Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA1041195
`
`Filing date:
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`03/10/2020
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91253119
`
`Party
`
`Correspondence
`Address
`
`Submission
`
`Filer's Name
`
`Filer's email
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`Signature
`
`Date
`
`Attachments
`
`Defendant
`Vivid Robotics, Inc
`
`PRIYA SINHA CLOUTIER
`CLOUTIER ARNOLD JACOBOWITZ
`2701 1ST AVE, SUITE 200
`SEATTLE, WA 98121
`UNITED STATES
`becky@cajlawyers.com, priya@cajlaywers.com
`206-866-3230
`
`Motion to Amend/Amended Answer or Counterclaim
`
`Priya Sinha Cloutier
`
`priya@cajlawyers.com
`
`/Priya Sinha Cloutier/
`
`03/10/2020
`
`Motion_to_Amend03102020.pdf(20881 bytes )
`Picnic_File_03_10202.pdf(1131702 bytes )
`
`

`

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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE
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`TRADEMARK TRIAL AND APPEAL BOARD
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`
`
`PICKNIK, LLC
`
`Opposition No. 91253119
`
`Opposer,
`
`vs.
`
`VIVID ROBOTICS, INC.
`
` Applicant
`
`
`
`MOTION TO AMENDANSWER AND
`
`AMENDED AFFIRMATIVE DEFENSES
`
`APPLICATION SERIAL NO. 88493424
`
`MARK: PICNIC
`
`
`
` Applicant, Vivid Robotics, Inc., by and through its undersigned counsel, hereby requests the
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`TTAB for leave to rename its Answer and Counterclaims to and Answer and Amended
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`Affirmative Defenses. The Opposer has agreed to the allowing the amendment. As no answer is
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`due by the Opposer and discovery began on 03 March 2020, the Opposer has not been
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`prejudiced.
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`
`
`
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`MOTION TO AMENDANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO.
`88493424 MARK: PICNIC - 1
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`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE., STE 200
`SEATTLE, WASHINGTON 98121
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`DATED: 03 March 2020
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`Respectfully submitted,
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`Cloutier Arnold Jacobowitz PLLC
`
`
`By: /Priya Sinha Cloutier/
`Priya Sinha Cloutier, WSBA #37407
`Email: priya@cajlawyers.com
`2701 1st Ave., Ste 200
`Seattle, WA 98121
`
`MOTION TO AMENDANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO.
`88493424 MARK: PICNIC - 2
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`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE., STE 200
`SEATTLE, WASHINGTON 98121
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`CERTIFICATE OF SERVICE
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` I
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` hereby certify that on 10 March 2020, the forgoing was filed electronically with
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`the TTAB and emailed to:
`
`
`
`CAROLYN JUAREZ
`NEUGEBOREN O'DOWD PC
`1227 SPRUCE ST., STE. 200
`BOULDER, CO 80302
`UNITED STATES
`carolyn@nodiplaw.com, seneca@nodiplaw.com
`
`
`
`By: /Priya Sinha Cloutier/
`Priya Sinha Cloutier, WSBA #37407
`Email: priya@cajlawyers.com
`2701 1st Ave., Ste 200
`Seattle, WA 98121
`
`MOTION TO AMENDANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO.
`88493424 MARK: PICNIC - 3
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`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE., STE 200
`SEATTLE, WASHINGTON 98121
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE
`
`TRADEMARK TRIAL AND APPEAL BOARD
`
`PICKNIK, LLC
`
`Opposer,
`
`vs.
`
`VIVID ROBOTICS INC.
`’
`
`
`Applicant
`
`Opposition No. 912531 19
`
`ANSWER AND AMENDED
`AFFIRMATIVE DEFENSES
`
`APPLICATION SERIAL NO. 88493424
`MARK: PICNIC
`
`
`
`APPLICANT’S ANSWER T 0 NOTICE OF OPPOSITION
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`Applicant, Vivid Robotics, Inc., for its answer to the Notice of Opposition filed by PickNiK,
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`LLC against application for registration of the trademark Picnic, Serial No. 88493 424, filed June
`
`28, 2019, and published in the Official Gazette of October 29, 2019, by and through its
`
`undersigned counsel, hereby pleads and avers as follows:
`
`ANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO. 88493424 MARK:
`PICNIC — 1
`
`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE, STE 200
`SEATTLE, WASHINGTON 98121
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`Answering paragraph 1 of the Notice of Opposition, Applicant admits the allegation
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`contained therein.
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`Answering paragraph 2 of the Notice of Opposition, Applicant admits allegation
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`contained therein.
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`Answering paragraph 3 of the Notice of Opposition, Applicant denies the allegations
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`contained therein.
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`Answering paragraph 4 of the Notice of Opposition, Applicant admits the allegation
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`“PickNik is the owner of pending U.S. Trademark Application Serial No.
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`88/706,056 for PICKNIK for “Design and development of computer software for
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`robots; Design, development, and consulting services related thereto in the field of
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`robotics; Product design and development in the field of robotics; Technical support
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`services, namely, troubleshooting of computer software problems” in International
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`Class 42 (the “PICKNIK Application”), which was filed as a use-based application
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`under Section 1(a) of the Lanham Act.” Applicant denies the remainder of the
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`allegations contained therein.
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`Answering paragraph 5 of the Notice of Opposition, Applicant does not have
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the allegations.
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`Answering paragraph 6 of the Notice of Opposition, Applicant does not have
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`sufficient knowledge or information to form a belief as to the allegations contained
`
`therein and accordingly denies the allegations.
`
`ANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO. 88493424 MARK:
`PICNIC ~ 2
`
`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE, STE 200
`SEATTLE, WASHINGTON 98121
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`Answering paragraph 7 of the Notice of Opposition, Applicant does not have
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the allegations.
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`Answering paragraph 8 of the Notice of Opposition, Applicant does not have
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the allegations.
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`Answering paragraph 9 of the Notice of Opposition, Applicant denies the allegations
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`contained therein.
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`10.
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`Answering paragraph 10 of the Notice of Opposition, Applicant denies the
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`allegations contained therein.
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`11.
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`Answering paragraph 11 of the Notice of Opposition, Applicant denies the
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`allegations contained therein.
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`12.
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`Answering paragraph 12 of the Notice of Opposition, Applicant denies the
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`allegations contained therein.
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`13.
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`Answering paragraph 13 of the Notice of Opposition, Applicant denies the
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`allegations contained therein.
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`14.
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`Answering paragraph 14 of the Notice of Opposition, Applicant denies the
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`allegations contained therein.
`
`ANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO. 88493424 MARK:
`PICNIC — 3
`
`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE, STE 200
`SEATTLE, WASHINGTON 98121
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`APPLICANT’S AFFIRMATIVE DEFENSES ,
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`Vivid Robotics, Inc., by and through its undersigned counsel, and for its Affirmative
`
`Defenses against the Opposer, alleges and states as follows:
`
`1. On information and belief, Opposer is a limited liability corporation organized and
`
`existing under the State of Delaware.
`
`. Counterclaimant Vivid Robotics, Inc., is a corporation organized and existing under
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`the laws of Delaware.
`
`Opposer filed US trademark Application Serial No. 88/706,056 on November 25,
`
`2019
`
`Opposer claimed first use of “PickNik” on March 2015, and first use in commerce on
`
`October 2015.
`
`On or about September 18, 2019, Opposer published a blog post, attached hereto as
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`Exhibit A, claiming “PickNik turns 2”.
`
`. Dr. Coleman, upon information and belief is a member of PickNik LLC, and acts as its
`
`agent. Dr. Coleman indicated that he created an LLC sometime after the Amazon
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`Picking Challenge of 2015. However, provides no indication of the name or other
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`trademark associated with his 2015 LLC.
`
`Opposer’s trademark application provides no specimen of use for anything except
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`robotic consulting services or software services.
`
`ANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO. 88493424 MARK:
`PICNIC — 4
`
`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE, STE 200
`SEATTLE, WASHINGTON 98121
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`8. On its Linkedln Page, attached hereto as Exhibit C, Opposer claims to provide
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`consulting services working with open source software.
`
`9. A Google search shows that Opposer describes itself as software consultants.
`
`PickNik Robotics Software Consultants
`
`httpsflpicknikai v
`We are robotia software experts avaitable to develop. integrate. a: provide general consulting
`and training for you: robotic applications.
`Jobs . Team . Robotfcs Consulting Advanced robotics to the
`nu'
`.
`tAu‘v.‘AJn
`
`10. Opposer has provided no specimen of use for its broad US trademark applicatio
`
`except its own website.
`
`FIRST AFFIRMATIVE DEFENSE
`
`ESTOPPEL
`
`11. Applicant repeat, reallege, and incorporate by reference paragraphs 1—10, above as
`
`though fully set forth herein.
`
`12. Because Opposer does not have clean hands, its trademark must be limited to its
`
`common law rights.
`
`ANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO. 88493424 MARK:
`PICNIC ~ 5
`
`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE, STE 200
`SEATTLE, WASHINGTON 98121
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`SECOND AFFIRMATIVE DEFENSE
`
`INVALIDITY OR ENFORCEABILITY
`
`13. Counterclaimants repeat, reallege, and incorporate by reference paragraphs 1-10,
`
`above as though fully set forth herein.
`
`14. The complaint fails, in Whole or palt, because the trademark asserted against Applican
`
`in the Opposition is invalid and/or unenforceable.
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`ANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO. 88493424 MARK:
`PICNIC — 6
`
`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE., STE 200
`SEATTLE, WASHINGTON 98121
`
`
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`

`

`DATED:
`
`"?
`u
`
`{wfiléQCJ/IA (3Z3 2;?
`5‘ ”1
`
`Respectfully submitted,
`
`Cloutier Arnold Jacobowitz PLLC
`
`
`By: /Priya Sinha Cloutier/
`Priya Sinha Cloutier, WSBA #37407
`Email: priyaggcajlawyers.c0m
`2701 lSt Ave, Ste 200
`Seattle, WA 98121
`
`ANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO. 88493424 MARK:
`PICNIC — 7
`
`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE, STE 200
`SEATTLE, WASHINGTON 98121
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` s iiis ,
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`
`
`EXHIBIT A
`
`“PickNik Turns 2”
`
`I, APPLICATION SERIAL NO. 88493424 MARK: PICNIC - 8
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`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE, STE 200
`SEATTLE, WASHINGTON 98121
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`1/27/2020
`
`PickNik Turns 2 l PickNik
`
`SEPTEMBER 18. 2019
`
`PickNik Turns 2
`
`When Dr. Dave Coleman entered the Amazon Picking Challenge in 2015 on behalf
`
`of the University of Colorado at Boulder, he had no idea it would lead to him
`
`starting a successful robotics company.
`
`"We didn’t win [the Amazon Picking Challenge]. but Google offered me a job as a
`
`contractor to work on Movelt, which required | create an LLC, and then things
`
`started moving...”
`
`As he started having too many Movelt projects, Dave realized there was an
`
`opportunity in the growing robotics market for open source software. He brought
`
`on 3 co—founders to spearhead the robotics software startup.
`
`"I realized that in order to have the impact I wanted to on Movelt, I would need to
`
`have a bigger team. l couldn't take a job at traditional companies that would
`
`prevent me from still contributing to open source. Starting a company made a lot
`
`of sense"
`
`
`
`hllpszllpicknlkaIlmoveiK/ros/Zm 9/09/1fllpicknlk-tum-thml
`
`1/4
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`

`1/27/2020
`
`PickNik Turns 2 | Pickle
`
`PickNik's humble beginnings started in Dave’s basement, and now employs over a
`
`dozen PhD roboticists and robotics software engineers all over the world with its
`
`headquarters in Boulder, Colorado.
`
`Dave's passion for the open source software model has helped PickNik Robotics
`
`become lead developer and maintainer of Movelt, a key part of ROS (Robotics
`
`Operating System). Movelt is used heavily by industry, startups, academics. and
`
`graduate students alike to enable robotic arms to interact with objects and move
`
`them to new locations. Movelt is now used worldwide in hundreds of robots.
`
`including projects by NASA and many others.
`
`
`
`As the robotics industry continues to grow, PickNik continues to focus on world
`
`class robotics consulting and providing powerful robotics software.
`
`Accelerate Your Robotics Development I About 319%: Robots are complex
`
`systems that require a wide breadth of expert knowledge spanning multiple
`
`disciplines, making robotics development extremely difficult and costly. Since 2015.
`
`PickNik’s mission has been to address this technical challenge while dramatically
`
`reducing development time for advanced robotic applications. To achieve this.
`
`PickNik supports and collaborates with the worldwide open source robotics
`
`movement, providing companies with cutting edge research and barrier—free open
`
`source software.
`
`hilps:l/picknik.al/moveiUros/2019/09/18/picknlk-iUm-2.hlml
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`2/4
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`

`1/27/2020
`
`PickNik Turns 2 | PickNik
`
`PickNik is rooted with a strong background in robotics theory combined with
`
`applied software experience to provide unique solutions. Robotics companies
`
`including Google, Amazon, Kindred, and many others are partnering with PickNik to
`
`develop robotic applications to address the toughest issues through software
`
`consulting. custom development, and other initiatives. By working together, we
`
`can accomplish far more than by working alone.
`
`if you would like more information please contact Rob Coleman at
`
`mlegmpicknikai
`
`(—— Previous Post
`E_a_sy Robot Software
`
`Next Post
`MovefiWorkshgp 2019 Macau
`
`———)
`
`Latest Posts
`
`oficfiwgs 29.2.0132
`PickNik and Ranygta
`Team Up to Release
`Movelt G...
`
`stovmagmsgmg
`Movelt Style
`
`omega: :8, 2019
`Meet PickNik at
`ROSCon 2019
`
`(3‘,erng
`
`Products
`
`8ng
`
`learn
`
`Jobs
`
`PickNik is: cmnmitted to open source and (ensures that
`all relevant projects contribute a portion back to
`
`Connect
`hllps:l/picknlk.allmovelUros/Zoi9/0911Hlpicknik-lurn-Zhlml
`
`improving Movelt and ROS.
`
`3/4
`
`

`

`
`

`

`EXHIBIT B
`
`PickNik LinkedIn Page
`
`APPLICATION SERIAL NO. 88493424 MARK: PICNIC - 9
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`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 IST AVE, STE 200
`SEATTLE, WASHINGTON 98121
`
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`1/21/2020
`
`m Q Search
`
`(1) PickNik Robotics: About | Linkedin
`
`iii
`
`’5?) Q
`
`Pi Attorney Needed - 18 new personal injury law clients seeking a lawyer. View their cases nowi Ad
`
`
`
`
`
`PickNik Robotics
`industrial Automation - Boulder, CO « 420 followers
`
`Accelerate Your Robotics Development
`
`Follow
`
`See all 19 employees on Linked
`
`‘
`‘
`
`
`
`
`g
`,
`Promoted
`: Overwew
`Pi Attorney Needed
`13 new Bergen,” injury is“, diam;
`seeking a lawyer. View their cases
`new!
`‘ Aramark Knows Work Wear
`Up to 50% off, plus take $l0 off— a
`a logo for a team look for $5.99
`
`. The Movelti Motion Planning Library
`« ROS Control and Realtime Systems
`,
`~__--__ -- The Open Motion Planning Library (OMPL)
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`«- Gazebo Simulation
`é PREMIUM
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`
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`
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`
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`
`http://pici<nik.ai/
`
`+1 —(720)- 513-2221
`
`industrial Automation
`11430 employees
`19 on Linkedin (D
`
`COMCAST Get Fast lntemet + Vorce
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`EEERDS Robot Operating System
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`Headquarters
`
`Boulder, CO
`
`Type
`
`Founded
`
`Specialties
`
`Privately Held
`
`2015
`
`ROS, Moveltl, Motion Planning, Robotic Consulting,
`Project Management, Robotic Simulation, inverse
`Kinematics, CH, Movelt, Robotics Development, and
`Robotics Consulting
`
`5
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`PickNik Consulting
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`CERTIFICATE OF SERVICE
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`I hereby certify that on 10 March 2020, the forgoing was filed electronically with
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`the TTAB and emailed to:
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`CAROLYN JUAREZ
`
`NEUGEBOREN O'DOWD PC
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`1227 SPRUCE ST., STE. 200
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`BOULDER, CO 80302
`UNITED STATES
`carolyn@n0diplaw.com, seneca@110diplaw.com
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`By: /P1‘iya Sinha Cloutier/
`Priya Sinha Cloutier, WSBA #37407
`Email: priya@cajlawyers.com
`2701 lst Ave, Ste 200
`Seattle, WA 98121
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`ANSWER AND AMENDED AFFIRMATIVE DEFENSES APPLICATION SERIAL NO. 88493424 MARK:
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`CLOUTIER ARNOLD JACOBOWITZ PLLC
`2701 1ST AVE., STE 200
`SEATTLE, WASHINGTON 98121
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