Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA1093064
`11/03/2020
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`ESTTA Tracking number:
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`Filing date:
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Notice of Opposition
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`Notice is hereby given that the following party opposes registration of the indicated application.
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`Opposer Information
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`Name
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`Entity
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`Address
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`Correspondence
`information
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`Devonna W Johnson
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`Individual
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`Citizenship
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`UNITED STATES
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`671 MARAN LN SW
`MABLETON, GA 30126
`UNITED STATES
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`DEVONNA W JOHNSON
`671 MARAN LN SW
`MABLETON, GA 30126
`UNITED STATES
`Primary Email: petreligionbrand@gmail.com
`Secondary Email(s): road2judah@yahoo.com
`4044298202
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`Applicant Information
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`Application No.
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`88940177
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`Publication date
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`10/06/2020
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`Opposition Filing
`Date
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`Applicant
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`11/03/2020
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`Opposition Peri-
`od Ends
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`11/05/2020
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`COMERCIALIZADORA PETEXPRESS, SA DE CV
`PUEBLA 308 INT. 304, COL. ROMA, CUAUHTEM
`MEXICO CITY, 06700
`MEXICO
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`Goods/Services Affected by Opposition
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`Class 035. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: On-line retail store services featuringpet
`foods, pet supplements, pet beds and blankets, pet toys, pet bowls and utensils, pet jewelry and
`clothing, pet strollers, pet care products including brushes, shampoos and odor removers, backpacks
`for pets, pet diapers and bags for disposing of pet waste, pet accessories including leashes and col-
`lars; Retail storeservices featuring pet foods, pet supplements, pet beds and blankets, pet toys,pet
`bowls and utensils, pet jewelry andclothing, pet strollers, pet care products including brushes, sham-
`poos and odorremovers, backpacks for pets, pet diapers and bags for disposing of pet waste, pet ac-
`cessories including leashes and collars
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`Grounds for Opposition
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`Priority and likelihood of confusion
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`Trademark Act Section 2(d)
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`Applicant not rightful owner of mark for identified
`goods or services
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`Trademark Act Section 1
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`Attachments
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`Notice of opposition.pdf(15372 bytes )
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`Signature
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`/Devonna W Johnson/
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`Name
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`Date
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`Devonna W Johnson
`
`11/03/2020
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`
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK
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` TRIAL AND APPEAL BOARD
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`Serial Number: 88940177 for an Opposition
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`Devonna Johnson v. Opposition Number 88940177
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`
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` NOTICE OF OPPOSITION
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`Devonna Johnson-Individual
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`671 Maran Ln SW
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`Mableton, Georgia 30126
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`I, Devonna Johnson submit the following Notice of Opposition regarding Application Serial
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`Number 88940177 for the mark of PET RELIGION.
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` 1. Standing on the grounds of §2(15 U.S.C. § 1052(d) I plead,
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` Likelihood of Confusion.
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` I allege that there is a Likelihood of Confusion between my First Use/Priority of Use
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` mark and the mark contained in Application Serial No. 88940177 for use in
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`connection with selling of pet products. The name is identical in sound and meaning.
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` The goods of Applicant and myself are identical. The goods offered in connection with
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` both marks include many of the same products and create the same overall
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` commercial impression. The goods more than likely would emanate from the same
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` source. Because it is likely that consumers will believe that applicants goods originate
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` from the same source as the goods of myself, and because registration of Applicants
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` mark would cause harm or damage to the present and future growth of my expanding
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` brand I respectfully request that the Examining Attorney reconsider the pending
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` application Serial Number 88940177 and refuse registration under 2(d) of the
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` Trademark act.
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`2. Standing on the grounds of 1(15 U.S.C § 1051) 3 (a) (b) (d), I plead,
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`Priority of Use
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` am stating that I, Devonna Johnson was in use of the name PET RELIGION from
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` I
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` 2017 to present. I have Instagram, Facebook and Twitter accounts in the same
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`Name and a website purchased with the intention of future internet sales and business
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`cards purchased prior to 2020. I have customers that have purchased from me
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` regularly for 3 years. I have a small but growing fan base in the social media world. I
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`allege that the Applicant possibly knew of my business name from Instagram or other
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`social media as Applicant showed up on Instagram with the same name recently with a
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`slight addition to it. For this reason, I am requesting the refusal of above Serial Number
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`under 1(15 U.S.C § 1051) 3 (a) (b) (d) of the Trademark Act.
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