throbber
Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA1178809
`
`Filing date:
`
`12/15/2021
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91272167
`
`Party
`
`Correspondence
`Address
`
`Defendant
`Emily Grace Thomas
`
`RICHARD W. HOFFMANN
`REISING ETHINGTON P.C.
`755 W. BIG BEAVER RD. SUITE 1850
`TROY, MI 48084
`UNITED STATES
`Primary Email: hoffmann@reising.com
`Secondary Email(s): docketing@reising.com, dcosta@reising.com, beck-
`er@reising.com
`2486893500
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Answer
`
`Richard W. Hoffmann
`
`hoffmann@reising.com, dcosta@reising.com, docketing@reising.com
`
`/Richard W. Hoffmann/
`
`12/15/2021
`
`Attachments
`
`91272167 Answer and Affirmative Defenses.pdf(277703 bytes )
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Opposition No. 91272167
`
`) )
`
`) Application Serial No. 79/245,112
`)
`
`) Mark:
`)
`
`) )
`
`) )
`
`OLSMAN, MACKENZIE, PEACOCK
`& WALLACE, P.C.,
`Opposer,
`
`v.
`
`EMILY GRACE THOMAS
`
`Applicant.
`
`APPLICANT EMILY GRACE THOMAS’ ANSWER AND AFFIRMATIVE DEFENSES TO
`OPPOSER OLSMAN, MACKENZIE, PEACOCK & WALLACE, P.C.’s NOTICE OF
`OPPOSITION
`
`Applicant, Emily Grace Thomas, an individual having an address at 29488 Woodward
`
`Avenue, Suite 340, Royal Oak, MI 48073 (“Applicant”), by and through her attorneys of record,
`
`Trademark Trial and Appeal Board Manual of Procedure (“TBMP”) and the Federal Rules of Civil
`
`Procedure (“Fed.R.Civ.P.”), answers Opposer, Olsman, Mackenzie, Peacock & Wallace, P.C
`
`(hereafter “Opposer” ) Notice of Opposition as follows:
`
`The grounds stated by Opposer for this Opposition are
`
` mark of Application Serial No. 90387461 (the “Opposed
`
`BIRTH JUSTICE Application”) by Applicant is likely to cause confusion, or to cause
`
`mistake or to deceive with respect to Opposer’s prior use and adoption of
`
`marks comprising BIRTH JUSTICE and
`
`10
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`

`

`
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` or (“Opposer’s BIRTH JUSTICE Mark”), on the basis of fraud for
`
`falsely misrepresenting ownership and acting with reckless disregard for the truth before the
`
`USPTO, and on the basis that Application Serial No. 90387461 is void ab initio for having been
`
`filed in the name of party not owning the mark.
`
`Applicant’s respective Answers to Opposers allegations are as follows:.
`
`
`
`1. Opposer is a law firm specializing in a variety of personal injury, neglect, police
`
`misconduct, sexual abuse, and malpractice claims, including those relating to birth injury.
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a belief
`
`as to the truth or falsity of the allegations contained in Paragraph 1 of the Notice of Opposition and
`
`therefore denies same.
`
`2. In connection with its legal practice, Opposer has used the BIRTH JUSTICE logo
`
`
`
`
`
` since at least as early as October 2018 in connection with its legal
`services (“Opposer’s Services”).
`
`11
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`

`

`
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a belief
`
`as to the truth or falsity of the allegations contained in Paragraph 2 of the Notice of Opposition and
`
`therefore denies same.
`
`
`
`
`
`
`
`
`
`3.
`
`At Opposer’s direction and expense, Opposer’s graphic designer created the
`
`logo for Opposer in August 2018, with all rights, title and interest
`
`in such logo assigned to Opposer.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the allegations of Paragraph 3 of the Notice of
`
`Opposition.
`
`4.
`
`Opposer’s US Application Serial No. 97062312 pending with the USPTO for
`
`
`
`
`
`12
`
` for legal services (“Opposer’s BIRTH JUSTICE Application”).
`
`

`

`APPLICANT’S ANSWER: Applicant admits that Opposer’s US Application Serial No.
`97062312 pending with the USPTO for the identified mark in connection with legal services.
`
`5.
`
`In connection with its birth injury legal services, Opposer uses Opposer’s BIRTH
`
`JUSTICE Mark on Opposer’s website, in social media, in promotional materials, and as a trade
`
`name. The domain name birthjustice.com previously redirected to the BIRTH JUSTICE section
`
`of Opposer’s website at www.olsmanlaw.com.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`belief as to the truth or falsity of the allegations contained in Paragraph 5 of the Notice of
`
`Opposition and therefore denies same.
`
`
`
`6.
`
`Applicant Ms. Thomas was employed by Opposer from approximately June 2018
`
`through early September 2021.
`
`
`
`APPLICANT’S ANSWER: Applicant admits the allegation of Paragraph 6 of the Notice of
`
`Opposition.
`
`
`
`
`
`
`
`7.
`
`During her employment with Opposer, Applicant participated in personal injury
`
`and medical malpractice cases, including those involving birth trauma.
`
`APPLICANT’S ANSWER: Applicant admits that she settled two birth injury cases while
`
`at Opposer’s firm, both of which originated from a prior firm and the clients followed Applicant to
`
`Opposer’s firm.
`
`8. While employed by Opposer and notwithstanding Opposer’s rights in Opposer’s
`13
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`
`
`

`

`
`
`
`
`
`
`
`
`
`
`BIRTH JUSTICE Marks, including but not limited to the
`
`logo,
`
`Applicant started a “Birth Justice” Facebook page in June 2019.
`
`
`
`APPLICANT’S ANSWER: Applicant admits the allegation of Paragraph 8 of the Notice of
`
`Opposition.
`
`9.
`
`Without regard to Opposer’s rights and while employed by Opposer, Applicant
`
`filed a trademark application for
`
` on December 16, 2020 for “legal
`
`services; namely providing legal consultation and research services, and litigation assistance and
`
`strategy services relating to birth injury” (“Applicant’s Services”).
`
`
`
`APPLICANT’S ANSWER: Applicant denies that Opposer has any rights to any mark in this
`
`Opposition, but Applicant admits that she filed the identified trademark application for Applicant’s
`
`services.
`
`14
`
`

`

`10.
`
`Applicant filed App. Serial No. 90387461 for
`
` in her own
`
`name, while still employed by Opposer.
`
`APPLICANT’S ANSWER: Applicant denies any implication that Opposer has any rights to any
`
`mark in this Opposition, but Applicant admits that Applicant filed the identified trademark
`
`application for Applicant’s services on December 16, 2020.
`
`
`
`11.
`
`Applicant filed the Opposed BIRTH JUSTICE Application using Opposer’s law
`
`firm address of 2684 West Eleven Mile Road, Berkley, Michigan 48072.
`
`
`
`APPLICANT’S ANSWER: Applicant admits that when Applicant filed the trademark
`
`application she used her then office mailing address at 2684 West eleven Mile Road, Berkley MI
`
`48072.
`
`
`
`12.
`
`A little over a month after filing the Opposed BIRTH JUSTICE Application, and
`
`while still employed by Opposer, Applicant filed a request to update the address associated with
`
`the Opposed Application to her own address: 151 Lafayette, Apt. 319, Pontiac, Michigan 48342.
`
`APPLICANT’S ANSWER: Applicant admits that it filed a Change Address or Representation
`
`Form on January 27, 2021, identifying an address at 151 Lafayette, Apt. 319, Pontiac, Michigan
`
`48342.
`
`
`
`
`
`15
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`

`

`13.
`
`The Opposed BIRTH JUSTICE Application was filed on a use basis, claiming a
`
`date of first use and first use in commerce of February 25, 2019.
`
`
`
`APPLICANT’S ANSWER: Applicant admits the allegation of Paragraph 13 of the Notice of
`
`Opposition.
`
`
`
`14.
`
`Applicant was employed by Opposer as of the first use and first use in commerce
`
`date of February 25, 2019.
`
`
`
`APPLICANT’S ANSWER: Applicant admits that applicant was employed by Opposer as of
`
`February 25, 2019, but denies any implication that Applicant’s claimed use was on behalf of
`
`Opposer.
`
`
`
`15.
`
`Applicant entered a disclaimer of BIRTH JUSTICE in the Opposed BIRTH
`
`JUSTICE Application, confirming she has no exclusive right to use “birth justice” apart from the
`
`mark as shown.
`
`
`
`APPLICANT’S ANSWER: Applicant admits that a disclaimer was entered by Examiner’s
`
`Amendment dated August 2,2021 which acknowledged that “No claim is made to the exclusive
`
`right to use “BIRTH JUSTICE” apart from the mark as shown.
`
`
`
`16.
`
`Applicant was aware of Opposer’s ownership of Opposer’s BIRTH JUSTICE
`
`Mark prior to filing an application for the Opposed BIRTH JUSTICE Mark.
`
`
`
`16
`
`

`

`APPLICANT’S ANSWER: Applicant denies the allegation of Paragraph 16 of the Notice of
`
`Opposition.
`
`
`
`17.
`
`The specimens submitted by Applicant in connection with the Opposed BIRTH
`
`JUSTICE Application consist of Facebook pages touting Opposer’s settlement awards and
`
`reflecting the birthjustice.com domain name, which redirected to Opposer’s website at
`
`olsmanlaw.com.
`
`
`
`APPLICANT’S ANSWER: Applicant admits that the specimens consist of Facebook pages
`
`maintained by Applicant and that the Facebook pages touting Opposer’s settlement awards and
`
`reflecting the birthjustice.com domain name, which redirected to Applicant’s biography page.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`18.
`
`The
`
` mark of the Opposed BIRTH JUSTICE
`
`Application
`
`replicates exactly the
`
`logo that Opposer’s graphic artist created for
`
`17
`
`

`

`Opposer at Opposer’s direction and expense.
`
`
`
`APPLICANT’S ANSWER: Applicant denies that the Applicant’s mark replicates exactly the
`
`logo of Opposer’s Application and Applicant further denies that Opposer’s graphic artist created
`
`the logo of Opposer’s Application.
`
`
`
`19.
`
`The inversion of the black and white color scheme in the Opposed BIRTH
`
`JUSTICE Application does not differentiate that mark from Opposer’s BIRTH JUSTICE logo,
`
`both of which appear below:
`
`Applicant’s Mark
`
`Opposer’s Mark
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a belief
`
`as to the truth or falsity of the allegations contained in Paragraph 19 of the Notice of Opposition and
`
`therefore denies same.
`
`
`
`
`
`20.
`
`The Opposed BIRTH JUSTICE Application is not limited as to color.
`
`APPLICANT’S ANSWER: Applicant admits that its Application is not limited as to color.
`
`
`
`
`
`18
`
`

`

`
`
`Opposer’s BIRTH JUSTICE Application is not limited as to color.
`
`21.
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a belief
`
`as to the truth or falsity of the allegations contained in Paragraph 21 of the Notice of Opposition and
`
`therefore denies same.
`
`
`
`22.
`
`As Opposer expects the Opposed BIRTH JUSTICE Application will be cited
`
`against Opposer’s BIRTH JUSTICE Application, Opposer has standing to bring this proceeding.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a belief
`
`as to the truth or falsity of the allegations contained in Paragraph 22 of the Notice of Opposition and
`
`therefore denies same.
`
`23.
`
`Well prior to Applicant’s December 16, 2020 filing date of the Opposed BIRTH
`
`JUSTICE Application, Opposer has used the BIRTH JUSTICE mark for legal services.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the allegations contained in Paragraph 23 of the
`
`Notice of Opposition.
`
`
`
`24.
`
`Any use by Applicant of Opposer’s BIRTH JUSTICE Mark inured to the benefit
`
`of Opposer.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the allegations contained in Paragraph 24 of the
`
`Notice of Opposition.
`
`
`
`19
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`

`

`25.
`
`As a result of the quality of Opposer’s Services and the widespread promotion
`
`thereof under Opposer’s BIRTH JUSTICE Mark, Opposer and Opposer’s Services have attracted
`
`substantial commercial interest and consumer recognition.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`belief as to the truth or falsity of the allegations contained in Paragraph 25 of the Notice of
`
`Opposition and therefore denies same
`
`26.
`
`Opposer’s BIRTH JUSTICE Mark has become a symbol of Opposer, Opposer’s
`
`Services, and Opposer’s goodwill.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`belief as to the truth or falsity of the allegations contained in Paragraph 26 of the Notice of
`
`Opposition and therefore denies same.
`
`27.
`
`Opposer’s use of Opposer’s BIRTH JUSTICE Mark and the rights associated
`
`therewith date to at least as early as October 2018 for legal services, predating the December 16,
`
`2020 filing date and February 25, 2019 claimed first use and first use in commerce date of the
`
`Opposed BIRTH JUSTICE Application, resulting in Opposer’s priority over Applicant.
`
`
`
`APPLICANT’S ANSWER: Applicant denies that Opposer has any rights associated with the
`
`BIRTH JUSTICE Mark, and accordingly denies the allegations of Paragraph 27 of the Notice of
`
`Opposition.
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`20
`
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`

`

`28.
`
`
`Applicant’s Services consist of legal services.
`
`
`APPLICANT’S ANSWER: Applicant admits that the services listed in Applicant’s application
`
`are Legal services; namely providing legal consultation and research services, and litigation
`
`assistance and strategy services relating to birth injury, otherwise denied.
`
`29.
`
`
`Opposer’s Services consist of legal services.
`
`
`APPLICANT’S ANSWER: Applicant admits that the services listed in Opposer’s application are
`
`Legal services
`
`
`
`
`
`The parties’ respective services are identical.
`
`30.
`
`
`APPLICANT’S ANSWER: Applicant denies that the listing of services in the respective
`
`applications is “identical.”
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`
`
`
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`
`
`
`
`
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`31.
`
`Applicant’s Services and Opposer’s Services are offered to the same consuming
`
`public.
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`belief as to the truth or falsity of the allegations contained in Paragraph 31 of the Notice of
`
`Opposition and therefore denies same.
`
`32.
`
`Applicant’s Services and Opposer’s Services are sold or offered in the
`
`same channels of trade.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`21
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`

`

`belief as to the truth or falsity of the allegations contained in Paragraph 32 of the Notice of
`
`Opposition and therefore denies same.
`
`
`
`33.
`
`The mark of the Opposed BIRTH JUSTICE Application is identical to Opposer’s
`
`BIRTH JUSTICE Mark.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the allegations of Paragraph 33 of the Notice of
`
`Opposition.
`
`
`
`34.
`
`The BIRTH JUSTICE portion of the Opposed BIRTH JUSTICE Application is
`
`pronounced the same as the BIRTH JUSTICE portion of Opposer’s BIRTH JUSTICE Mark.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`belief as to the truth or falsity of the allegations contained in Paragraph 34 of the Notice of
`
`Opposition and therefore denies same.
`
`
`
`35.
`
`In view of the identity of the marks, the identity of the services, the identity of the
`
`purchasers, and the identity of the channels of trade, purchasers are likely to mistakenly assume
`
`that Applicant’s Services originate from, are sponsored by, or are in some way associated with
`
`Opposer.
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`
`
`APPLICANT’S ANSWER: Applicant denies the allegations of Paragraph 26 of the Notice of
`
`Opposition.
`
`
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`22
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`

`

`
`
`36.
`
`The Opposed BIRTH JUSTICE Application is thus likely to cause confusion, or to
`
`cause mistake or to deceive. Accordingly, Opposer is likely to be damaged by registration of the
`
`mark of Application Serial No. 90387461.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`belief as to the truth or falsity of the allegations contained in Paragraph 36 of the Notice of
`
`Opposition and therefore denies same.
`
`
`
`37.
`
`Applicant left Opposer’s firm on or about September 2, 2021.
`
`
`APPLICANT’S ANSWER: Applicant admits the allegation of Paragraph 37 of the Notice of
`
`Opposition.
`
`
`
`
`
`38.
`
`Upon Applicant’s departure from Opposer’s firm, Opposer discovered that
`
`Applicant has filed Application Serial No. 90387461, which was published for opposition on
`
`September 7, 2021.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`belief as to the truth or falsity of the allegations contained in Paragraph 38 of the Notice of
`
`Opposition and therefore denies same.
`
`
`
`39.
`
`On information and belief, notwithstanding Opposer’s prior rights in Opposer’s
`
`BIRTH JUSTICE Mark, Applicant continues to use Opposer’s BIRTH JUSTICE Mark, and to
`
`
`
`23
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`

`

`prosecute the Opposed Birth Justice Application.
`
`
`
`APPLICANT’S ANSWER: Applicant denies that Opposer has any rights to any mark in this
`
`Opposition, but Applicant admits that it continues to prosecute Applicant’s trademark application.
`
`
`
`40.
`
`Given Applicant’s former employment with Opposer and the identity of the marks,
`
`Applicant’s continued use of Opposer’s BIRTH JUSTICE Mark has resulted in actual confusion in
`
`the marketplace.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`belief as to the truth or falsity of the allegations contained in Paragraph 38 of the Notice of
`
`Opposition and therefore denies same.
`
`41.
`
`On information and belief, Applicant was aware of Opposer’s rights in Opposer’s
`
`BIRTH JUSTICE Mark prior to filing the Opposed BIRTH JUSTICE Application.
`
`APPLICANT’S ANSWER: Applicant denies that Opposer has any rights to any mark in this
`
`Opposition and therefore denies the allegations of Paragraph 41 of the Notice of Opposition.
`
`42.
`
`Applicant even provided Opposer’s own law firm address to the USPTO when
`
`filing the Opposed BIRTH JUSTICE Application.
`
`
`
`APPLICANT’S ANSWER: Applicant admits that when Applicant filed the trademark application
`
`she used her then office mailing address at 2684 West eleven Mile Road, Berkley MI 48072.
`
`24
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`
`
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`
`
`

`

`43.
`
`On information and belief, Applicant was aware she was not the owner of the
`
`Opposed BIRTH JUSTICE Application at the time she filed the application.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the allegations of Paragraph 43 of the Notice of
`
`Opposition.
`
`
`
`44.
`
`On information and belief, Applicant knew Opposer’s BIRTH JUSTICE Mark was
`
`designed by Opposer’s graphic artist at Opposer’s direction and expense prior to the filing of the
`
`Opposed BIRTH JUSTICE Application.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the allegations of Paragraph 45 of the Notice of
`
`Opposition.
`
`
`
`45.
`
`On information and belief, Applicant knew Opposer’s BIRTH JUSTICE Mark was
`
`owned by Opposer prior to the filing of the Opposed BIRTH JUSTICE Application.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the allegations of Paragraph 45 of the Notice of
`
`Opposition.
`
`
`
`46.
`
`In addition, at the time of filing Application No. 90387461, Applicant falsely
`
`represented to the USPTO that no other party had the right to use the mark of the Opposed BIRTH
`
`JUSTICE Application in commerce, thereby committing fraud on the US Patent and Trademark
`
`Office.
`
`
`
`25
`
`

`

`APPLICANT’S ANSWER: Applicant denies the allegations of Paragraph 46 of the Notice of
`
`Opposition.
`
`
`
`47.
`
`Applicant’s false statement of ownership in the Opposed BIRTH JUSTICE
`
`Application was material to the filing.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the false premise and therefore denies the
`
`allegations of Paragraph 43 of the Notice of Opposition.
`
`
`
`
`
`
`
`48.
`
`Applicant’s provision of Opposer’s law firm address as her address in the Opposed
`
`BIRTH JUSTICE Application was material to the filing.
`
`
`
`APPLICANT’S ANSWER: Applicant is without sufficient information upon which to form a
`
`belief as to the truth or falsity of the allegations contained in Paragraph 48 of the Notice of
`
`Opposition and therefore denies same.
`
`
`
`49.
`
`Applicant’s false statements in the Opposed BIRTH JUSTICE Application were
`
`intended to deceive the USPTO.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the false premise and therefore denies the
`
`allegations of Paragraph 49 of the Notice of Opposition.
`
`50.
`
`In making false statements to the USPTO in connection with the Opposed BIRTH
`
`26
`
`

`

`JUSTICE Application, Applicant acted with a reckless disregard for the truth, resulting in fraud on
`
`the USPTO.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the false premise and therefore denies the
`
`allegations of Paragraph 50 of the Notice of Opposition.
`
`
`
`51.
`
`Because Applicant was not the owner of the mark of the Opposed BIRTH JUSTICE
`
`Application at the time of the filing of that application, Application Serial No. 90387461 is void ab
`
`initio.
`
`
`
`APPLICANT’S ANSWER: Applicant denies the false premise and therefore denies the allegations
`
`of Paragraph 51 of the Notice of Opposition
`
`
`
`52.
`
`If Applicant is granted the registration herein opposed, it would thereby obtain at
`
`least a prima facie exclusive right to use of the mark of the Opposed BIRTH JUSTICE Application,
`
`which would be a further source of damage.
`
`
`
`APPLICANT’S ANSWER: Applicant denies that Opposer would suffer any damage and therefore
`
`denies the allegations of Paragraph 52 of the Notice of Opposition.
`
`
`
`
`
`
`
`
`
`1.
`
`2.
`
`AFFIRMATIVE DEFENSES
`
`Opposer cannot demonstrate priority for its alleged mark, and/or application.
`
`Opposer cannot demonstrate any likelihood that the public will be confused or misled
`
`27
`
`

`

`as to the source of Applicant’s goods, or that Applicant’s goods are associated with or endorsed by
`
`Opposer.
`
`
`
`3.
`
`By having knowledge of Applicant’s use of the mark of the applied-for registration,
`
`Opposer is estopped from claiming any likelihood that the public will be confused or misled as to the
`
`source of Applicant’s goods, or that Applicant’s goods are associated with or endorsed by Opposer.
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`4.
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`By having knowledge of Applicant’s use of the mark of the applied-for registration,
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`Opposer has acquiesced in Applicant’s use and therefore the registrability of Applicant’s mark.
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`WHEREFORE, Applicant and Counter-Petitioner respectfully prays that:
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`PRAYER FOR RELIEF
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`a) the Opposition be dismissed and that this Opposition be sustained in favor of the Applicant
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`and that Applicant’s mark, Application Serial No. 90/387461, be permitted to proceed to
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`registration; and
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`b) it be awarded such further relief as this Board deems just and proper.
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`Date: December 15, 2021
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`Respectfully submitted,
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`By: /Richard W. Hoffmann/
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`RICHARD W. HOFFMANN (MI Bar No. P42352)
`JAMES D. STEVENS JR. (MI Bar No. 82081)
`Reising Ethington P.C.
`755 West Big Beaver Road, Suite 1850
`Troy, Michigan 48084
`Telephone: 248-689-3500
`Facsimile: 248-689-4071
`hoffmann@reising.com
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`Attorneys for Applicant Emily Grace Thomas
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`28
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