
`the Opposer's class is 042.
`
`• London Shard verbatim copyright infringement, theft & patent infringement structure built
`
`without Amos' knowledge or permission from 2009-2012 in London, Britain, UK.
`
`• Amos has losses exceed 6 billion USD that benefits the Qatar State Bank & United
`
`Kingdom.
`
`• The proper venue for Registered Architectural Works Copyrights and its related Trademark
`
`and in force Patents, is in Federal Court for the Eastern District of Virginia.
`
`• December 22,2020 Opposition No.91251090 Transamerica Corporation vs. Carl Amos.
`
`Before Wellington, Shaw, and Lebow.
`
`Before Wellington, Shaw, and Lebow, Administrative Trademark Judges. By the Board:
`
`We find a genuine dispute of material fact remains as to the similarity of the marks for
`purposes of likelihood of confusion and dilution. Additionally, we note that Opposer
`does not argue how its goods or services are related to Applicant's non-monetary
`coins or point to evidence for purposes of demonstrating a relationship. As to the
`failure to function claim, a genuine dispute remains as to the extent and manner in
`which Applicant is currently using his mark on the goods. In its brief, Opposer argues
`
`Applicant's "expressed intent is to use the claimed mark not as a trademark but to
`
`designate his ownership of the architectural design of the London Shard." However,
`on the summary judgment record before us, we find a genuine dispute of material fact
`
`remains with respect to Applicant's intent in using his mark. Moreover, we cannot
`
`conclude that, based on such use identified by Opposer, consumers wiil not perceive
`
`the mark as a source-identifier for the identified goods, including non-monetary coins.
`Accordingly, Opposer's motion for summary judgment on its claims of priority and
`
`likelihood of confusion, dilution, and failure to function is denied.
`
`Respectfully submitted,
`
`by_ OrKAl, (\niw0
`
`Carl R. Amos
`
`Date
`
`02/18/2021
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 6 of 30 PageID# 6
`
`Appendix I
`
`Exhibit A
`
`e
`
` 0 fi h?:i5ii//(:()a5atogJocgov/qii--biri/Pw<:br«:otu;y'i^l-27&!i-iivr/i^?«)r(;h Ar<j--Atp'i5 C.arl&h-
`
`Search Request; Left Anchored N'ame = Amos Carl
`Search Resuhs:Displa>-ing 27 of 37 entries
`
`U[ipravkHis|J next ^ j
`
`Jwahmose Glass Skyscraper: Slraight and Bent I^-ramidaL
`
`Type o^^^'ork:
`
`Visual Nmienal
`
`Repstration Nomber / Date:
`
`VAu001336377'2018-01-26
`
`Application Tftle:
`
`Jtvahmose Glass Skv'scraper; Straight and Bent PytamidaL
`
`Title:
`
`Jtvafamose Glass Skyscraper: Straight and Bent PvTamidal
`
`Description:
`
`Electronic file (eSen-ice)
`
`Copyright Claimant:
`
`Carl Raymond Amos, 1958-. Address: S710 W. Hillsborough As'e. =m3, Tampa, FL, 33615.
`
`Date of Creation:
`
`1994
`
`Alternative Title on Application:
`
`Jwahmose
`
`Authorship on Application:
`
`Carl Raymond Amos. 1958-; Citizenship: L%ited Stares. Authorship; architectural work.
`
`Jrvahmose Bent PvTamid Glass Building
`
`Previous Registration:
`
`2001, VAu 000526764.
`
`1994, VAu 518745.
`
`Pre-existing Material:
`
`photograph, architectural work, sculpture,
`
`Basis of Claim:
`
`revised architectural woric.
`
`Rights and Permissions:
`
`Carl Raymond Amos, 8710 W. Hillsboroi^ Ave. «M13, Tampa, FL, 33615, United States, (813) 5254974, ahmose_mcghonnail.com
`
`Copj'right Note:
`
`C.O. correspot^ence.
`
`Names:
`
`Amos. Carl Ravtnond. 1958-
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 7 of 30 PageID# 7
`
`Appendix II
`
`Motion for Summary Judgment against Ooposer Aegon Netherlands &TransAmerica et.al MSJ
`
`10 pgs
`
`

`

`Appendix II
`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 8 of 30 PageID# 8
`
`Exhibit D
`
`THE UNITED STATES
`
`DEPARTMENT^ JUSTICE
`
`ARCHIVES
`
`Home »Justice Manual » Criminal Resource Manual » CRM 500-999 » Criminal Resource Manual 901-999
`
`923.18 U.S.C. § 371—Conspiracy to Defraud the United States
`
`The general conspiracy statute, 18 U.S.C. § 371, creates an offense "[i]f two or more persons conspire
`
`either to commit any offense against the United States, or to defraud the United States, or any agency
`thereof in any manner or for any purpose, (emphasis added). See Project, Tenth Annual Survey of White
`Collar Crime, 32 Am. Crim. L. Rev. 137, 379-406 (199S)(generally discussing § 371).
`
`The operative language Is the so-called "defraud clause," that prohibits conspiracies to defraud the United
`States. This clause creates a separate offense from the "offense clause" in Section 371. Both offenses
`require the traditional elements of Section 371 conspiracy, including an illegal agreement, criminal intent,
`
`and proof of an overt act.
`
`Although this language Is very broad, cases rely heavily on the definition of "defraud" provided by the
`
`Supreme Court in two early cases. Mass v. Henkel, 216 U.S. 462 (1910), and Hammerschmidt v. United
`
`States, 265 U.S. 182 (1924). In Mass the Court stated:
`
`The statute is broad enough in its terms to include any conspiracy for the purpose of
`
`impairing, obstructing or defeating the lawful function of any department of government...
`(A)ny conspiracy which is calculated to obstruct or impair its efficiency and destroy the value
`of its operation and reports as fair, impartial and reasonably accurate, would be to defraud
`the United States by depriving it of its lawful right and duty of promulgating or diffusing the
`information so officially acquired in the way and at the time required by law or departmental
`regulation.
`
`Mass, 216 U.S. at 479-480. In Hammerschmidt, Chief Justice Taft, defined "defraud" as follows:
`
`To conspire to defraud the United States means primarily to cheat the Government out of
`
`property or money, but it also means to interfere with or obstruct one of its lawful
`governmental functions by deceit, craft or trickery, or at least by means that are dishonest. It
`is not necessary that the Government shall be subjected to property or pecuniary loss by the
`fraud, but only that its legitimate official action and purpose shall be defeated by
`misrepresentation, chicane or the overreaching of those charged with carrying out the
`
`governmental intention.
`
`Hammerschmidt, 265 U.S. at 188.
`
`The general purpose of this part of the statute is to protect governmental functions from frustration and
`distortion through deceptive practices. Section 371 reaches "any conspiracy for the purpose of impairing,
`obstructing or defeating the lawful function of any department of Government." Tanner v. United States,
`483 U.S. 107,128 (1987); see Dennis v. United States, 384 U.S. 855 (1966). The "defraud part of section 371
`
`

`

`Appendix II
`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 9 of 30 PageID# 9
`
`criminalizes any willful impairment of a legitimate function of government, whether or not the improper
`acts or objective are criminal under another statute." United States v. Tuohey, 867 F.2d 534,537 (9th Cir.
`
`1989).
`
`The word "defraud" in Section 371 not only reaches financial or property loss through use of a scheme or
`artifice to defraud but also is designed and intended to protect the integrity of the United States and its
`agencies, programs and policies. United States v. Burgin, 621 F.2d 1352,1356 (5th dr.), cert, denied, 449
`U.S. 1015 (1980); see United States v. Herron, 825 F.2d 50, 57-58 (5th dr.); United States v. Winkle, 587
`F.2d 705,708 (5th dr. 1979), cert, denied, 444 U.S. 827 (1979). Thus, proof that the United States has been
`defrauded under this statute does not require any showing of monetary or proprietary loss. United States v.
`Conover, 772 F.2d 765 (11th dr. 1985), affd, sub. nom. Tanner v. United States, 483 U.S. 107 (1987);
`United States v. Del Toro, 513 F.2d 656 (2d dr.), cert, denied, 423 U.S. 826 (1975); United States v. Jacobs,
`475 F.2d 270 (2d dr.), cert, denied, 414 U.S. 821 (1973).
`
`Thus, if the defendant and others have engaged in dishonest practices in connection with a program
`administered by an agency of the Government, it constitutes a fraud on the United States under Section
`
`371. United States v. Gallup, 812 F.2d 1271,1276 (10th dr. 1987); Conover, 772 F.2d at 771. In United
`States V. Hopkins, 916 F.2d 207 (5th dr. 1990), the defendants' actions in disguising contributions were
`designed to evade the Federal Election Commission's reporting requirements and constituted fraud on the
`
`agency under Section 371.
`
`The intent required for a conspiracy to defraud the government Is that the defendant possessed the Intent
`(a) to defraud, (b) to make false statements or representations to the government or its agencies in order
`to obtain property of the government, or that the defendant performed acts or made statements that
`he/she knew to be false, fraudulent or deceitful to a government agency, which disrupted the functions of
`the agency or of the government. It Is sufficient for the government to prove that the defendant knew the
`
`statements were false or fraudulent when made. The government Is not required to prove the statements
`ultimately resulted in any actual loss to the government of any property or funds, only that the defendant's
`
`activities impeded or interfered with legitimate governmental functions. See United States v. Puerto, 730
`F.2d 627 (11th dr.), cert, denied, 469 U.S. 847 (1984); United States v. Tuohey, 867 F.2d 534 (9th Cir. 1989);
`United States v. Sprecher, 783 F. Supp. 133,156 (S.D.N.Y. 1992)(A%it is sufficient that the defendant
`engaged in acts that interfered with or obstructed a lawful governmental function by deceit, craft, trickery
`or by means that were dishonest"), modified on other grounds, 988 F.2d 318 (2d Cir. 1993).
`
`In United States v. Madeoy, 912 F.2d 1486 (D.C. Cir. 1990), cert, denied, 498 U.S. 1105 (1991), the
`
`defendants were convicted of conspiracy to defraud the government and other offenses in connection with
`a scheme to fraudulently obtain loan commitments from the Federal Housing Administration (FHA) or
`Veterans Administration (VA). The court held that the district court had properly instructed the jury that:
`
`the Government must prove beyond a reasonable doubt the existence of a scheme or artifice
`to defraud, with the objective either of defrauding the FHA or the VA of their lawful right to
`conduct their business and affairs free from deceit, fraud or misrepresentation, or of obtaining
`money and property from the FHA by means of false and fraudulent representations and
`
`promises which the defendant knew to be false.
`
`Madeoy, 912 F.2d at 1492.
`
`Prosecutors considering charges under the defraud prong of Section 371, and the offense prong of Section
`371 should be aware of United States v. Minarik, 875 F.2d 1186 (6th Cir. 1989) holding limited, 985 F.2d 962
`(1993), and related cases. See United States v. Arch Trading Company, 987 F.2d 1087 (4th Cir. 1993). In
`Minarik, the prosecution was found to have "used the defraud clause in a way that created great confusion
`about the conduct claimed to be illegal," and the conviction was reversed. 875 F.2d at 1196. After Minarik,
`
`

`

`Appendix II
`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 10 of 30 PageID# 10
`
`defendants have frequently challenged indictments charging violations of both clauses, although many
`United States Courts of Appeals have found it permissible to invoke both clauses of Section 371. Arch
`Trading Company, 987 F.2d at 1092 (collecting cases); see also United States v. Licciardi, 30 F.3d 1127,
`1132-33 (9th CIr. 1994)(even though the defendant may have impaired a government agency's functions, as
`part of a scheme to defraud another party, the government offered no evidence that the defendant
`intended to defraud the United States and a conspiracy to violate an agency regulatory scheme could not
`
`lie on such facts).
`
`In summary, those activities which courts have held defraud the United States under 18 U.S.C. § 371 affect
`
`the government in at least one of three ways:
`
`[cited in JM 9-42.001]
`
`They cheat the government out of money or property;
`
`They interfere or obstruct legitimate Government activity; or
`
`They make wrongful use of a governmental instrumentality.
`
`Updated January 21,2020
`
`10
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 11 of 30 PageID# 11
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`Before the Trademark Trial and Appeal Board
`
`Carl Raymond Amos )
`(Carl R. Amos) )
`) Opposition Serial No. 91234318
`Defendant/Applicant, ) Adv. U.S. App. 88232718
`) JWAHMOSE GLASS SKYSCRAPER FINE OZ
`
`TRANSAMERICA CORPORATION, )
`
`V.
`
`)
`
`) )
`
`Plaintiff/Opposer, )
`
`)
`
`Motion for Summary Judgment against Qpposer TransAmerica & TransAmerica et.al MSJ
`
`Applicant has spoken with Interlocutory Attorney Mike Webster and understands that TTAB has
`
`Jurisdiction over all registered Trademarks. The Board is empowered to determine only the right to
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`register under 15 U.S.C. §1067,15 U.S.C. §1068,15 U.S.C. §1070, and 15 U.S.C. §1092.
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`1. In consideration that the identifications of goods in Opposer's pleaded registration and applicant's
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`involved application both are separate and have distinct Classes. Applicant Has Silver, Gold &
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`precious metal coins with image of his Registered IP Class 14. Opposer's Mark is a simple pyramid
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`building and has separate, different Class 42, located in San Francisco, California.
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`2. As noted Supra, in determining whether or not there is a likelihood of confusion, we must presume
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`that the scope of the goods encompasses all of the goods of the nature and type described, that
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`they would travel in "separate" channels of trade normal for those goods and to all classes of
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`prospective purchasers for those goods. See Canadian Imperial Bank v. Wells Fargo Bank, Supra,
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`thus, because the parties' goods are "separate and not identical in part". The Classes are different
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`and separate, and there is no similarity of marks, this is a material fact. Therefore, there is no
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`dispute of material fact and Applicant is entitled to judgment as a matter of law; see Anderson v.
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`Liberty Lobby, Inc., 477 U.S. 242, 256-57 (1986).
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`Applicant thanks US Trademarks Office for good careful diligence and assistance. USDOJ Attorney &
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`Prosecutor Laura Bach, in 2015, during interview, advised that the Applicant "must stringently monitor
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`and enforce his Intellectual Property".
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`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 12 of 30 PageID# 12
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`USPTO TTAB
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`Opposition
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`Number: 91251090
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`Filing Date: 07/20/2020
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`Status:
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`Pending
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`Status Date: 09/20/2019
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`General Contact Number: 571-272-8500
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`Interlocutory Attorney:
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`MIKE WEBSTER
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`Paralegal Name: VERONICA P WHITE
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`Defendant
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`Name:
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`Carl Raymond Amos
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`Correspondence:
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`8710 W. Hillsborough Ave, Suite 413
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`ahmoseJnc@hotmall.com
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`Phone: 813-426-9359
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`Serial #:
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`88232718
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`ADPlication File
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`Assignment
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`Application Status:
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`Opposition Pending
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`Mark:
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`JWAHMOSE GLASS SKYSCRAPER FINE OZ
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`Plaintiff
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`Name:
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`Transamerica Corporation
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`Correspondence:
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`BRUCE A MCDONALD
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`SMITH GAMBRELL & RUSSELL LLP
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`1055 THOMAS JEFFERSON ST NW #400
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`WASHINGTON, DC 20007
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`UNITED STATES
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`bmcdonaid@sgrlaw.com
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`Phone: 202-263-4362
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`Serial #:
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`73457288
`
`Assignment
`
`1370509
`
`File
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`#:
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`Application
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`Registration
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`Application Status: REGISTERED AND RENEWED
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 13 of 30 PageID# 13
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`ll
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`I.
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`Motion to enter as own counsel, Defendant Carl R. Amos
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`1. This Is a Motion to Revoke Power of Attorney from Robert Powers of McClanahan Powers.
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`Defendant requests to sever the Attorney Client relationship between the Defendant and
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`McClanahan Powers, PLLC of 8133 Leesburg Pike, Suite 130, Vienna, VA 22182.
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`2. Carl R. Amos requests that he serve and represent himself as own counsel against Plaintiff
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`TransAmerIca et. al.
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`II.
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`Motion to Dismiss Complaint Due to Lack of Standing
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`1. Motion to dismiss Complaint due to Lack of Standing third party: Qatar and United Kingdom.
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`2. The actual beneficiaries of Plaintiffs Lawsuit are the Bank of Qatar, Government of Qatar,
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`City of London, United Kingdom and the British Crown, are undisclosed third parties by
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`Plaintiff and Legal Counsel forTransAmerica.
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`3. See Lujan v. Defs. of Wildlife, 504 U.S. 555,560-61 (1992). Importantly, standing is not
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`"dispensed in gross," and, accordingly, a plaintiff must demonstrate standing for each claim
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`"he seeks to press and for each form of relief that is sought." See Davis v. FEC, 554 U.S. 724,
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`734 (2008). Moreover, when there are multiple parties to a lawsuit brought in federal court,
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`"[f]or all relief sought, there must be a litigant with standing, whether that litigant joins the
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`lawsuit as a plaintiff, a coplaintiff, or an intervenor as of right." See Town of Chester v. Laroe
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`Estates, Inc., 581 U.S. , No. 16-605, slip. op. at 6 (2017
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`III.
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`Motion to Dismiss Due to Lack of Venue and Lack of Jurisdiction
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`1. Deception and Misdirection: Plaintiff Complaint and Basic Premise lacks merit is deceptive,
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`misleading and moot.
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`2. Plaintiff TransAmerica et. al. and Counsel has managed to hide and mislead and flimflam
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`theTTAB into believing that so-called London Shard is a building residing in United States of
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`America. The London Shard is in the heart of London, England which is clearly out of the
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`TTAB's jurisdiction and the TTAB is an incorrect venue. Plaintiff refuses to inform court that
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`he is a proxy and secretly representing National Bank of Qatar et. al. (lack standing due to 3'*^
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`party) by pushing this fraudulent Complaint and Opposition upon the TTAB.
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`3. The London Shard is a building residing in a foreign country (venue) of Great Britain, UK, and
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`owned by foriegn Country and owners Qatar and Qatar National Bank.
`
`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 14 of 30 PageID# 14
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`ll
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`4. Suspicious Plaintiff TransAmerica and Counsel believe that London Shard is identical to San
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`Francisco's old TransAmerica building and somehow adversely diminishes longstanding
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`TransAmerica Trademarks,
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`5. Plaintiff TransAmerica and Counsel is clearly representing a third party, the United Kingdom
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`and
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`6. National Bank of Qatar, and through deception is alleging causation and Injury, Plaintiff
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`deceptively pretends to not represent a third party (3*^^ Party).
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`7. Plaintiff has managed to build a false scenario, that the London structure based in London
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`England
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`8. Is somehow identical to old San Francisco building located in California, USA and by
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`"Causation" would cause irreparable financial Injury to Plaintiff and his third parties.
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`9. Thereby, Plaintiff is demanding redress and remedy.
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`10. The Plaintiffs Complaint is bogus, frivolous and lacks merit.
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`11. This false premise launched by unscrupulous TransAmerica and Counsel has made Counsel
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`for TransAmerica rich, in "billable hours" and served him well financially during Global
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`Covid-19 crisis as Counsel for TransAmerica Corporation.
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`12. However, problem is the "London Shard" ONE (London Shard located in Great Britain, Does
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`not Equal ONE TransAmerica Building located in San Francisco, California USA, by any
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`Stretch!
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`13. Plaintiff TransAmerica and Counsel, is hiding the basic fact that he is a Proxy for and secretly,
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`truly representing 3^'' parties.
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`14. The so-called London Shard, does not exist in United States of America and London Shard, is
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`a Building that resides in Great Britain, the United Kingdom, City of London, Owned by bank
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`of Qatar and the State of Qatar.
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`15. PlaintiffTransAmeica and Counsel is de facto representation of a Third Party, i.e., London
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`Shard owners, the United Kingdom, Great Britain and Qatar government and National Bank
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`of Qatar owners et.al and his main agenda is to hoodwink the TTAB, the complaint launched
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`by Plaintiff Counsel and TransAmerica is spurious, a sham and has no Merit.
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`16. The true beneficiaries are the state of Qatar and National Bank of Qatar, the City of London
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`in Great Britain, a foreign country. Plaintiff TransAmerica and Counsel are perpetuating fraud
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`and lead the TTAB into believing otherwise.
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`17. Defendant kindly asks court, to demand that Plaintiff immediately brings forth its true 3'^''
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`party and true ultimate beneficiary and third party benefactor National Bank of Qatar
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`(owners of London Shard, Great Britain, the United Kingdom).
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`

`

`Case 1:21-cv-00326-LO-IDD Document 1 Filed 03/17/21 Page 15 of 30 PageID# 15
`jippsLnit-i 11
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`18. Plaintiff has not and refuses to, Register as a "Foreign Agent and proxy representative of
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`Qatar Bank & State of Qatar, the London Shard and British Crown, UK." Therefore Plaintiff
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`Lacks Standing.
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`19. Plaintiff has and is committing a fraud and sleight of hand to persuade the TTAB to believe
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`that Defendant's silver rounds, bearing his Intellectual property (IP), Registered Architectural
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`Works, created in 1991,1994-199and premiered by USA National Science Foundation in
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`1999 show by NSF and published and later quickly stolen 2009-2012 by criminal bankrupt
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`British Architects, financed by Qatar and National Bank of Qatar and coveted by British
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`Crown, is somehow equivalent to old 1976 lofty Trans America building in San Francisco, CA,
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`USA.
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`20. Plaintiff admits the Plaintiff has never litigated against Qatar National bank or Government
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`of Great Britain United Kingdom during its construction phase and completion from 2009-
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`2012. Plaintiff TransAmerica and Counsel, are ju