Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
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`ESTTA Tracking number:
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`ESTTA1171382
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`Filing date:
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`11/09/2021
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding
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`91271176
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`Party
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`Correspondence
`Address
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`Submission
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`Filer's Name
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`Filer's email
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`Defendant
`Georgia Parker
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`GEORGIA PARKER
`3315 E RUSSELL RD A4-141
`LAS VEGAS, NV 89120
`UNITED STATES
`Primary Email: tva@connect-central.com
`Secondary Email(s): worldwidebrandsolutions@gmail.com
`7028162700
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`Answer
`
`Jennifer Ko Craft
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`jcraft@dickinsonwright.com, trademarkslv@dickinsonwright.com, amor-
`etto@dickinson-wright.com
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`Signature
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`Date
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`/Jennifer Ko Craft/
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`11/09/2021
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`Attachments
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`Opp. 91271176 - BOSS LADIEZ Answer.pdf(121188 bytes )
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`
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`
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`BOSS LADY ENTERTAINMENT, INC.,
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`GEORGIA PARKER,
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`Applicant.
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`v.
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`Opposer,
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`
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`Opposition No. 91271176
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`Mark: BOSS LADIEZ
`Ser. No: 86/460420
`Published: April 27, 2021
`Class: 35, 42
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`
`
`ANSWER
`Applicant, Georgia Parker, (“Applicant”) an individual residing in Las Vegas, Nevada,
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`by and through her attorneys of record, responds to the allegations set forth in the Notice of
`Opposition filed by Boss Lady Entertainment, Inc. (“Opposer”) on August 20, 2021 as follows:
`Applicant is without information sufficient to admit or deny the allegations in
`1.
`Paragraph 1 and therefore denies the allegations therein.
`Applicant is without information sufficient to admit or deny the allegations in
`2.
`Paragraph 2 and therefore denies the allegations therein.
`Applicant admits only that Opposer is identified by the United States Patent and
`3.
`Trademark Office (“USPTO”) as the owner of Reg. No. 3,706,980 in Classes 9 and 35, which
`issued on November 3, 2009. The remaining allegations of Paragraph 3 are legal conclusions to
`which no response is required. To the extent a response is required, Applicant is without
`information sufficient to admit or deny the allegations in Paragraph 3 and therefore denies the
`allegations therein.
`Applicant admits only that Opposer is identified by the USPTO as the owner of
`4.
`Reg. No. 4,768,850 in Class 25, which issued on July 7, 2015. The remaining allegations of
`Paragraph 4 are legal conclusions to which no response is required. To the extent a response is
`required, Applicant is without information sufficient to admit or deny the allegations in
`Paragraph 4 and therefore denies the allegations therein.
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`
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`
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`Applicant admits the allegation in Paragraph 5.
`5.
`Applicant admits only that she filed the application for the Mark as an intent to
`6.
`use application. The remaining allegations of Paragraph 6 are legal conclusions to which no
`response is required. To the extent a response is required, Applicant is without information
`sufficient to admit or deny the allegations in Paragraph 6 and therefore denies the allegations
`therein.
`Applicant denies Opposer’s characterization of the similarity of the marks.
`7.
`The allegations in Paragraph 8 are legal conclusions to which no response is
`8.
`required. To the extent a response is required, Applicant is without information sufficient to
`admit or deny the allegations in Paragraph 8 and therefore denies the allegations therein.
`The allegations in Paragraph 9 are legal conclusions to which no response is
`9.
`required. To the extent a response is required, Applicant denies.
`WHEREFORE, Applicant prays the Board deny the Notice of Opposition with prejudice,
`together with whatever other relief the Board may deem appropriate.
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`Dated: November 9, 2021.
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`Respectfully submitted,
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`DICKINSON WRIGHT PLLC
`
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`_/Jennifer Ko Craft/___________
`Jennifer Ko Craft, Esq.
`jcraft@dickinsonwright.com
`trademarkslv@dickinsonwright.com
`3883 Howard Hughes Parkway, Suite 800
`Las Vegas, Nevada 89169
`(702) 550-4400 (phone)
`(844) 670-6009 (fax)
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`
`
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 9th day of November, 2021, this Answer was served via email
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`and first-class mail, postage prepaid, on counsel for Opposer at the following address:
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`Robert A. ecker
`Fross Zalnick Lehrman & Zissu, P.C.
`151 West 42nd Street, 17th Floor
`New York, NY 10036
`Email: rbecker@fzlz.com
`
`/s/ Ashley B. Moretto
`An Employee of Dickinson Wright PLLC
`
`
