`ESTTA1114192
`02/12/2021
`
`ESTTA Tracking number:
`
`Filing date:
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Notice of Opposition
`
`Notice is hereby given that the following party opposes registration of the indicated application.
`
`Opposer Information
`
`Name
`
`Leaf Trading, LLC
`
`Granted to Date
`of previous ex-
`tension
`
`Address
`
`Attorney informa-
`tion
`
`02/17/2021
`
`4717 PLANO PARKWAY
`SUITE 150
`CARROLLTON, TX 75010
`UNITED STATES
`
`DANIELLE COMANDUCCI
`SMITH, GAMBRELL & RUSSELL, LLP
`1301 AVENUE OF THE AMERICAS
`21ST FLOOR
`NEW YORK, NY 10019
`UNITED STATES
`Primary Email: dcomanducci@sgrlaw.com
`Secondary Email(s): jsebastian@sgrlaw.com, krowe@sgrlaw.com, mbed-
`sole@sgrlaw.com, docketing@sgrlaw.com, khennessey@sgrlaw.com
`646-887-9522
`
`Docket Number
`
`Applicant Information
`
`Application No.
`
`88924610
`
`Publication date
`
`10/20/2020
`
`Opposition Filing
`Date
`
`Applicant
`
`02/12/2021
`
`Opposition Peri-
`od Ends
`
`02/17/2021
`
`Critical Role LLC
`2025 NORTH LINCOLN STREET
`BURBANK, CA 91504
`UNITED STATES
`
`Goods/Services Affected by Opposition
`
`Class 009. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Audio and video recordings featuring televi-
`sion programs, television series, documentaries, comedy, interviews, storytelling, animation, personal
`biographies, and musical performances; digital media,namely, audio, video, text, animation, and
`graphical content in the nature of pre-recorded video cassettes, digital video discs, digital versatile
`discs, downloadable audio and video recordings, DVDs, and high definition digital discs featuring
`television programs, television series, documentaries, comedy, interviews,storytelling, animation, per-
`sonal biographies, and musical; downloadable multimedia content in the nature of pre-recorded video
`cassettes, digital video discs,digital versatile discs, downloadable audio and video recordings, DVDs,
`and high definition digital discs, namely, audio, video, text, animation, and graphicalcontent, down-
`
`
`
`loadable via a global computer network and wireless devices featuring television programs, television
`series, documentaries, comedy, interviews, storytelling, animation, personal biographies and musical
`performances via a global computer network and wireless devices; downloadable podcasts in the
`field of fantasy, role playing, games, animation and fiction
`
`Class 016. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Printed publications, namely, books in the
`fields of fantasy, fiction, animatedcartoons and role playing games; printed publications, namely,
`magazines and printed periodicals in the field of role playing, fantasy, and animation;
`posters;stickers; decals; bumper stickers; postcards; trading cards other than for games; note cards;
`sketch books; comic books; greeting cards; lithographs; newsletters about fantasy, role playing,
`games, animation and fiction ; journals in the field of fantasy, role playing, games, animation and fic-
`tion; manuals in the field of fantasy, role playing, games, animation and fiction; book covers;
`folders;loose-leaf and ring binders; notebooks;art and craft clay, paint and paper kits; pens; pencils;
`paperweights; pictures; wrapping paper
`
`Class 025. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Clothing, namely, shirts, t-shirts, sweat-
`shirts, hooded sweatshirts, underwear,one-piece garments for babies, camisoles, pants, shorts,
`bandanas, pullovers, pants, scarves; headwear; hats; caps being headwear; outerwear, namely,
`coats, hats, gloves; footwear; socks; shirts; shorts; sweatshirts; pullovers; pants; scarves; cosplay
`costumes; costumes for use in role-playing games
`
`Class 028. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Toys, namely, action figures and accessor-
`ies therefore, dolls, modeled plastic toy figurines, puppets, board games, decorative ornaments,
`namely, Christmas tree ornaments, plush toys, playing cards, toy balloons, toy and scale model
`vehicles, scale model toy kits, theatrical masks, trading cards for games, dice, cups for dice
`
`Class 038. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Streaming of audio and video content via a
`global computer network; telecommunication services, namely, transmission oftelevision, radio, film,
`and multimediacontent via wireless, radio, satellite,cable and global computer networks; providing on-
`line forums for fantasy, role playing, games, animation and fiction; providing on-line chatrooms for so-
`cial networking; video-on-demand transmission services; streaming of video material over the internet
`
`Class 041. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Publishing of books, e-books and audio
`books; online publication of electronic books and journals; production of radio and television pro-
`grams; scriptwriting, other than for advertising purposes; television and radio entertainment,
`namely,continuing television and radio shows featuring fantasy, role playing, games, animation and
`fiction; providing films and television programs, not downloadable,via video-on-demand services;
`theatre productions; film directing, production and distribution, other than for advertising; entertain-
`ment services, namely, providing an ongoing audio and visual program in the nature of digital and
`multimedia programs with audio and video content, featuring comedy, unscripted, variety,fantasy,
`and talk show elements, that is broadcast, live or recorded, via a global computer network, satellite,
`cable, television, radio, and to mobile devices
`
`Grounds for Opposition
`
`Priority and likelihood of confusion
`
`Trademark Act Section 2(d)
`
`Mark Cited by Opposer as Basis for Opposition
`
`U.S. Application
`No.
`
`90030433
`
`Application Date
`
`07/01/2020
`
`Registration Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`LEAF
`
`Description of
`
`NONE
`
`Foreign Priority
`Date
`
`NONE
`
`
`
`Mark
`
`Goods/Services
`
`Class 016. First use: First Use: 1990/06/28 First Use In Commerce: 1990/06/28
`Collectible trading cards; Sports trading cards
`
`Attachments
`
`Leaf Trading LLC- Notice of Opposition - MOLLYMAUK TEALEAF.pdf(2609769
`bytes )
`
`Signature
`
`/Danielle Comanducci/
`
`Name
`
`Date
`
`Danielle Comanducci
`
`02/12/2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`TRADEMARK
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`In the Matter of Application Serial No. 88/924,610 of MOLLYMAUK TEALEAF
`Published: October 20, 2020
`
`
`LEAF TRADING, LLC,
`
`
`
`
`
`
`
`
`Opposer,
`
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`
`CRITICAL ROLE LLC,
`
`
`
`
`
`
`
`
`
`Applicant.
`
`
`
`Opposition No. ___________
`
`
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`NOTICE OF OPPOSITION
`
`
`
`
`
`Opposer Leaf Trading, LLC (“Opposer”) is a limited liability company organized and
`
`existing under the laws of the State of Delaware, with a principal place of business at 4717 Plano
`
`Parkway, Suite 150, Carrollton, Texas 75010. Opposer believes that it will be damaged by
`
`registration of the mark MOLLYMAUK TEALEAF, which is the subject matter of Application
`
`Serial No. 88/924,610, filed by Applicant Critical Role LLC (“Applicant”), a limited liability
`
`company organized and existing under the laws of the State of California, with a principal place
`
`of business at 2025 North Lincoln Street, Burbank, California 91504, and hereby opposes
`
`registration of same.
`
`The grounds for opposition are as follows:
`
`1.
`
`Opposer is the owner of the mark LEAF for collectible trading cards and sports
`
`trading cards.
`
`
`
`1" = "1" "SGR/24199955.1" "" SGR/24199955.1
`
`
`
`2.
`
`Since at least as early as June 28, 1990, Opposer, itself and through its predecessors-
`
`in-interest, has been using the LEAF mark in commerce for its collectible trading cards and sports
`
`trading cards (collectively, the “LEAF Goods”). A true and correct screengrab taken on February
`
`1, 2021, from Opposer’s https://leaftradingcards.com/ website showing use of the LEAF mark in
`
`connection with the LEAF Goods is attached as Exhibit A and made part of the record.
`
`3.
`
`In addition, since least as early as February 2012, Opposer, itself and through its
`
`predecessors-in-interest, has engaged in a variety of services relating to trading cards, including,
`
`but not limited to, authentication and grading services, providing authentication and grading
`
`documents and certifications, promoting trading card events, providing fan and sports information,
`
`and hosting fantasy sports leagues and related services (collectively, the “LEAF Services”). A true
`
`and correct screengrab taken on February 1, 2021, from Petitioner’s https://leaftradingcards.com/
`
`website showing use of the LEAF mark in connection with the Leaf Services is attached as Exhibit
`
`B and made part of the record.
`
`4.
`
`Opposer is the owner of U.S. Application Serial No. 90/030,433 of the LEAF mark
`
`for “Collectible trading cards; Sports trading cards” in International Class 016. A current printout
`
`of information from the electronic database records of the United States Patent and Trademark
`
`Office (“USPTO”) showing the current status and title of such application is attached as Exhibit C
`
`and are made part of the record.
`
`5.
`
`Opposer promotes its LEAF brand and the LEAF Goods and the LEAF Services
`
`through various advertising channels, including but not limited to, Opposer’s website
`
`https://leaftradingcards.com. See Exhibits A and B.
`
`6.
`
`In addition, Opposer also markets and sells the LEAF Goods and the LEAF
`
`Services through numerous trading card dealers located in the United States and around the world.
`
`A
`
`true
`
`and
`
`correct printout
`
`taken on February 1, 2021,
`
`from Petitioner’s
`
`2
`
`1" = "1" "SGR/24199955.1" "" SGR/24199955.1
`
`
`
`https://leaftradingcards.com/ website showing a list of trading card dealers under the heading
`
`“Where To Buy Leaf Trading Card Products” is attached as Exhibit D and made part of the record.
`
`7.
`
`Opposer also uses its LEAF mark to promote Opposer’s goods and services on
`
`social media, including Facebook and Twitter. True and correct screengrabs of selected pages
`
`from Opposer’s LEAF Facebook and Twitter pages, taken on February 1, 2021, showing use of
`
`the LEAF mark for Opposer’s goods and services is attached as Exhibit E and are made part of the
`
`record.
`
`8.
`
`Opposer’s LEAF mark is symbolic of the extensive goodwill and consumer
`
`recognition built up by Opposer through substantial amounts of time and effort in advertising and
`
`promotion.
`
`9.
`
`Notwithstanding Opposer’s rights in and to its LEAF mark, on May 20, 2020,
`
`Applicant filed an application to register the mark MOLLYMAUK TEALEAF for, inter alia,
`
`“trading cards other than for games” in International Class 016 and “trading cards for games” in
`
`International Class 028 (“Applicant’s Goods”) under an intent to use basis.
`
`10.
`
`Applicant’s application to register the mark MOLLYMAUK TEALEAF was
`
`assigned Serial No. 88/924,610, and the application was published for opposition on October 20,
`
`2020.
`
`11.
`
`Current printouts of information from the electronic database records of the USPTO
`
`showing the current status and title of Applicant’s Application Serial No. 88/924,610 for the
`
`MOLLYMAUK TEALEAF mark are attached as Exhibit F.
`
`12.
`
`Opposer’s date of first use of its LEAF mark of June 28, 1990 is prior to Applicant’s
`
`application filing date of May 20, 2020. Therefore, Petitioner has priority of use over Applicant’s
`
`Application Serial No. 88/924,610.
`
`3
`
`1" = "1" "SGR/24199955.1" "" SGR/24199955.1
`
`
`
`13.
`
`The mark MOLLYMAUK TEALEAF, when used in connection with Applicant’s
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`Goods, is confusingly similar to Opposer’s LEAF mark.
`
`14.
`
`Customers who purchase Applicant’s MOLLYMAUK TEALEAF brand trading
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`cards are likely to be confused, mistaken or deceived as to the source of such goods. Applicant’s
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`MOLLYMAUK TEALEAF mark, when used in association with the Applicant’s Goods, is likely
`
`to cause confusion, mistake or deception when compared to Opposer’s LEAF mark.
`
`15.
`
`Applicant’s MOLLYMAUK TEALEAF mark and Opposer’s LEAF mark are
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`confusingly similar and have the same connotation and commercial impression.
`
`16.
`
`Applicant’s MOLLYMAUK TEALEAF mark and Opposer’s LEAF mark are
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`similar in sound, meaning and appearance such that when Applicant’s MOLLYMAUK TEALEAF
`
`mark is used on goods identical and/or closely related to trading cards and related services there is
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`a likelihood of confusion, mistake or deception.
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`17.
`
`Applicant’s MOLLYMAUK TEALEAF brand trading cards and Opposer’s LEAF
`
`brand trading cards and related services are identical and/or closely related so that there is a
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`likelihood of confusion, mistake or deception when Applicant’s MOLLYMAUK TEALEAF mark
`
`and Opposer’s LEAF mark are used for such trading cards and related services.
`
`18.
`
`Opposer currently uses and Applicant intends to use their respective marks in the
`
`same or similar fields of use, thereby exacerbating the likelihood of confusion regarding the marks
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`and the likelihood of confusion as to sponsorship or affiliation.
`
`19.
`
`Opposer markets its trading card goods and related services to the same types of
`
`customers as will the Applicant.
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`20.
`
`If Applicant is permitted to use and register the MOLLYMAUK TEALEAF mark
`
`for trading cards, confusion in the trade resulting in damage and injury to Opposer will be caused
`
`4
`
`1" = "1" "SGR/24199955.1" "" SGR/24199955.1
`
`
`
`and will result by reason of the confusing similarity between Applicant’s MOLLYMAUK
`
`TEALEAF mark and Opposer’s LEAF mark.
`
`21.
`
`Persons familiar with Opposer’s LEAF mark and the trading card goods and related
`
`services marketed and sold under such LEAF mark are likely to confuse Applicant’s trading cards
`
`goods as goods promoted, offered, sold or sponsored by Opposer, and such confusion will harm
`
`Opposer.
`
`22.
`
`In addition to the harm identified in the precedent paragraphs, any defect, objection
`
`or fault found with Applicant’s trading card goods or unfavorable publicity given to Applicant’s
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`MOLLYMAUK TEALEAF trading card goods would reflect badly upon and significantly injury
`
`the reputation which Opposer has established in its LEAF mark.
`
`23.
`
`In particular, the USPTO has suspended Opposer’s Application Serial No.
`
`90/030,433 to register the LEAF mark for “Collectible trading cards; Sports trading cards” in
`
`International Class 016 based on a finding that there is a likelihood of confusion between
`
`Opposer’s LEAF mark and Applicant’s MOLLYMAUK TEALEAF mark bearing U.S.
`
`Application Serial No. 88/924,610. A true and correct copy of the Office Action containing such
`
`suspension is attached as Exhibit G.
`
`24.
`
`If Applicant is permitted to use and register the mark MOLLYMAUK TEALEAF
`
`for Applicant’s trading card goods, confusion in the trade resulting in damage and injury to
`
`Opposer will be caused and will result by reason of the confusing similarity between Applicant’s
`
`MOLLYMAUK TEALEAF mark and Opposer’s LEAF mark.
`
`WHEREFORE, Opposer believes that it will be damaged by registration of Applicant’s
`
`MOLLYMAUK TEALEAF mark, and prays that its opposition to Application Serial No.
`
`88/924,610 be sustained.
`
`
`
`5
`
`1" = "1" "SGR/24199955.1" "" SGR/24199955.1
`
`
`
`
`
`
`
`This 12th day of February, 2021.
`
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`Respectfully submitted,
`
`SMITH, GAMBRELL & RUSSELL, LLP
`
`
`/s/ Danielle Comanducci
`1301 Avenue of the Americas
`21st Floor
`New York, NY 10019
`Phone: 646-887-9522
`Fax: 646-887-8154
`Email: dcomanducci@sgrlaw.com
`
`
`Attorney for Opposer Leaf Trading, LLC
`
`6
`
`1" = "1" "SGR/24199955.1" "" SGR/24199955.1
`
`
`
`EXHIBIT A
`
`
`
`URL: https://leaftradingcards.com/
`Date Accessed: February 1, 2021
`
`
`
`
`
`
`EXHIBIT B
`
`
`
`URL: https://leaftradingcards.com/
`Date Accessed: February 1, 2021
`
`
`
`
`
`
`EXHIBIT C
`EXHIBIT C
`
`
`
`Generated on: This page was generated by TSDR on 2021-02-01 23:03:19 EST
`
`Mark: LEAF
`
`US Serial Number: 90030433
`
`Filed as TEAS
`Plus:
`
`Yes
`
`Register: Principal
`
`Mark Type: Trademark
`
`TM5 Common Status
`Descriptor:
`
`Application Filing
`Date:
`
`Jul. 01, 2020
`
`Currently TEAS
`Plus:
`
`Yes
`
`LIVE/APPLICATION/Under Examination
`
`The trademark application has been accepted by the Office (has met the
`minimum filing requirements) and that this application has been assigned to
`an examiner.
`
`Status: An Office action suspending further action on the application has been sent (issued) to the applicant. To view all documents in this file,
`click on the Trademark Document Retrieval link at the top of this page.
`
`Status Date: Oct. 15, 2020
`
`
`
`Mark Literal
`Elements:
`
`LEAF
`
`Mark Information
`
`Standard Character
`Claim:
`
`Mark Drawing
`Type:
`
`Yes. The mark consists of standard characters without claim to any particular font style, size, or color.
`
`4 - STANDARD CHARACTER MARK
`
`Goods and Services
`
`Note:
`The following symbols indicate that the registrant/owner has amended the goods/services:
`Brackets [..] indicate deleted goods/services;
`Double parenthesis ((..)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and
`Asterisks *..* identify additional (new) wording in the goods/services.
`
`For: Collectible trading cards; Sports trading cards
`
`International
`Class(es):
`
`016 - Primary Class
`
`Class Status: ACTIVE
`
`Basis: 1(a)
`
`U.S Class(es): 002, 005, 022, 023, 029, 037, 038, 050
`
`First Use: Jun. 28, 1990
`
`Use in Commerce: Jun. 28, 1990
`
`Basis Information (Case Level)
`
`Filed Use: Yes
`
`Filed ITU: No
`
`Filed 44D: No
`
`Filed 44E: No
`
`Filed 66A: No
`
`Filed No Basis: No
`
`Owner Name: Leaf Trading, LLC
`
`Currently Use: Yes
`
`Currently ITU: No
`
`Currently 44E: No
`
`Currently 66A: No
`
`Currently No Basis: No
`
`Current Owner(s) Information
`
`
`
`Owner Address: Suite 150
`4717 Plano Parkway
`Carrollton, TEXAS UNITED STATES 75010
`
`Legal Entity Type: LIMITED LIABILITY COMPANY
`
`State or Country
`Where Organized:
`
`DELAWARE
`
`Attorney/Correspondence Information
`
`Attorney Name: Julie A. Sebastian
`
`Attorney Primary
`Email Address:
`
`jsebastian@sgrlaw.com
`
`Correspondent
`Name/Address:
`
`JULIE A. SEBASTIAN
`SMITH, GAMBRELL & RUSSELL, LLP
`1230 PEACHTREE ST. N.E.
`PROMENADE, SUITE 3100
`ATLANTA, GEORGIA UNITED STATES 30309
`
`Attorney of Record
`
`Attorney Email
`Authorized:
`
`Yes
`
`Correspondent
`
`Phone: 404-815-3717
`
`Fax: 404-685-7017
`
`Correspondent e-
`mail:
`
`jsebastian@sgrlaw.com krowe@sgrlaw.com jaxdo
`cketing@sgrlaw.com
`
`Correspondent e-
`mail Authorized:
`
`Yes
`
`Domestic Representative - Not Found
`Prosecution History
`
`Date
`
`Description
`
`Oct. 15, 2020
`
`NOTIFICATION OF LETTER OF SUSPENSION E-MAILED
`
`Oct. 15, 2020
`
`LETTER OF SUSPENSION E-MAILED
`
`Oct. 15, 2020
`
`SUSPENSION LETTER WRITTEN
`
`Oct. 07, 2020
`
`ASSIGNED TO EXAMINER
`
`Jul. 29, 2020
`
`NEW APPLICATION OFFICE SUPPLIED DATA ENTERED IN TRAM
`
`Jul. 04, 2020
`
`NEW APPLICATION ENTERED IN TRAM
`TM Staff and Location Information
`
`TM Attorney: ARRIOLA, KIMBERLY CHEN
`
`Current Location: TMO LAW OFFICE 128 - EXAMINING
`ATTORNEY ASSIGNED
`
`TM Staff Information
`
`Law Office
`Assigned:
`
`LAW OFFICE 128
`
`File Location
`
`Date in Location: Oct. 15, 2020
`
`Proceeding
`Number
`
`6332
`
`6332
`
`92881
`
`92881
`
`
`
`EXHIBIT D
`
`
`
`URL: https://leaftradingcards.com/
`Date Accessed: February 1, 2021
`
`
`
`
`
`2/1/2021
`
`Where To Buy Leaf Trading Card Products - Leaf Trading Cards
`
`
`
`Where To Buy Leaf Trading Card Products
`
`Consumers – Where to Buy:
`
`Leaf Trading Cards Dealers
`This map was created by a user. Learn how to create your own.
`
`Map data ©2021
`Terms
`5,000 mi
`This map was created by a user. Learn how to create your own.
`
`https://leaftradingcards.com/buy-leaf-trading-card-products/
`
`1/8
`
`
`
`2/1/2021
`
`Where To Buy Leaf Trading Card Products - Leaf Trading Cards
`
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`SolarFly Cards
`Boulder
`Ultimate Sports
`Grand Junction
`Edward Skinnon
`Southington
`Kevin’s Cards
`North Haven
`Omni Comics and Cards
`Bristol
`End Zone Sports
`Milford
`Dan’s Sports Cards & Games
`Jacksonville
`Dick & Jane’s Sportscards
`Jacksonville
`Eugene Man
`Orlando
`Jacksonville Stamp & Coin
`Jacksonville
`LIVECASEBREAK, LLC
`Plantation
`
`STATE
`AK
`AL
`AZ
`AZ
`AZ
`AZ
`AZ
`AZ
`AZ
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CA
`CAN
`CO
`CO
`CO
`CO
`CO
`CO
`CO
`CT
`CT
`CT
`DE
`FL
`FL
`FL
`FL
`FL
`
`PHONE
`(907) 274-4112
`(251) 510-3915
`(310) 463-1871
`(703) 400-4471
`(623) 979-2273
`(602) 548-1254
`(520) 296-3236
`(408) 820-2226
`(480) 777-2688
`(415) 309-2489
`(818) 610-2273
`(818) 843-2600
`(209) 602-4915
`(714) 685-1865
`(916) 933-3987
`(805) 705-9722
`(661) 324-1062
`(949) 837-7830
`(650) 595-5115
`(949) 295-1624
`(408) 530-8250
`(310) 530-5818
`(408) 243-1120
`(714) 527-6319
`(714) 758-3803
`(831) 427-0670
`(818) 705-2255
`(760) 415-9699
`(604) 530-5507
`(303) 751-6882
`(303) 733-4878
`(719) 528-5959
`(719) 574-7040
`(303) 699-9808
`(330) 714-6098
`(970) 314-2092
`(860) 919-0879
`(203) 239-1074
`(860) 571-0138
`(302) 335-3935
`(904) 777-4548
`(904) 725-2316
`(407) 923-3244
`(904) 234-0191
`(954) 617-0440
`
`https://leaftradingcards.com/buy-leaf-trading-card-products/
`
`2/8
`
`
`
`2/1/2021
`
`Where To Buy Leaf Trading Card Products - Leaf Trading Cards
`
`Price Busters Games
`Heroes LLC
`Sports Legends
`AJTK Sportscards
`K-Kards
`Paula’s Sports Cards
`Sports Center
`Chucks Sports Cards Plus
`Midwest Collectables
`Ryanscardz
`The Rookie
`Jerry’s Rookie Shop
`Baseball Card Collectibles
`Bergie’s Sports Cards Dugout
`Chicagoland Sports Cards
`Diamond Cards
`Frivolous Sells
`Galaxy Stores
`Jim & Steve’s Sportscards
`Matt’s Sports Cards
`Miller’s Collector’s Corner
`Ripkings
`Super Sexy Cardboard
`Triple Crown Trading Company
`Whatnot Collectibles Shop
`Baseball Card Exchange
`Big Time Breaks
`Don’s Dugout
`Gotta Have it Collectibles
`Kam’s OTW Cards
`Snoopy 351
`Collector’s Cache, LLC
`Olivers Sportscards & Memorabilia
`R&D Collectibles
`GNT Sportscards
`Mount Sterling Baseball Cards
`Redman’s Dugout
`Sports Card & Gaming Exchange
`Jason’s Sports Cards
`Primetime Sports
`Sports Center Collectables LLC
`LJ’s Sportscards
`LTD Sports
`New England Sportscards
`P&T Sportscards
`Southeastern Sports Cards
`
`Pensacola
`Newnan
`Fayetteville
`Aiea
`Honolulu
`Honolulu
`Honolulu
`Des Moines
`Davenport
`Urbandale
`Windsor Heights
`Boise
`Shobonier
`Highland Park
`Buffalo Grove
`Quincy
`Hoffman Estates
`Naperville
`Waukegan
`Lockport
`New Baden
`Downers Grove
`Kewanee
`Naperville
`Chatham
`Indianapolis
`Lafayette
`Seymour
`Lake Station
`Evansville
`Zionsville
`lenexa
`Wichita
`Topeka
`Bowling Green
`Mount Sterling
`Glasgow
`Dry Ridge
`Baton Rouge
`Baton Rouge
`Slidell
`Southbridge
`Westport
`Pepperell
`Fairhaven
`Westport
`
`FL
`GA
`GA
`HI
`HI
`HI
`HI
`IA
`IA
`IA
`IA
`ID
`IL
`IL
`IL
`IL
`IL
`IL
`IL
`IL
`IL
`IL
`IL
`IL
`IL
`IN
`IN
`IN
`IN
`IN
`IN
`KS
`KS
`KS
`KY
`KY
`KY
`KY
`LA
`LA
`LA
`MA
`MA
`MA
`MA
`MA
`
`(850) 912-8922
`(678) 485-3861
`(678) 779-0540
`(808) 487-6620
`(808) 228-0608
`(808) 533-4886
`(808) 593-0246
`(515) 480-1077
`(563) 823-1775
`(515) 491-8403
`(515) 255-4675
`(208) 338-3828
`(618) 349-8348
`(847) 433-2250
`(847) 229-2626
`(214) 222-1556
`(847) 757-9005
`(630) 637-0187
`(847) 244-1981
`(815) 729-4292
`(618) 206-8777
`(630) 930-2626
`(309) 525-0889
`(630) 357-7707
`(217) 553-3278
`(317) 254-8681
`(765) 588-8130
`(812) 522-4909
`(219) 962-1900
`(812) 402-2231
`(217) 590-9059
`(913) 338-2273
`(316) 425-1938
`(785) 233-2510
`(270) 991-5005
`(859) 498-6582
`(270) 651-2308
`(859) 322-2341
`(225) 291-4018
`(504) 874-7878
`(504) 439-0684
`(508) 765-0533
`(774) 319-5200
`(603) 249-9061
`(781) 447-0777
`(774) 319-5200
`
`https://leaftradingcards.com/buy-leaf-trading-card-products/
`
`3/8
`
`
`
`2/1/2021
`
`Where To Buy Leaf Trading Card Products - Leaf Trading Cards
`
`All in Cards
`All Seasons Sports Cards
`Baseball Card Outlet
`Kencor
`Lou Brown Cards, Inc.
`Stadium Cards & Comics
`Med City Memorabilia
`PSA Sports Auctions
`Sideline Sports Collectibles
`Three Stars Sportscards
`Center(cid:216)eld Sports
`The Collector Store LLC
`Vettes and Cards
`D&M Sportscards
`All Things Collectible
`Bryans Sportscards
`Crane’s Cards
`EE Cards Unlimited
`Gold Buyers Jewelry Coin & Collectibles
`Greg’s Cards
`Legends Autographs
`Scott’s Toys & Collectibles
`The Hobby Box
`Dakota Gaming Supply
`Matthew Myers
`Prep 2 Pro Sports (NE-PREP)
`Wes’ Baseball Cards Inc.
`East Coast Card Connection
`Northeast Sportscards
`On Deck Baseball Cards
`Perfectly Centered
`RDC Cards
`The Baseball Card Store, Inc.
`Charlie’s Cardz
`Legacy Sports Cards
`A&S Sports
`American Legends
`BP Sportscards (NY-BPCARD)
`Chameleon Comics
`First International Health Foods
`Izzy’s Cards
`MattsBaseball.com
`MMC Sports Cards
`Never Enough Cards
`Six Eight Cards
`T. Breyer Unique, Inc.
`
`MD
`Baltimore
`MD
`Frostburg
`MD
`Baltimore
`MI
`Fenton
`MI
`Grand Rapids
`MI
`Ypsilanti
`MN
`Rochester
`MN
`Maple Grove
`MN
`Saint Cloud
`MN
`Saint Paul
`MO
`Spring(cid:216)eld
`MO
`Saint Charles
`MO
`Paci(cid:216)c
`NB
`Moncton
`NC
`Gastonia
`NC
`Charlotte
`NC
`Winston Salem
`NC
`Charlotte
`NC
`Cary
`NC
`Spruce Pine
`NC
`Clayton
`NC
`Lexington
`NC
`Wilmington
`ND
`Bismarck
`NE
`Omaha
`NE
`Norfolk
`NE
`Lincoln
`NJ
`Lyndhurst
`NJ
`Basking Ridge
`NJ
`Millville
`NJ
`Roselle Park
`NJ
`Cranford
`NJ
`Ramsey
`NM
`Albuquerque
`NV
`Las Vegas
`NY
`Westbury
`NY
`Bronxville
`NY
`Florida
`NY
`New York
`NY
`Haverstraw
`NY
`Bethpage
`NY
`Watervliet
`NY
`Baldwin
`Port Jefferson Station NY
`Tonawanda
`NY
`Southold
`NY
`
`(410) 484-5069
`(301) 689-5668
`(401) 284-7922
`(734) 699-5065
`(616) 940-8173 x104
`(734) 434-0283
`(507) 202-3470
`(763) 553-2995
`(320) 217-2116
`(651) 633-6041
`(417) 831-7675
`(636) 477-7800
`(636) 257-3486
`(506) 852-3244
`(704) 824-0010
`(704) 763-5495
`(336) 723-3420
`(703) 798-2105
`(919) 900-7388
`(828) 765-9778
`(860) 614-5834
`(336) 731-6324
`(910) 350-2858
`(701) 226-4635
`(402) 677-4210
`(402) 371-3351
`(402) 488-3775
`(204) 438-4327
`(973) 727-3741
`(856) 825-8703
`(908) 241-1112
`(908) 709-0635
`(201) 445-9007
`(505) 269-4196
`(702) 341-6525
`(516) 398-7800
`(914) 725-2225
`(845) 651-1660
`(212) 587-3411
`(845) 323-2916
`(516) 428-5702
`(800) 675-1898
`(516) 546-1571
`(631) 331-3629
`(716) 803-3323
`(631) 765-8124
`
`https://leaftradingcards.com/buy-leaf-trading-card-products/
`
`4/8
`
`
`
`2/1/2021
`
`Where To Buy Leaf Trading Card Products - Leaf Trading Cards
`
`The Bullpen
`TNT Sportscards
`ToyWiz
`All-Pro Sportscards
`Antique Cards and Cars Inc.
`Bomber Sports Cards
`Cards for Collectors
`B&B Sports Cards
`Grand Slam Sports
`Hooked On Cards Wholesale
`Matthew Wahlert
`Off the Charts
`OH-DREAMS Cardboard Dreams
`OTP Cards & Collectibles
`Over the Fence
`Ice Box Cards & Collectibles
`Card Stadium
`Cards & Sports, Inc.
`Dave’s Sports Cards
`Georgetown Card Exchange, Inc.
`Greentree Sports Cards
`Hill’s Wholesale Gaming
`Joe’s Sports Cards & Collectibles
`Juniata Cards
`Kinem’s Collectibles
`Peter Comparetto’s Cards
`SD Trading
`Sports Vault
`Sportscards Etc.
`Steele City Collectibles
`Steele City Collectibles
`WoWo Cards
`Legends Sports Cards
`Mark’s Novelties
`Marty’s Sportscard Exchange
`Sports Treasures
`The Dugout
`A&J Sportscards
`Collector’s Den
`Dllove Comics and Cards
`Empire Collectibles
`Kenny’s Collectibles of Austin
`Nick’s Sports Cards
`SATX Cards
`SMP Sportscards
`Sports Cards Plus
`
`New Windsor
`Tallman
`Suffern
`Cuyahoga Falls
`Brookville
`Pepper Pike
`Cincinnati
`Fairview Park
`Chagrin Falls
`North Ridgeville
`Cincinnati
`Cincinnati
`Akron
`Alliance
`Eastlake
`Barrie
`Harrisburg
`Media
`Erie
`Hatboro
`Pittsburgh
`Forbes Road
`Greensburg
`Altoona
`Eric
`Levittown
`Yardley
`Exton
`Mc Kees Rocks
`McKeesport
`Pittsburgh
`Erie
`Sioux Falls
`Johnson City
`Chattanooga
`Knoxville
`Sevierville
`Happy
`Wichita Falls
`Cypress
`Corpus Christi
`Austin
`Dallas
`San Antonio
`Grapevine
`San Antonio
`
`NY
`NY
`NY
`OH
`OH
`OH
`OH
`OH
`OH
`OH
`OH
`OH
`OH
`OH
`OH
`Ontario
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`PA
`SD
`TN
`TN
`TN
`TN
`TX
`TX
`TX
`TX
`TX
`TX
`TX
`TX
`TX
`
`(845) 569-3080
`(201) 390-1368
`(845) 624-1995
`(330) 922-4642
`(937) 833-4422
`(216) 245-8799
`(513) 761-0593
`(440) 777-5234
`(440) 543-2758
`(877) 704-5609
`(513) 245-2469
`(513) 403-1755
`(330) 699-2881
`(330) 356-0821
`(440) 953-2700
`(705) 739-1010
`(717) 234-0655
`(610) 566-0655
`(814) 868-0826
`(215) 675-2813
`(412) 937-0540
`(412) 610-1942
`(724) 830-0873
`(814) 944-0810
`(814) 864-2309
`(215) 785-4967
`(215) 530-4365
`(610) 344-3260 x216
`(412) 787-3235
`(412) 672-6200
`(412) 366-5858
`(814) 566-1381
`(605) 376-3112
`(423) 929-0283
`(423) 648-7037
`(865) 688-2273
`(865) 429-3373
`(541) 343-5561
`(940) 851-0777
`(713) 560-3479
`(361) 462-2924
`(512) 748-9718
`(972) 248-2271
`(210) 784-7821
`(817) 251-1752
`(210) 524-2337
`
`https://leaftradingcards.com/buy-leaf-trading-card-products/
`
`5/8
`
`
`
`2/1/2021
`
`Where To Buy Leaf Trading Card Products - Leaf Trading Cards
`
`The Old Ball Park
`Triple Cards & Collectibles
`Overtime Cards
`Blowout Cards
`Chart Toppers Sports Cards
`Collector’s Corner
`Collector’s Heaven
`Gene’s Dugout
`Heroes Sports Cards
`Pigeons Sports Cards
`Scott Sams
`The Card Cellar
`Card Exchange
`Digital Heroes
`Mad AL Distributors
`Mill Creek Sports
`The Baseball Card Shop
`Kryptonite Kollectibles
`Power Sportscards
`Sports Dome Kenosha
`Card Express
`Flash Shop
`Lanxing Card House
`Mint Company Limited
`Ricky’s Card Shop
`Shanghai Ruika Trading Co., Ltd.
`
`Alvin
`Plano
`Midvale
`Sterling
`Virginia Beach
`Sterling
`Richmond
`Arlington
`Virginia Beach
`Ashburn
`Glen Allen
`Fredericksberg
`Seattle
`Walla Walla
`Fife
`Mill Creek
`Puyallup
`Janesville
`Plymouth
`Kenosha
`China
`China
`Hong Kong
`Japan
`China
`China
`
`TX
`TX
`UT
`VA
`VA
`VA
`VA
`VA
`VA
`VA
`VA
`VA
`WA
`WA
`WA
`WA
`WA
`WI
`WI
`WI
`
`
`
`
`
`
`
`(281) 585-8800
`(972) 509-5263
`(801) 566-3100
`(703) 953-3131
`(214) 686-7364
`(703) 450-7280
`(804) 673-1127
`(703) 534-1360
`(757) 313-2694
`(803) 479-3292
`(804) 339-4426
`(540) 891-9549
`(206) 440-5466
`(509) 525-0380
`(907) 274-4115
`(425) 742-8500
`(253) 848-8662
`(608) 758-2100
`(920) 893-9661
`(262) 697-9288
`
`
`
`https://leaftradingcards.com/buy-leaf-trading-card-products/
`
`6/8
`
`
`
`2/1/2021
`
`Where To Buy Leaf Trading Card Products - Leaf Trading Cards
`
`https://leaftradingcards.com/buy-leaf-trading-card-products/
`
`7/8
`
`
`
`2/1/2021
`
`Where To Buy Leaf Trading Card Products - Leaf Trading Cards
`
`COPYRIGHT © 2021 LEAF TRADING CARDS
`
`DULCET THEME BY FRT
`
`https://leaftradingcards.com/buy-leaf-trading-card-products/
`
`8/8
`
`
`
`EXHIBIT E
`
`
`
`URL: https://www.facebook.com/Leaftradingcards/
`Date Accessed: February 1, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`URL:
`https://twitter.com/Leaf_Cards?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5Eaut
`hor
`
`Date Accessed: February 1, 2021
`
`
`
`
`
`
`
`
`EXHIBIT F
`EXHIBIT F
`
`
`
`Generated on: This page was generated by TSDR on 2021-02-02 10:10:50 EST
`
`Mark: MOLLYMAUK TEALEAF
`
`US Serial Number: 88924610
`
`Register: Principal
`
`Mark Type: Trademark, Service Mark
`
`TM5 Common Status
`Descriptor:
`
`Application Filing
`Date:
`
`May 20, 2020
`
`LIVE/APPLICATION/Published for Opposition
`
`A pending trademark application has been examined by the Office and has
`been published in a way that provides an opportunity for the public to oppose
`its registration.
`
`Status: A request for an extension of time to file an opposition has been filed with the Trademark Trial and Appeal Board. For further
`information, see TTABVUE on the Trademark Trial and Appeal Board web page.
`
`Status Date: Nov. 03, 2020
`
`Publication Date: Oct. 20, 2020
`
`
`
`Mark Literal
`Elements:
`
`MOLLYMAUK TEALEAF
`
`Mark Information
`
`Standard Character
`Claim:
`
`Mark Drawing
`Type:
`
`Name Portrait
`Consent:
`
`Yes. The mark consists of standard characters without claim to any particular font style, size, or color.
`
`4 - STANDARD CHARACTER MARK
`
`The name(s), portrait(s), and/or signature(s) shown in the mark does not identify a particular living individual.
`
`Related Properties Information
`
`International
`Registration
`Number:
`
`International
`Application(s)
`/Registration(s)
`Based on this
`Property:
`
`A0102356
`
`Goods and Services
`
`Note:
`The following symbols i

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