Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
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`ESTTA Tracking number:
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`ESTTA1192596
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`Filing date:
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`02/22/2022
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding no.
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`91273978
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`Party
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`Correspondence
`address
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`Defendant
`Guangzhou Royal Wolf Standard Denim Garment Ltd
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`WILLIAM SCOTT GOLDMAN
`GOLDMAN LAW GROUP
`1300 PENNSYLVANIA AVE., N.W.; STE. 700
`WASHINGTON, DC 20004
`UNITED STATES
`Primary email: trademarks@branding-law.com
`202-880-9200
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`Submission
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`Filer's name
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`Filer's email
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`Signature
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`Date
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`Answer
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`Chrishna Lindor
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`Chrishna@beakpo.com
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`/Chrishna Lindor/
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`02/22/2022
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`Attachments
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`Trademark answer - Copy .pdf(336976 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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`——————————————————————
`FREDDY S.P.A.,
` §
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` § U.S. Serial No. 90489638
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`Opposer,
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`V.
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` §
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`Opposition No.
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` §
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`GUANGZHOU ROYAL WOLF STANDARD §
`DENIM GARMENT LTD’S U.S. §
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` §
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` §
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` Applicant.
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` §
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`APPLICANT’S ANSAPPLICANTR TO NOTICE OF OPPPOSITION
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`Applicant, GUANGZHOU ROYAL WOLF STANDARD DENIM GARMENT LTD’S U.S.
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` (hereinafter “Applicant”), by and through its attorney, hereby answers the Notice of Opposition (the
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`“Opposition”) filed by FREDDY S.P.A. (hereinafter “Opposer”) on January 14, 2022 and assigned
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`Opposition No. 91273357. Applicant hereby responds, solely for the purpose of this proceeding, to each
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`of the grounds set forth in the Notice of Opposition:
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`1. Applicant admits the allegation in Paragraph 1 and 2 of the Opposition.
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`2. Applicant lacks knowledge or information sufficient to form a belief as to the truth of the matters
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`alleged in Paragraph 3 of the Opposition and, therefore, denies the same.
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`3. Applicant admits the allegation in Paragraph 4 of the Opposition. The time has been recognized by the
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`Trademark Office.
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`OPPOSER’S PRIOR USE OF
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`ITS TRADEMARKS
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`1
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`4. Applicant lacks knowledge or information sufficient to form a belief as to the truth of the matters
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`alleged in Paragraph 5 of the Opposition.
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`5. Applicant denies the allegations in Paragraph 6 of the Opposition. Opposer is referring to the Freddy
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`brand or WR.UP®, not the disputed trademark.
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`6. Applicant denies the allegations in Paragraph 7 of the Opposition. Opposer's trademark is WR.UP®,
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`and the products it sells have nothing to do with Applicants MW trademark.
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`7. Applicant denies the allegations in Paragraph 8 of the Opposition. Opposer refers to their products and
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`has nothing to do with Applicants trademark application.
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`8. Applicant denies the allegations in Paragraph 9 of the Opposition. Opposer refers to WR.UP® pants,
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`not related to Applicants trademark application.
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`9. Applicant denies the allegations in Paragraph 10 of the Opposition. Opposer mentioned design style
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`and layout pattern, which has nothing to do with the trademark Applicant applied for.
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`10. Applicant denies the allegations in Paragraph 11 of the Opposition. Opposer mentioned design style
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`and layout pattern, which has nothing to do with the trademark Applicant applied for.
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`11. Applicant denies the allegations in Paragraph 12 of the Opposition. Opposer's remarks are fraudulent,
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`and Applicant require the other party to provide evidence of trademark use.
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`12. Applicant denies the allegations in Paragraph 13 of the Opposition. Opposer mentioned design style
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`and layout pattern, which has nothing to do with the trademark Applicant applied for.
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`13. Applicant admits the allegation in Paragraph 15 of the Opposition. The reason for the similarity of the
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`trademarks is that during the patent judicial litigation between the Opposer and the Applicant in China
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`in 2019, Opposer systematically studied Applicants intellectual property rights and copied the copyright
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`patterns that Applicants owned. (cid:2073)国作登字-2022-F-10005786(cid:2074)
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`14. Applicant admits the allegation in Paragraph 16 of the Opposition. The reason why the trademarks are
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`similar/identical is that the Opposer plagiarized and squatted Applicants prior Chinese trademark.
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`2
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`15. Applicant admits the allegation in Paragraph 17 of the Opposition. Applicants have extensive publicity
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`and sales records in the United States, see Evidence Attachment.
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`APPLICANT’S BAD FAITH
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`16. Applicant denies the allegations in Paragraph 18 of the Opposition. Opposers are plagiarists. After a
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`patent dispute in China, the Opposers copied Applicants trademarks that Applicant continued to use on
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`a large scale. Opposers know that Applicants use and have copyright, but insist on global squatting and
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`objection to invalidate our trademark.
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`17. Applicant denies the allegations in Paragraph 19 of the Opposition. The Opposer copied Applicants
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`trademark, and the trademark mentioned by the Opposer has nothing to do with the trademark Applicant
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`applied for.
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`18. Applicant denies the allegations in Paragraph 20 of the Opposition. Applicants own many intellectual
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`property rights around the world, and the other party's submission is only one of them, and is not related
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`to the disputed trademark.
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`19. Applicant denies the allegations in Paragraph 21 of the Opposition. Applicant initiated the invalidation
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`of his patent in the context of the Opposer's patent lawsuit. Opposers lose patent litigation case.
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`Opposers copied Applicant trademarks to register worldwide during patent disputes.
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`20. Applicant denies the allegations in Paragraph 22 of the Opposition. Opposers plagiarize Applicants
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`trademark and seriously infringe Applicant prior trademark rights and copyrights. After the Opposers
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`failed to register trademarks in the European Union, the United States, and Australia, they objected and
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`invalidated our trademarks on a large scale with trumped-up reasons, which seriously violated our rights.
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`Applicant have now initiated lawsuits against them in China.
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`21. Applicant denies the allegations in Paragraph 23 of the Opposition. Applicants have always been in a
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`market competition relationship. Opposers plagiarize and attack our trademarks are acts of malicious
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`competition. Applicant have never heard of the other party before Applicant received the patent lawsuit
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`from the other party.
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`3
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`22. Applicant denies the allegations in Paragraph 24 of the Opposition. Applicants have always been in a
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`market competition relationship. Opposers plagiarize and attack our trademarks are acts of malicious
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`competition. Applicant have never heard of the other party before Applicant received the patent lawsuit
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`from the other party.
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`COUNT I
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`PRIORITY AND LIKELIHOOD OF CONFUSION
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`23. Applicant denies the allegations in Paragraph 26 of the Opposition. Opposer fraud. For details, see
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`Reply to Article 14.
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`24. Applicant denies the allegations in Paragraph 27 of the Opposition. The trademark is designed and used
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`by Applicant. Except for plagiarizing and squatting Applicant trademark and maliciously complaining
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`about the sales link of Applicant products, the Opposers have not carried out any related trademark
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`promotion and use.
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`25. Applicant denies the allegations in Paragraph 28 of the Opposition. Opposer fraud.
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`26. Applicant denies the allegations in Paragraph 29 of the Opposition. Opposer fraud.
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`27. Applicant denies the allegations in Paragraph 30 of the Opposition. The reason for the similarity is that
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`the Opposers plagiarized and squatted Applicants trademarks, and our trademarks gained
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`distinctiveness under extensive use. The Opposers’ trademarks lost their distinctiveness because they
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`were copied and decorated too close to the real pants that are widely sold in the market and was
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`therefore rejected by the EU and US Trademark Offices.
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`28. Applicant denies the allegations in Paragraph 31 of the Opposition. The Opposers did not use the pattern
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`for trademark purposes, so there is no confusion.
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`29. Applicant denies the allegations in Paragraph 32 of the Opposition. Applicants are the designer of the
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`trademark, which continues to be used worldwide, and has applied for copyright protection, at least
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`until the Opposer files a patent lawsuit with the Applicant. Opposers are well aware of the fact that
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`Applicant have designed and used the mark. Opposers insist on plagiarizing and squatting trademarks
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`for the purpose of commercial competition and to destroy our promotion in the global market. Opposers
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`4
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`attempt to squat Applicant trademarks and then initiate trademark infringement lawsuits against us to
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`kill our brand.
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`COUNT II FRAUD ON THE USPTO (15 U.S.C. § 1064(3))
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`30. Applicant denies the allegations in Paragraph 34 of the Opposition. The applicant applied for
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`registration in strict accordance with the requirements of the Trademark Office,and submitted sufficient
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`evidence. The Trademark Office also reviewed it. The United States is our important market, and
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`trademarks are used continuously
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`in
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`the United States,
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`such as American
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`stores.
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`(cid:28431) https://www.ebay.com/sch/shasculfites/m.html?_nkw=&_armrs=1&_ipg=&_from= (cid:28432) Applicant
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`have hundreds of stores around the world, including the United States, for sale. Since the design of
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`the trademark, it has been widely publicized and used, and it has gained a good reputation. It is not
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`clear why the Opposers questioned it.
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`31. Applicant denies the allegations in Paragraph 35 of the Opposition. The applicant truthfully provided
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`all the information to the lawyer, and the objector was deliberately seeking trouble. Applicants sell in
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`nearly a hundred stores worldwide and advertise extensively, see evidence of US and international use,
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`including images and sales links below: https://www.ebay.com/itm/333870081138?nordt=true
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`https://www.ebay.com/itm/333870112937?nordt=true
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`32. Applicant denies the allegations in Paragraph 36 of the Opposition. Applicants use it widely in jeans,
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`jeggings, leggings, pants, shorts, underwear, underpants, the link is as follows:
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`33. https://www.ebay.com/itm/333869351666?nordt=true
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`34. https://www.ebay.com/itm/333974653696?nordt=true
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`35. https://www.ebay.com/itm//333869398227?nordt=true
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`36. https://www.ebay.com/itm/333869376464?nordt=true
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`37. https://www.ebay.com/itm/333974655595?nordt=true
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`38. https://www.ebay.com/itm//333974626745?nordt=true
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`5
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`39. https://www.ebay.com/itm//333869508705?nordt=true
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`40. https://www.ebay.com/itm/333870081138?nordt=true
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`41. https://www.ebay.com/itm/333870112937?nordt=true
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`42. https://www.ebay.com/itm//333869542214?nordt=true
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`43. https://www.wish.com/merchant/618b7b56b13e76b9d8682854?source=merchant&positio
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`n=0&share=Applicantb
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`44. Applicant denies the allegations in Paragraph 37 of the Opposition. Applicants are the designer and
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`user of the trademark and have not authorized others to use it in the United States, so the statement is
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`in line with the actual situation.
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`45. Applicant denies the allegations in Paragraph 38 of the Opposition. Applicants are the designer and
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`user of this trademark. Although the Opposers copied our trademark and tried to squat in the United
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`States, because the Opposers copied the trademark for the purpose of complaining about the competing
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`products in the market. Opposers transformed our trademark to be the same as the actual pants pettern,
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`which resulted in loss of distinctiveness, and was questioned by the Trademark Office of market
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`monopoly, and their squatting trademark registration was rejected by the Trademark Office. At the
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`same time, the Opposers did not actually publicize and use their registered graphic trademarks, so the
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`Opposers also have no rights to this trademark except infringing our copyright.
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`46. Applicant denies the allegations in Paragraph 39 of the Opposition. Opposer fraud.
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`47. Applicant denies the allegations in Paragraph 40 of the Opposition. The Opposers are plagiarists,
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`squatters, and malicious competitors. The other party conceals the Trademark Office, covers up its
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`plagiarism and malicious market competition intentions, and fabricates a lot of evidence. To prevent
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`our normal trademark protection activities after a failed trademark squatting.
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`48. Applicant denies the allegations in Paragraph 41 of the Opposition. The Opposer is the party trying to
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`defraud the Trademark Office.
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`6
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`49. Applicant denies the allegations in Paragraph 42 of the Opposition. The Opposer is the party trying to
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`defraud the Trademark Office.
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`WHEREFORE, in consideration of the foregoing, Applicant respectfully request Dismissal of the Notice
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`of Opposition in its entirety, and the registration be granted to Application Serial No., 90400771 together
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`with such other and further relief this board may deem just and proper.
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`Date: February 22, 2022
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`Respectfully Submitted,
`By its Attorney,
`Chrishna Lindor
`By:/ Chrishna Lindor /
`Chrishna Lindor
`E-mail: Chrishna@Beakpo.com
`Attorney for Applicant
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and complete copy of the above document was sent to the Opposer’s
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`counsel of record via email to:
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`Date: February 22, 2022
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`Chrishna Lindor
`/Chrishna Lindor/
`Attorney at Law
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