Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
`ESTTA1128570
`04/21/2021
`
`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
`
`WeWork Companies LLC
`
`Granted to Date
`of previous ex-
`tension
`
`Address
`
`Attorney informa-
`tion
`
`04/21/2021
`
`115 WEST 18TH STREET
`NEW YORK, NY 10011
`UNITED STATES
`
`LAURA POPP-ROSENBERG
`FROSS ZELNICK LEHRMAN & ZISSU, P.C.
`151 W. 42ND STREET, 17TH FLOOR
`NEW YORK, NY 10036
`UNITED STATES
`Primary Email: lpopp-rosenberg@fzlz.com
`Secondary Email(s): lkittay@fzlz.com, skipen@fzlz.com, ttabfiling@fzlz.com
`2128135900
`
`Docket Number
`
`Applicant Information
`
`Application No.
`
`79293862
`
`Publication date
`
`12/22/2020
`
`Opposition Filing
`Date
`
`International Re-
`gistration No.
`
`Applicant
`
`04/21/2021
`
`1550883
`
`Interlink GmbH
`AM ANGER 3-5
`82237 W?RTHSEE
`FED REP GERMANY
`
`Opposition Peri-
`od Ends
`
`International Re-
`gistration Date
`
`04/21/2021
`
`04/29/2020
`
`Goods/Services Affected by Opposition
`
`Class 035. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Compilation of advertisements for use as
`web pages on the Internet; compilationof advertisements for use as web pages on the Internet; ad-
`vertising; online advertising; computerised business promotion; advertising and marketing; business
`promotion; advertising; advertising, marketing and promotional services; provision of information re-
`lating to advertising; analysis of advertising response; on-line advertising on a computer network; ad-
`vertising by transmission of on-line publicity for third parties through electronic communications net-
`works; consultancy relating to advertising; consultationsrelating to business advertising; collection of
`information relating to advertising; marketing studies; client businessdata analysis; assistance to
`managementin commercial enterprises in respect ofadvertising; advertising, marketing andpromotion-
`al consultancy, advisory and assistance services; presentation of goods on communication media, for
`
`

`

`retail purposes; placement of design staff; placement of staff; arranging of business introductions; ar-
`ranging of business introductions; business intermediary services relating to the matching of potential
`private investors with entrepreneurs needing funding; temporary personnel services;providing of busi-
`ness consultants and investors to start-ups and vice versa; electronic commerce services, namely,
`providing information about products via telecommunication networks for advertising and sales pur-
`poses; business management consultancy and advisory services; business consultancy to firms;
`business strategy and planning services; business consultation and management regarding market-
`ing activities; business merger consultation; business advice relating to growthfinancing; business ad-
`vice relating to marketing management consultations; business advice relating to disposals; business
`merger consulting; business consultation and management regarding launching of new products;
`business strategy services; strategic business planning; consultancy and advisory services in the
`fieldof business strategy; compilation of advertisements for use as web pages on theInternet; brand
`positioning services; brand creation services; marketing advice; advice relating to marketing manage-
`ment; marketing agency services; conductingof marketing studies; market campaigns;business plan-
`ning consultancy; advisoryservices relating to business planning;advice in the field of business man-
`agement and marketing; brand creation services, namely, advertising and promotion; administrative
`consultancy relating to the use and management of social media; business model development; sup-
`port in thepreparation of business plans; evaluation of business plans; business consultation regard-
`ing launching of new products and services; business consultancy to large companies relating to set-
`ting up innovation departments, incubators, accelerators and incubation units; business management
`of companies; business consulting; targeted matching and arranging of suitable business introduc-
`tions; linking of business contacts; consultancy relating to sales matters; none of the aforesaid ser-
`vices relating to wholesaling and online trading in the field of furniture
`
`Class 036. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Investment consultancy; investment con-
`sultancy; investment fund management; industrial funds investment; private clientfunds investment
`services; equity capital investment; personal equity plan investment; mutual fund investment; invest-
`ment fund management; investment portfoliomanagement services; establishing mutual funds for oth-
`ers; arranging of financial investments; purchase and management of business investments; rental,
`purchase and management of real estate and property; arranging letting of real estate; rental of office
`space and office workstations, coworking spaces, working cafes,restaurants, event and workshop
`premises; financing assistance; arranging of financial in startups, business investmentbrokerage
`
`Class 041. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Arranging and conducting of workshops
`and conferences in the field of finance; provision of business and people coaching services in the
`field of finance; arranging and conducting of software user training; arranging and conducting of IT
`courses; coaching of founders and entrepreneurs
`
`Class 042. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Website development services; design
`ofweb pages; design of web pages; building and maintaining websites; website development for oth-
`ers; managing the web sites of others; hosting computer sites; consultancy with regard to webpage
`design;updating websites for others; designingwebsites for advertising purposes; managing the web
`sites of others; hosting web sites; hosting web sites; building andmaintaining websites; hosting the
`computer sites, namely, web sites of others; creation and provision of web pages to and for third
`parties; designing and developing webpages on the Internet; creating and maintaining web sites for
`others; installing web pages on the Internet forothers; designing and implementing web sites for oth-
`ers; creating and designingweb pages for others; creating and maintaining computer sites, namely,
`web sites for others; design of web pages; design, creation, hosting and maintenance of websites, for
`others; software as a service [SaaS] featuring software for graphic design; hosting and rental of soft-
`ware; hosting computer sites; server hosting; hosting websites on the Internet; application service
`provider services for hosting computer software applications of others; hosting of digital content on
`the Internet; design, development, maintenance and hosting of websites for others;application service
`provider [ASP], namely, hosting computer software applications of others; hosting of digital content,
`namely, on-line journals and blogs; maintenance of websites and hosting on-line web facilities for oth-
`ers; development of computer programs; graphic design; graphic design; graphic design; com-
`puteraided graphic design; art work graphic design; graphic design for the compilation of web pages
`on the Internet; constructing an Internet platform for electronic commerce; brand design services;
`design of brand names; product development consultation; development, production of software and
`providing temporary use of online nondownloadable software for graphic design; research and devel-
`
`

`

`opment of new products; website maintenance of online profiles on social media
`
`Class 045. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Trademark agent services; trademark
`watch services; licensing of trademarks; consultancy relating to domain name registration services; li-
`censing of intellectual property, online social networking services; on-line social networking services
`
`Grounds for Opposition
`
`Priority and likelihood of confusion
`
`Trademark Act Section 2(d)
`
`Marks Cited by Opposer as Basis for Opposition
`
`U.S. Registration
`No.
`
`4453874
`
`Registration Date
`
`12/24/2013
`
`Word Mark
`
`Design Mark
`
`WEWORK
`
`Application Date
`
`03/22/2013
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 035. First use: First Use: 2010/02/00 First Use In Commerce: 2011/10/00
`Providing co-working facilities equipped with private offices, office equipment,
`mailroom, printing center, receptionist, kitchen, meeting rooms, telecommunica-
`tions equipment and other office amenities; Business information services; in-
`cubation services, namely, providing work space containing business equipment
`and other amenities to emerging, start-up andexisting companies; Business de-
`velopment services, namely, providing start-up support for businesses of others;
`providing office support services; online business networking services; Adminis-
`tering group purchasing programs and other discount programs, namely negoti-
`ating with providers of insurance, banking, credit card processing, travel and
`transportationservices, to enable participant membersof a business community
`to obtain discounts on the purchase of those services from others; computer-as-
`sisted business information and research services; assistance and advice re-
`garding business location; arranging and conducting special events, parties,
`camps, concerts and travel for business purposes
`Class 041. First use: First Use: 2010/02/00 First Use In Commerce: 2011/10/00
`Entertainment and educational services,namely, organizing, conducting and ar-
`ranging training, classes, seminars, workshops, conferences and exhibitions in
`thefields of business, technology and social networking; electronic publication
`ofblogs, brochures, magazines, and newsletters on a wide variety of topics; ar-
`ranging, organizing, conducting and hostingsocial entertainment events
`Class 042. First use: First Use: 2013/02/00 First Use In Commerce: 2013/03/22
`Computer services, namely, creating an on-line community for registered users
`to participate in discussions, get feedback from their peers, form virtual com-
`munities, and engage in business and socialnetworking; platforms for providing
`a web-based on-line portal for customers toparticipate in business and social
`
`

`

`networking, engage in virtual communities, manage membership in a co-working
`and private office facilities service, request and manage office assignments, re-
`serve conference rooms, control employees' useraccess, order printing services,
`and sign up and pay for vendor services such as catering, benefits and health
`insurance; computer services, namely, hosting on-line web facilities for others
`for organizing and conducting online introductions, meetings, gatherings and in-
`teractivediscussions; computer services, namely,interactive hosting services
`which allow the user to publish and share their own content and images, and in-
`teract with others, on-line; computer services, namely, cloud hosting provider
`services; computer services, namely, on-site and remote management of IT sys-
`tems; installation [, updating and maintenance ] of computer software; [ rental of
`web servers; ]server hosting; technical support services, namely, troubleshoot-
`ing of computersoftware problems; technical support services, namely,
`troubleshooting in the nature of diagnosing computer hardware and software
`problems
`Class 045. First use: First Use: 2013/02/00 First Use In Commerce: 2013/03/22
`Online social networking services; social networking services in the field of busi-
`ness provided via a website
`
`U.S. Registration
`No.
`
`4983663
`
`Registration Date
`
`06/21/2016
`
`Word Mark
`
`Design Mark
`
`WELIVE
`
`Application Date
`
`12/18/2013
`
`Foreign Priority
`Date
`
`10/24/2013
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 036. First use: First Use: 2016/04/04 First Use In Commerce: 2016/04/04
`Leasing of real property and apartments; Management of apartments and build-
`ings
`
`U.S. Registration
`No.
`
`5033257
`
`Registration Date
`
`08/30/2016
`
`Word Mark
`
`WELIVE
`
`Application Date
`
`04/14/2015
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 043. First use: First Use: 2016/05/27 First Use In Commerce: 2016/05/27
`Providing temporary accommodations; providing temporary housing accommod-
`ations;hotel services; online booking and reservation services for temporary
`lodging
`
`U.S. Registration
`No.
`
`5042982
`
`Registration Date
`
`09/13/2016
`
`Word Mark
`
`Design Mark
`
`WELIVE
`
`Application Date
`
`12/17/2014
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 045. First use: First Use: 2016/04/00 First Use In Commerce: 2016/04/00
`Concierge services for others comprising making requested personal arrange-
`mentsand reservations and providing customer-specific information to meet indi-
`vidualneeds rendered together in an apartmentcomplex; online social network-
`ing services; personal concierge services for others comprising making reques-
`ted personalarrangements and reservations, running errands and providing cus-
`tomer specific information to meet individual needs, all rendered in residential
`complexes
`
`U.S. Registration
`No.
`
`5119653
`
`Registration Date
`
`01/10/2017
`
`Word Mark
`
`WEWORK
`
`Application Date
`
`03/06/2013
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 038. First use: First Use: 2014/00/00 First Use In Commerce: 2014/00/00
`Digital network telecommunications services; providing multiple user wireless
`access to the Internet; Telecommunications services, namely, electronic trans-
`mission of data and digital messaging via mobile handheld devices and via
`wired and wireless communication devices; telecommunications services,
`namely, enabling users to electronically transmit messages,text, multimedia con-
`tent, videos, audio, animation and images via a global computer network; provid-
`ing online forums, chat rooms and electronic bulletin boardsfor transmission of
`messages among users in the field of general interest; video conferencing ser-
`vices; providing facilities and equipment for video and telepresence conferen-
`cing
`
`U.S. Registration
`No.
`
`5276604
`
`Registration Date
`
`08/29/2017
`
`Word Mark
`
`Design Mark
`
`WEWORK
`
`Application Date
`
`11/12/2013
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 035. First use: First Use: 2011/04/02 First Use In Commerce: 2011/04/02
`Providing on-line employment information in the field of careers, job listings,job
`resources and resumes; providing career information; business networking ser-
`vices
`
`U.S. Registration
`No.
`
`5380816
`
`Registration Date
`
`01/16/2018
`
`Word Mark
`
`WELIVE
`
`Application Date
`
`10/07/2013
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 009. First use: First Use: 2016/04/04 First Use In Commerce: 2016/04/04
`Computer application software for mobile phones and handheld computers,
`namely,software for members of a residential community to participate in social
`networking, engage in virtual communities, manage their community member-
`ship
`Class 038. First use: First Use: 2016/04/04 First Use In Commerce: 2016/04/04
`Digital network telecommunications services; providing multiple user wireless
`access to the Internet
`Class 042. First use: First Use: 2016/04/04 First Use In Commerce: 2016/04/04
`Computer services, namely, creating an on-line community for registered users
`to participate in discussions, get feedback from their peers, form virtual com-
`munities, and engage in social networking; providing a web hosting platform for
`members of a residential community to participate in social networking, engage
`in virtual communities, manage community membership; computer services,
`namely, on-site and remote management of IT systems;technical support ser-
`vices, namely, troubleshooting of computer software problems; technical support
`services, namely, troubleshooting in the nature of diagnosing computer hard-
`ware and software problems
`Class 043. First use: First Use: 2016/04/04 First Use In Commerce: 2016/04/04
`Providing community centers for social gatherings and meetings; providing of
`drink
`Class 045. First use: First Use: 2016/04/04 First Use In Commerce: 2016/04/04
`online social networking services; personal concierge services for others com-
`prising making requested personal arrangements and reservations, running er-
`rands and providing customer specific information to meet individual needs, all
`rendered in residential complexes
`
`U.S. Registration
`No.
`
`5675496
`
`Registration Date
`
`02/12/2019
`
`Word Mark
`
`WELIVE
`
`Application Date
`
`12/17/2014
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 009. First use: First Use: 2016/04/25 First Use In Commerce: 2016/04/25
`Software and downloadable software for organizing parties and events; com-
`puter application software for mobile phones and handheld computers, namely,
`software for members of a residential community to participate in social network-
`ing, engage in virtual communities
`Class 038. First use: First Use: 2016/06/21 First Use In Commerce: 2016/06/21
`Providing access to digital network telecommunications services; providing mul-
`tiple user wireless access to the Internet
`Class 042. First use: First Use: 2016/06/21 First Use In Commerce: 2016/06/21
`Technical support services, namely, troubleshooting of computer software prob-
`lems; technical support services, namely, troubleshooting in the nature of dia-
`gnosing computer hardware and software problems
`Class 043. First use: First Use: 2016/06/21 First Use In Commerce: 2016/06/21
`Online booking and reservation servicesfor temporary lodging; coffee bar ser-
`vices; providing community centers for social gatherings and meetings; provid-
`ing of drink
`
`U.S. Registration
`No.
`
`5868965
`
`Registration Date
`
`09/24/2019
`
`Word Mark
`
`WE
`
`Application Date
`
`10/12/2017
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`The mark consists of the letters "WE" inside of a circle.
`
`Class 035. First use: First Use: 2019/05/00 First Use In Commerce: 2019/05/00
`Incubation services, namely, business development services for others; incuba-
`tion services, namely, providing start-up support for businesses of others; incub-
`ation services, namely, providing business networking events; providing facilities
`for business meetings; business operation of offices and office space
`
`U.S. Registration
`No.
`
`5980652
`
`Registration Date
`
`02/11/2020
`
`Word Mark
`
`Design Mark
`
`WEWORK
`
`Application Date
`
`07/30/2018
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`The mark consists of the stylized wording "WEWORK" in lowercase letters.
`
`Class 035. First use: First Use: 2012/01/00 First Use In Commerce: 2012/01/00
`Incubation services, namely, providing work space containing business equip-
`mentand other office amenities in the nature of a receptionist, meeting rooms, a
`mailroom, printing center, kitchen, and telecommunications equipment, all for
`business purposes to emerging, start-up and existing companies; providing facil-
`itiesfor business meetings and business events; business operation of commer-
`cial real estate, offices and office space for others; providing shared office space
`containing business equipment and other office amenities in the nature of a re-
`ceptionist, meeting rooms, a mailroom, printing center, kitchen, and telecommu-
`nications equipment, all for business purposes to emerging, start-up and existing
`companies; providing coworking facilities forbusiness meeting purposes
`
`

`

`Class 036. First use: First Use: 2012/01/00 First Use In Commerce: 2012/01/00
`Real estate services, namely, leasing of office space and real estate; Rental of
`office space; rental of shared office space
`Class 043. First use: First Use: 2012/01/00 First Use In Commerce: 2012/01/00
`Providing food and beverage services; providing meeting room services in the
`nature of rental of meeting rooms and conference rooms
`
`U.S. Registration
`No.
`
`4838465
`
`Registration Date
`
`10/20/2015
`
`Word Mark
`
`Design Mark
`
`WEWORK
`
`Application Date
`
`11/12/2013
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`Attachments
`
`NONE
`
`Class 009. First use: First Use: 2013/12/20 First Use In Commerce: 2013/12/20
`Computer application software for usersto manage membership in a co-working
`facilities service, reserve conference rooms, participate in business and social
`networking, engage in virtual communities, search job listings, and sign up and
`pay for vendor services such as catering,benefits and health insurance
`
`85883629#TMSN.png( bytes )
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`85868853#TMSN.png( bytes )
`86116984#TMSN.png( bytes )
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`F4014332.PDF(150606 bytes )
`86977013#TMSN.png( bytes )
`
`Signature
`
`/Laura Popp-Rosenberg/
`
`Name
`
`Date
`
`LAURA POPP-ROSENBERG
`
`04/21/2021
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`
`WEWORK COMPANIES LLC,
`
`
`Opposer,
`
`
`
`-against-
`
`
`INTERLINK GMBH,
`
`
`Applicant.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`NOTICE OF OPPOSITION
`
`WeWork Companies LLC believes that it will be damaged by the issuance of a
`
`registration for the trademark WE INTERLINK & Design as applied for in U.S. Trademark
`
`Application Serial No. 79293862, and therefore opposes the same. As grounds for this
`
`opposition, Opposer alleges as follows:
`
`1.
`
`WeWork Companies LLC (“Opposer”) is a Delaware limited liability company
`
`with an address of 115 West 18th Street, New York, New York, 10011.
`
`2.
`
`Opposer, an acknowledged leader in the coworking industry in the United States
`
`and around the world, has provided businesses and individuals with workspace, commercial real
`
`estate, residential real estate, community, education, and related goods and services since 2010
`
`under a family of marks that includes WE, WEWORK, WELIVE, and many other WE-
`
`formatives (collectively, “Opposer’s Marks”).
`
`3.
`
`Opposer’s Marks all contain the distinctive WE term and have been used and
`
`advertised in such a manner that the public associates not only the individual marks, but the
`
`common WE term, with a single source – namely, Opposer.
`
`{F3986447.1 }
`
`
`
`

`

`4.
`
`Among Opposer’s myriad offerings are shared office space and coworking
`
`facilities (including private offices, meeting rooms, office support staff and other office
`
`amenities), real estate management services, incubation services, event hosting and
`
`entertainment services, educational and training services (including events, seminars and
`
`conferences in the fields of business and technology), business information and promotion
`
`services, group purchasing programs, online publications, and special event programming, all of
`
`which are promoted and offered under Opposer’s Marks.
`
`5.
`
`As a result of Opposer’s reputation, substantial sales success, inestimable
`
`popularity, and significant investment in advertising and promotion, Opposer’s Marks – both
`
`individually and collectively – have become well-known throughout the United States and the
`
`world. Opposer’s Marks represent enormous goodwill and are extremely valuable assets to
`
`Opposer.
`
`6.
`
`Opposer’s Marks – both individually and collectively – have become uniquely
`
`identified with Opposer and have come to identify the goods and services of Opposer
`
`exclusively.
`
`7.
`
`In addition to its strong common law trademark rights in Opposer’s Marks
`
`developed through many years of use and promotion, Opposer owns federal trademark
`
`registrations for certain of Opposer’s Marks, including but not limited to:
`
`Mark
`
`Reg. No.
`
`Reg. Date
`
`International Class(es)
`
`WEWORK
`
`WEWORK
`
`WELIVE
`
`WELIVE
`
`WELIVE
`
`WEWORK
`
`WEWORK
`
`{F3986447.1 }
`
`
`4453874
`
`4838465
`
`4983663
`
`5033257
`
`5042982
`
`5119653
`
`5276604
`
`12/24/2013
`
`35, 41, 42, 45
`
`10/20/2015
`
`6/21/2016
`
`8/30/2016
`
`9/13/2016
`
`1/10/2017
`
`8/29/2017
`
`2
`
`9
`
`36
`
`43
`
`45
`
`38
`
`35
`
`

`

`Mark
`
`Reg. No.
`
`Reg. Date
`
`International Class(es)
`
`WELIVE
`
`WELIVE
`
`5380816
`
`5675496
`
`1/16/2018
`
`9, 38, 42, 43, 45
`
`1/22/2019
`
`9, 38, 42, 43
`
`5868965
`
`9/24/2019
`
`35
`
`5980652
`
`2/11/2020
`
`35, 36, 43
`
`
`
`
`
`
`
`
`
`8.
`
`According to the online records of the United States Patent and Trademark Office
`
`(“USPTO”), Applicant Interlink GmbH (“Applicant”) is a German Gesellschaft mit beschränkter
`
`Haftung (GmbH) with an address of Am Anger 3-5, 82237 Wörthsee, Germany.
`
`9.
`
`According to the online records of the USPTO, on April 29, 2020, Applicant filed
`
`U.S. Trademark Application Serial No. 79293862 (the “Application”) to register the trademark
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`WE INTERLINK & Design, shown here:
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`(“Applicant’s Mark”).
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`10.
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`The Application was filed based on Section 66(a) of the Lanham Act as an
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`extension of international registration pursuant to 15 U.S.C. § 1141f for use in connection with
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`the following goods and services:
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` “Compilation of advertisements for use as web pages on the Internet; compilation of
`advertisements for use as web pages on the Internet; advertising; online advertising;
`computerised business promotion; advertising and marketing; business promotion;
`advertising; advertising, marketing and promotional services; provision of
`information relating to advertising; analysis of advertising response; on-line
`advertising on a computer network; advertising by transmission of on-line publicity
`for third parties through electronic communications networks; consultancy relating to
`advertising; consultations relating to business advertising; collection of information
`relating to advertising; marketing studies; client business data analysis; assistance to
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`{F3986447.1 }
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`management in commercial enterprises in respect of advertising; advertising,
`marketing and promotional consultancy, advisory and assistance services;
`presentation of goods on communication media, for retail purposes; placement of
`design staff; placement of staff; arranging of business introductions; arranging of
`business introductions; business intermediary services relating to the matching of
`potential private investors with entrepreneurs needing funding; temporary personnel
`services; providing of business consultants and investors to start-ups and vice versa;
`electronic commerce services, namely, providing information about products via
`telecommunication networks for advertising and sales purposes; business
`management consultancy and advisory services; business consultancy to firms;
`business strategy and planning services; business consultation and management
`regarding marketing activities; business merger consultation; business advice relating
`to growth financing; business advice relating to marketing management consultations;
`business advice relating to disposals; business merger consulting; business
`consultation and management regarding launching of new products; business strategy
`services; strategic business planning; consultancy and advisory services in the field of
`business strategy; compilation of advertisements for use as web pages on the Internet;
`brand positioning services; brand creation services; marketing advice; advice relating
`to marketing management; marketing agency services; conducting of marketing
`studies; market campaigns; business planning consultancy; advisory services relating
`to business planning; advice in the field of business management and marketing;
`brand creation services, namely, advertising and promotion; administrative
`consultancy relating to the use and management of social media; business model
`development; support in the preparation of business plans; evaluation of business
`plans; business consultation regarding launching of new products and services;
`business consultancy to large companies relating to setting up innovation
`departments, incubators, accelerators and incubation units; business management of
`companies; business consulting; targeted matching and arranging of suitable business
`introductions; linking of business contacts; consultancy relating to sales matters; none
`of the aforesaid services relating to wholesaling and online trading in the field of
`furniture” in International Class 35;
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` “Investment consultancy; investment consultancy; investment fund management;
`industrial funds investment; private client funds investment services; equity capital
`investment; personal equity plan investment; mutual fund investment; investment
`fund management; investment portfolio management services; establishing mutual
`funds for others; arranging of financial investments; purchase and management of
`business investments; rental, purchase and management of real estate and property;
`arranging letting of real estate; rental of office space and office workstations,
`coworking spaces, working cafes, restaurants, event and workshop premises;
`financing assistance; arranging of financial in startups, business investment
`brokerage” in International Class 36;
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` “Arranging and conducting of workshops and conferences in the field of finance;
`provision of business and people coaching services in the field of finance; arranging
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`{F3986447.1 }
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`and conducting of software user training; arranging and conducting of IT courses;
`coaching of founders and entrepreneurs” in International Class 41;
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` “Website development services; design of web pages; design of web pages; building
`and maintaining websites; website development for others; managing the web sites of
`others; hosting computer sites; consultancy with regard to webpage design; updating
`websites for others; designing websites for advertising purposes; managing the web
`sites of others; hosting web sites; hosting web sites; building and maintaining
`websites; hosting the computer sites, namely, web sites of others; creation and
`provision of web pages to and for third parties; designing and developing webpages
`on the Internet; creating and maintaining web sites for others; installing web pages on
`the Internet for others; designing and implementing web sites for others; creating and
`designing web pages for others; creating and maintaining computer sites, namely,
`web sites for others; design of web pages; design, creation, hosting and maintenance
`of websites, for others; software as a service [SaaS] featuring software for graphic
`design; hosting and rental of software; hosting computer sites; server hosting; hosting
`websites on the Internet; application service provider services for hosting computer
`software applications of others; hosting of digital content on the Internet; design,
`development, maintenance and hosting of websites for others; application service
`provider [ASP], namely, hosting computer software applications of others; hosting of
`digital content, namely, on-line journals and blogs; maintenance of websites and
`hosting on-line web facilities for others; development of computer programs; graphic
`design; graphic design; graphic design; computer aided graphic design; art work
`graphic design; graphic design for the compilation of web pages on the Internet;
`constructing an Internet platform for electronic commerce; brand design services;
`design of brand names; product development consultation; development, production
`of software and providing temporary use of online nondownloadable software for
`graphic design; research and development of new products; website maintenance of
`online profiles on social media” in International Class 42; and
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` “Trademark agent services; trademark watch services; licensing of trademarks;
`consultancy relating to domain name registration services; licensing of intellectual
`property, online social networking services; on-line social networking services” in
`International Class 45.
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`11.
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`Upon information and belief, Opposer’s rights in Opposer’s Marks, both
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`individually and collectively, are prior and superior to any rights Applicant may claim in
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`Applicant’s Mark.
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`12.
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`Applicant is not connected to Opposer in any way, and has not been authorized by
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`Opposer to use Applicant’s Mark or any mark confusingly similar thereto.
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`13.
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`Applicant’s Mark is highly similar to Opposer’s Marks – both individually and
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`collectively