`ESTTA1111488
`02/01/2021
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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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`Granted to Date
`of previous ex-
`tension
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`Address
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`Attorney informa-
`tion
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`Agewell, LLC
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`02/03/2021
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`9292 N. MERIDIAN ST.
`SUITE 211 B
`INDIANAPOLIS, IN 46260
`UNITED STATES
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`BRADLEY M. STOHRY
`REICHEL STOHRY DEAN LLP
`212 W. 10TH ST., SUITE A-285
`INDIANAPOLIS, IN 46202
`UNITED STATES
`Primary Email: brad@rsindy.com
`Secondary Email(s): docket@rsindy.com
`317-501-2891
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`Docket Number
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`Applicant Information
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`Application No.
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`88463901
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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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`02/01/2021
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`Opposition Peri-
`od Ends
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`02/03/2021
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`Age Brain, Inc.
`6655 NORTHWEST 26TH WAY
`BOCA RATON, FL 33496
`UNITED STATES
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`Goods/Services Affected by Opposition
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`Class 035. First Use: 2016/11/01 First Use In Commerce: 2016/11/01
`All goods and services in the class are opposed, namely: Advertising services; business servicesin
`the nature of online retail store services featuring non-toxic health and beauty products
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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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`Mark Cited by Opposer as Basis for Opposition
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`U.S. Registration
`No.
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`3822185
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`Application Date
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`05/06/2002
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`
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`Registration Date
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`07/20/2010
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`Foreign Priority
`Date
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`NONE
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`Word Mark
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`Design Mark
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`Description of
`Mark
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`Goods/Services
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`AGEWELL
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`NONE
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`Class 003. First use: First Use: 2010/05/21 First Use In Commerce: 2010/05/21
`Cosmetic preparations, namely, hand creams and gels, skin, face and eye
`creams and gels
`Class 005. First use: First Use: 2010/05/21 First Use In Commerce: 2010/05/21
`Vitamins, minerals, nutritional and dietary supplements
`Class 010. First use: First Use: 2010/05/21 First Use In Commerce: 2010/05/21
`Surgical and medical apparatus and instruments, namely, electric or chemically
`activated heating pads and physical therapy equipment, namely, heat and cold
`packs for medical purposes; and hand and leg muscle exercisers for age-related
`sarcopenia
`Class 028. First use: First Use: 2010/05/21 First Use In Commerce: 2010/05/21
`Sporting goods equipment, namely, powered and manual exercise machines for
`movement of arms and legs, exercise mats
`Class 029. First use: First Use: 2010/05/21 First Use In Commerce: 2010/05/21
`Nutritional foods, namely, bars from processed vegetables
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`Attachments
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`Agewell - Notice of Opposition re AGE BRAIN LIVE SMART AGE
`WELL.pdf(128140 bytes )
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`Signature
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`/bms/
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`Name
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`Date
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`BRADLEY M. STOHRY
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`02/01/2021
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`In the matter of Trademark App. Ser. Nos. 88/463,901
`Filed on June 7, 2019
`For the mark AGE BRAIN LIVE SMART. AGE WELL.
`Published in the Official Gazette on October 6, 2020
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`Agewell, LLC,
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`Opposer,
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`Age Brain, Inc.,
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`Applicant.
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`Opposition No.:______________
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`NOTICE OF OPPOSITION
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`Agewell, LLC (“Opposer”) hereby opposes the above-referenced application to register
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`the AGE BRAIN LIVE SMART. AGE WELL. mark filed by Age Brain, Inc. (“Applicant”). The
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`grounds for opposition are as follows:
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`THE PARTIES
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`1.
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`Opposer is an Indiana limited liability company with a place of business at 9292
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`North Meridian Street, Suite 100B, Indianapolis, IN 46260.
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`2.
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`Applicant is a Florida corporation with a principal place of business at 6655
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`Northwest 26th Way, Boca Raton, FL 33496.
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`OPPOSER AND ITS USE OF THE AGEWELL MARK
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`Opposer provides a variety of goods and services related to the health field.
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`Opposer is the owner of substantial trademark rights in the AGEWELL mark.
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`Opposer owns numerous trademark registrations for the AGEWELL mark, most
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`3.
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`4.
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`5.
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`notably, U.S. Registration No. 3,822,185 (the “AGEWELL Registration”). The AGEWELL
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`Registration covers cosmetic preparations, vitamins, nutritional supplements, and nutritional
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`foods, among other goods.
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`6.
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`Opposer has been using the AGEWELL mark to promote its products and
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`services since 1992. Since that time, Opposer has established extensive and valuable goodwill in
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`the AGEWELL mark and has spent significant amounts of time and money establishing this
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`goodwill.
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`7.
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`The AGEWELL mark has come to indicate and stand for the high-quality goods
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`and services offered by Opposer.
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`8.
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`As a result of Opposer’s use of the AGEWELL mark, the AGEWELL mark has
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`become valuable property of Opposer.
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`GROUNDS FOR AND REJECTING APPLICANT’S TRADEMARK APPLICATION
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`9.
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`Trademark App. Ser. No. 88/463,901 (the “Application”) was filed by Applicant
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`for the AGE BRAIN LIVE SMART. AGE WELL. mark on June 7, 2019.
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`10.
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`The Application is an intent-to-use application and covers “retail store services
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`featuring non-toxic health and beauty products.”
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`11.
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`Opposer’s actual, continuous, and continuing use of the AGEWELL Mark in
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`commerce began long before Applicant filed its Application and/or began using the AGE
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`BRAIN LIVE SMART. AGE WELL. mark.
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`12.
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`13.
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`The AGEWELL Registration predates the Application by over a decade.
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`Applicant’s use and registration of the AGE BRAIN LIVE SMART. AGE
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`WELL. mark for the services listed in the Application is likely to cause confusion, mistake,
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`and/or lead to deception as to the origin of Applicant’s services in violation of Sections 32 and
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`43(a) of the Lanham Act, 15 U.S.C. §§1114 and 1125(a).
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`Page 2
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`14.
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`The likelihood of confusion is apparent in this instance because: (a) the AGE
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`BRAIN LIVE SMART. AGE WELL. mark contains the entirety of the AGEWELL mark; and
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`(b) Opposer’s “retail store services featuring non-toxic health and beauty products” would
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`feature products such as those described in the Registration.
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`15.
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`Applicant’s use and registration of the AGE BRAIN LIVE SMART. AGE
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`WELL. mark is likely to result in confusion and substantial damage and injury to Opposer.
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`Persons familiar with Opposer’s AGEWELL mark are likely to believe that Applicant’s services
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`originate with, or are licensed, sponsored or approved by Opposer. Any such confusion would
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`inevitably result in loss of sales to Opposer, and/or damage the goodwill and reputation that
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`Opposer has established in the AGEWELL mark.
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`WHEREFORE, Opposer prays that the Application be rejected.
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`Dated this 1st day of February, 2021.
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`Respectfully submitted,
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`/Bradley M. Stohry/
`Bradley M. Stohry
`REICHEL STOHRY DEAN LLP
`212 West 10th Street
`Suite A-285
`Indianapolis, Indiana 46202
`(317) 423-8820
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`By:
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`Attorney for Agewell, LLC
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`Page 3
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