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`ESTTA Tracking number:
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`ESTTA1188267
`
`Filing date:
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`02/01/2022
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding no.
`
`91273294
`
`Party
`
`Correspondence
`address
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`Submission
`
`Filer's name
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`Filer's email
`
`Plaintiff
`Apple Inc.
`
`JOSEPH PETERSEN
`KILPATRICK TOWNSEND & STOCKTON LLP
`1080 MARSH ROAD
`MENLO PARK, CA 94025
`UNITED STATES
`Primary email: jpetersen@kilpatricktownsend.com
`Secondary email(s): bbryner@kilpatricktownsend.com,
`jpetersen@kilpatricktownsend.com, cgenteman@kilpatricktownsend.com, agar-
`cia@kilpatricktownsend.com, tmadmin@kilpatricktownsend.com
`650-326-2400
`
`Other Motions/Submissions
`
`Joseph Petersen
`
`jpetersen@kilpatricktownsend.com, bbryner@kilpatricktownsend.com, cgente-
`man@kilpatricktownsend.com, agarcia@kilpatricktownsend.com, tmad-
`min@kilpatricktownsend.com
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`Signature
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`Date
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`/Joseph Petersen/
`
`02/01/2022
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`Attachments
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`Statement of Non-Oppositionf.pdf(145166 bytes )
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Application Serial No. 90/335,369
`For the Mark: APPLE-MAN
`Filed: November 22, 2020
`Published: June 8, 2021
`
`APPLE INC.,
`
` v.
`
`VASYL MOSKALENKO,
`
`Opposer,
`
`Applicant.
`
`Opposition No. 91273294
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`STATEMENT OF NON-OPPOSITION TO MOTION TO EXTEND
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`Opposer Apple Inc. (“Apple”) files this Statement of Non-Opposition to Applicant’s
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`Motion to Extend Time (4 TTABVUE 2).
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`Long prior to commencing this opposition, Apple reached out to Applicant to express
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`Apple’s concerns about Applicant’s attempt to register his APPLE-MAN mark broadly in Class 9
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`in connection with gaming software and downloadable software among other computer related
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`goods. Applicant did not address Apple’s concerns and Apple thereafter opposed Applicant’s
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`November 22, 2020 application for APPLE-MAN. Apple did so because the mark incorporates
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`Apple’s famous APPLE mark in its entirety and seeks registration for numerous goods in Class 9
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`long associated with Apple and its family of Apple trademarks including, among other goods,
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`“downloadable computer game software for use on mobile and cellular phones” and
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`“downloadable video and computer game programs.”
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`Apple attempted to resolve its dispute with Applicant amicably. However, Applicant’s last
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`1
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`
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`substantive settlement discussion with Apple occurred on November 23, 2021 during which
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`Applicant’s counsel promised to speak with his client concerning amicable resolution. Apple heard
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`nothing further of substance from Applicant on settlement until Applicant filed his January 12,
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`2022 motion to extend time in which Applicant notes “Applicant wishes to attempt to settle this
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`matter and requires time to attempt to do that.”
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`More recently, Applicant has released a video in which he claims that he “just want[s] to
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`make a comedy movie about a superhero whose super power is related with everyone's favorite
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`fruit.” See https://www.youtube.com/watch?v=cDuBYeVomvY. In this video, Applicant also
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`claims that he is “not going to produce … software [or] anything that might be deemed to conflict
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`with [Apple’s] brand.”
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`Apple has never objected to Applicant’s use of the name APPLE-MAN for his film title
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`and based on Applicant’s statements in the video, it appears that Applicant does not intend to
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`pursue his application to register his APPLE-MAN mark in connection with software and related
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`downloadable entertainment content in Class 9. Accordingly, Apple remains fully amenable to
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`working with Applicant to resolve this dispute amicably and on that basis has no opposition to
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`Applicant’s Motion to Extend.
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`Dated: February 1, 2022
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`Respectfully submitted,
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`KILPATRICK TOWNSEND &
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`
`
`STOCKTON LLP
`
`
`
`By: /Joseph Petersen/
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`Joseph Petersen
`1080 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 326-2400
`jpetersen@kilpatricktownsend.com
`
`2
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`
`
`William M. Bryner
`1001 West Fourth Street
`Winston-Salem, North Carolina 27101
`Telephone: (336) 607-7500
`bbryner@kilpatricktownsend.com
`
`Crystal Genteman
`1100 Peachtree Street NE, Suite 2800
`Atlanta, Georgia 30309
`Telephone: (404) 815-6500
`cgenteman@kilpatricktownsend.com
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`Attorneys for Opposer Apple Inc.
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`3
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Application Serial No. 90/335,369
`For the Mark: APPLE-MAN
`Filed: November 22, 2020
`Published: June 8, 2021
`
`APPLE INC.,
`
` v.
`
`VASYL MOSKALENKO,
`
`Opposer,
`
`Applicant.
`
`Opposition No. 91273294
`
`CERTIFICATE OF TRANSMITTAL
`
`I hereby certify that a true copy of the foregoing STATEMENT OF NON-OPPOSITION
`
`TO MOTION TO EXTEND is being filed electronically with the TTAB via ESTTA on this day,
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`February 1, 2022.
`
`
`
`/Alberto Garcia/
`Alberto Garcia
`
`4
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Application Serial No. 90/335,369
`For the Mark: APPLE-MAN
`Filed: November 22, 2020
`Published: June 8, 2021
`
`APPLE INC.,
`
` v.
`
`VASYL MOSKALENKO,
`
`Opposer,
`
`Applicant.
`
`Opposition No. 91273294
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on February 1, 2022, a true copy of the foregoing STATEMENT OF
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`NON-OPPOSITION TO MOTION TO EXTEND is being served on Applicant’s counsel of
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`record via electronic mail to:
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`JEREMY PETER GREEN
`JPG LEGAL
`68 JAY STREET, SUITE 612
`BROOKLYN, NY 11201
`docket@jpglegal.com
`
`/Alberto Garcia/
`Alberto Garcia
`
`5
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`