ESTTA Tracking number:
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`ESTTA1313673
`
`Filing date:
`
`10/03/2023
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding no.
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`91285757
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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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`Signature
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`Date
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`Attachments
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`Defendant
`Nicolet Law Office, S.C.
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`CAROL N. SKINNER
`SKINNER AND ASSOCIATES
`212 COMMERCIAL STREET
`HUDSON, WI 54016
`UNITED STATES
`Primary email: cskinner@skinnerlaw.com
`Secondary email(s): ccarper@skinnerlaw.com
`715-386-5800
`
`Motion for Relief from entry of Default Judgment
`
`Carol N. Skinner
`
`cskinner@skinnerlaw.com, ccarper@skinnerlaw.com
`
`/Carol N. Skinner/
`
`10/03/2023
`
`Nicolet Request for Relief from Default Judgment 10-3-23.pdf(18974 bytes )
`Nicolet Declaration in Support of Request for Relief 10-3-23.pdf(3208086 bytes )
`Certificate of Service Opp. No. 91285757.pdf(233251 bytes )
`
`

`

`IN THE UNITED STATES PATENT AND
`TRADEMARK OFFICE BEFORE THE TRADEMARK
`TRIAL AND APPEAL BOARD
`
`
`
`In the Matter of Application Serial No. 97324065
`For the Mark: NICOLET LAW
`Filed: 03/22/2022
`Published: 02/28/2023
`
`
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`
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`BYE, GOFF & ROHDE, LTD.
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`Opposer,
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`v.
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`NICOLET LAW OFFICE, S.C.,
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`Applicant-
`Respondent.
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`Opposition No. 91285757
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`NOTICE OF MOTION AND MOTION FOR RELIEF FROM DEFAULT JUDGMENT
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`
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`TO: BYE, GOFF & ROHDE, LTD.
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`c/o The Spence Law Firm
`222 S. 9th St., Suite 1600
`
`
`Minneapolis, MN 55402
`
`
`
`PLEASE TAKE NOTICE that Applicant-Respondent Nicolet Law Office, by its
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`attorneys Skinner and Associates, by Carol Skinner, requests relief from the Default Judgment
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`entered in the above Proceeding on 27 September, 2023 and the resulting abandonment of US
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`Trademark Application No. 97434065. Grounds for this motion are mistake, inadvertence,
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`surprise, and/or excusable neglect. Skinner and Associates did not receive Notice of the above
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`Opposition, and was unaware of its existence until receiving the Notice of Abandonment of the
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`above referenced application on 27 Sept., 2023, and Board Decision Sustaining Opposition No.
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`91285757 on the same date.
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`
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`1
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`

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`
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`This Motion is brought pursuant to Fed. R. Civ. Pro. 60(b) and TBMP 544, and is
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`supported by the Declaration of Attorney Carol Skinner, filed herewith.
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`Respectfully submitted this 3rd day of October, 2023.
`
`SKINNER AND ASSOCIATES
`
`
`
`
`Carol N. Skinner
`Attorneys for Nicolet Law Office, S.C.
`Attorney ID # 1017307
`
`
`212 Commercial
`Hudson, WI 54016
`(715) 386-5800
`cskinner@skinnerlaw.com
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`2
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`IN THE UNITED STATES PATENT AND
`TRADEMARK OFFICE BEFORE THE TRADEMARK
`TRIAL AND APPEAL BOARD
`
`In the Matter of Application Serial No. 97324065
`For the Mark: NICOLET LAW
`Filed: 03/22/2022
`Published: 02/28/2023
`
`BYE, GOFF & ROHDE, LTD.
`
`Opposer,
`
`v.
`
`NICOLET LAW OFFICE,S.C.,
`
`Applicant-
`Respondent.
`
`Opposition No. 91285757
`
`DECLARATION IN SUPPORT OF MOTION FOR RELIEF
`FROM DEFAULT JUDGMENT
`
`Declarant, Carol N. Skinner, hereby declares as follows:
`
`l.
`
`I am the Attorney for Applicant-Respondent Nicolet Law Office, S.C. (hereinafter
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`Nicolet) in the above referenced Opposition.
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`2.
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`I make this Declaration in support of Nicolet’s Motion for Relief from Default
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`Judgment, filed herewith.
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`3
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`Nicolet is the owner of US Trademark Application No. 97324065.
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`I recently
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`received a Notice from the USPTOindicating that the TTAB had entered a Default Judgmentin
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`Opposition No. 91285757 (hereinafter Proceeding ‘5757), thereby resulting in the abandonment
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`of Nicolet’s application, and suspending proceedings in Opposition No. 91285756 (hereinafter
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`Proceeding *5756) pending action by Opposerin that proceeding to obtain judgmenttherein.
`
`]
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`

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`4.
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`Although Skinner and Associatesis listed as Correspondent in both Oppositions,
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`neither myassistant, Christie Carper nor I received any Notice of Opposition for Proceeding
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`5757, which is why no Answerwasfiled. In nearly 25 years of practice before the USPTO,I
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`have never experiencedthesituation of not receiving notice of a proceeding.
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`5,
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`I received a Notice of Default on 18 August, 2023, with an Opposition number of
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`91285757.
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`I did not notice that one of the numbers wasdifferent than the 91285756 Proceeding,
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`of which I was aware and to whichI had filed an Answer(Exhibit 1). Believing the Notice to
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`involve Proceeding *5756, I contacted the USPTO,and communicated with the Interlocutory
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`Attorney on Proceeding ‘5756, Attorney McCormick, stating that an Answerhad in fact been
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`filed. She agreed, and I believed that I had received the Notice in error, and that the matter was
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`resolved.
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`6.
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`The above parties are involved in a trademark infringement proceeding brought
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`by Nicolet against both St. Paul Agency LLC and Bye Goff & Rhode Ltd., in the Western
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`District of Wisconsin, Case No. 22-cv-654-slc. While I am not the attorney representing Nicolet
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`in this case, | am aware that the case has been recently resolved, with the understanding that
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`opposition proceedings against Nicolet would be withdrawn.
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`Te
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`Due to my lack of knowledge of the ‘5757 Proceeding, I responded negatively to
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`Nicolet’s counsel’s inquiry about the existence of any Opposition against Nicolet other than the
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`‘5756 Proceeding.
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`8.
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`Myfailure to file an Answerin the above proceeding wasnot willful, and I am
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`not aware of any prejudice to the Opposerif this Motion is granted.
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`I have recently
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`communicated with counsel for Opposer, requesting Opposer’s consent to the Motion for Relief,
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`but have not yet received a response to my request. As indicated in Nicolet’s Answerto
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`

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`Opposition No. 91285756, Exhibit 1, supra, Nicolet has a meritorious defense to this Opposition,
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`and seeksrelief from this default judgment.
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`9.
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`Declarant furtherdeclaresthatall statements made herein of her own knowledge.
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`are true andthatall statements made on information and belief are believed to be true; and
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`further that these statements were made with the knowledgethat willful false statements and the
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`like so madeare punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of
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`the United States Code and that such willful false statement may jeopardize the validity of the
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`application or any registration issued thereon.
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`DECLARANT
`
`«
`puny
`di
`a
`r
`L fi tet Jf ¢ Sen re
`
`Carol N. Skinner
`
`Dated: October 3, 2023
`
`

`

`IN THE UNITED STATES PATENT AND
`TRADEMARK OFFICE BEFORE THE TRADEMARK
`TRIAL AND APPEAL BOARD
`
`In the Matter of Application Serial No. 97324065
`For the Mark: NICOLET LAW
`Filed: 03/22/2022
`Published: 02/28/2023
`
`SAINT PAUL AGENCY, LLC
`
`Opposer,
`
`Vv.
`
`NICOLET LAW OFFICE,S.C.,
`
`Applicant-
`Respondent.
`
`Opposition No. 91285756
`
`APPLICANT'S ANSWER TO OPPOSITION
`
`The Applicant, Nicolet Law Office, S.C. (hereafter Nicolet Law or Applicant), by its
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`attorneys Skinner and Associates by Carol N. Skinner, answers the Opposition of Saint Paul
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`Agency, LLC (hereafter Saint Paul Agency or Opposer), as follows:
`
`1.
`
`2.
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`3.
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`Admits the allegations contained in paragraph 1.
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`Admitsthe allegations contained in paragraph2.
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`Lacks information sufficient to form a belief regarding the allegations contained
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`in paragraph 3, and puts Opposertoits proof thereon.
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`4,
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`5.
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`Deniesthe allegations contained in paragraph 4.
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`Admits that the USPTOinitially issued a refusal based on surname, and required a
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`disclaimer of the word “LAW”apart from the mark as shown. Denies remaining assumptions.
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`
`
`

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`6.
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`7
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`8.
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`Admits the allegations contained in paragraph 6.
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`Admits the allegations contained in paragraph 7.
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`Admits that Nicolet Law wasforced to initiate legal action in US District Court
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`for the Western District of Wisconsin, Case No. 2-cv-654-slc,in order to stop Opposer’s
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`repeated, intentional infringing use of Nicolet Law’s mark in an attempt to misdirect consumers
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`to Opposer’s client, a competing personal injury law firm, Bye, Goff & Rhode, Ltd. Denies that
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`Opposer’s use of Applicant’s mark was either “errant” or “unknowing.”
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`9.
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`10.
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`Denies the allegations contained in paragraph 9.
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`Denies the allegations contained in paragraph 10 as written, and affirmatively
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`alleges that attorney Spiros Nicolet, an immigration lawyer in Chicago, IL, did purchasethe url
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`nicoletlawyers.com, does not usethis url in marketing, and has voluntarily redirectedall
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`searchers using this url to spirosnicoletlawoffices.com. A true and correct copy of a printoutof a
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`Google search for nicoletlawyers.com is attached hereto as Exhibit A.
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`ll.
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`12.
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`13.
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`14.
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`Realleges all previous answers.
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`Denies the allegations/legal conclusions contained in paragraph 12.
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`Deniesthe allegations/legal conclusions contained in paragraph 13.
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`Admits the allegations contained in paragraph 14, but affirmatively alleges that no
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`such evidenceis necessary, given the presumption of acquired distinctiveness after substantially
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`exclusive and continuous use of the mark in interstate commercefor the identified services for a
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`period of time exceeding five years. Nicolet Law hasin fact been using the mark NICOLET
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`LAW markin association with legal services in interstate commerce substantially exclusively
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`and continuously since at least as early as April 20, 2007.
`
`

`

`15.
`
` Realleges its responseto the allegations contained in paragraph 15, and
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`affirmatively alleges that Applicant has had commonlaw trademarkrights in the mark
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`NICOLET LAW sinceat least as early as April 20, 2007.
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`16.
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`Denies that Opposer would be injured by Applicant’s registration, denies that the
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`markis descriptive, and affirmatively alleges that Opposer’s sole reason forfiling the instant
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`Opposition is to aid its defense or obtain leverage in Case No. 2-cv-654-slc, and not becauseit
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`has a reasonable beliefthat it will be damaged under any lawful basis stated in or envisioned by
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`Trademark Act §13(a), 15 U.S.C. §1063(a), or §309.03(b) of the Trademark Trial and Appeal
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`Board Manual of Procedure (TBMP).
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`17.
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`18.
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`19.
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`Denies the allegations contained in paragraph 17.
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`Realleges all previous answers.
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`Denies the allegations contained in paragraph 19.
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`20.
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`Admits the factual content of the allegations contained in paragraph 20; denies the
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`legal conclusion.
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`21.
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`Denies the allegations contained in paragraph 21, and affirmatively alleges that
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`either 1178 or “over one hundred” individuals with the surname “Nicolet” out of a possible
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`322,278,200 individuals living in the United States does not establish that the name is a common
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`surname.
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`22.
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`Neither admits nor denies that Opposerrelies on information contained in
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`Opposer’s exhibits, but affirmatively alleges that the common surnames “Davis” and “Miller”
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`are not comparable to the surname “Nicolet”, nor does Opposer’s evidence prove anything
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`relevant to this Opposition.
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`23.
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`Denies the allegations contained in paragraph 23, and affirmatively alleges that
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`Applicant seeks to register the mark NICOLET LAW, which has acquired descriptiveness as a
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`3
`
`

`

`source identifier for Applicant’s legal services by dint of more than 16 years of substantially
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`exclusive and continuous use of the mark in interstate commerce.
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`24._Realleges its response to paragraph 10 of this Answer, in response to the
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`allegations contained in paragraph 24.
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`25.
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`26.
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`Denies the allegations contained in paragraph 25.
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`Denies the allegations contained in paragraph 26.
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`27._Realleges all previous answers.
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`28.|Admits the allegations contained in paragraph 28.
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`29.
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`30.
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`Admits the allegations contained in paragraph 29.
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`Denies the allegation contained in paragraph 30, and affirmatively allege that
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`counsel for Applicant first learned of the existence of Attorney Spiros Nicolet more than four
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`months after submitting the Section 2(f) Declaration. Upon information and belief, Attorney
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`Spiros Nicolet had not used the url nicoletlawyers.com to market his services prior to late May of
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`2023, instead using the url midwestgreencard.com to identify his immigration practice.
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`31.
`
`32.
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`33.
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`Denies the allegation contained in paragraph 31.
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`Denies the allegation contained in paragraph 32.
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`Denies the allegation contained in paragraph 33, and questions the statutory
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`entitlement of Opposerto bring this Opposition.
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`34.
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`Denies the allegation contained in paragraph 34.
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`AFFIRMATIVE DEFENSES
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`Pleading further, Applicant sets forth the following affirmative and other defenses:
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`1,
`
`2.
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`Nicolet Law realleges all preceding affirmative statements.
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`OpposerSt. Paul Agency has proffered no information lending credencetoits
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`claimsthat it will be in any way damagedbythe registration of Applicant’s trademark.
`
`4
`
`

`

`Be
`
`Opposerhas not offered, nor will be able to offer any evidencethatit has
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`suffered, nor will suffer any damage bythe registration of Applicant’s trademark.
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`4,
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`Opposer St. Paul Agencyis not entitled to oppose Applicant’s mark, as it has not
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`established, nor will it establish that it is within the zoneof interests protected by thestatute.
`
`It
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`has neither pled nor established a “realinterest,”i.e., a direct and personal stake in the outcome
`
`of this Opposition, nor a reasonable basis to believe it will be damaged by the registration of
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`Applicant’s trademark.
`
`J.
`
`Opposeris unlawfully using this proceeding in an effort to invent a defense
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`against the claim of intentional trademark infringementset forth in Case No. 2-cv-654-slc, with
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`no reasonablebasis in fact to believe it has suffered or will suffer damage by theregistration of
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`Applicant’s trademark.
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`6.
`
`Having unclean hands, Opposer should be required to bearall costs ofthis
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`proceeding.
`
`

`

`WHEREFORE,Applicant Nicolet Law Office, S.C. prays that Saint Paul Agency’s
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`Opposition be dismissed with prejudice, Opposer required to pay Applicant’s fees and costs
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`incurred in this proceeding, and the Application Serial No. 97324065 be allowed to proceed to
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`registration.
`
`Respectfully submitted this 7th day of August, 2023.
`
`SKINNER AND ASSOCIATES
`
`Carol N. Skinner
`Attorneys for Nicolet Law Office, S.C.
`Attorney ID # 1017307
`212 Commercial
`Hudson, WI 54016
`(715) 386-5800
`eskinner@skinnerlaw.com
`
`

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`IN THE UNITED STATES PATENT AND
`TRADEMARK OFFICE BEFORE THE TRADEMARK
`TRIAL AND APPEAL BOARD
`
`In the Matter of Application Serial No. 97324065
`For the Mark: NICOLET LAW
`Filed: 03/22/2022
`Published: 02/28/2023
`
`BYE, GOFF & ROHDE, LTD.
`
`Opposer,
`
`V.
`
`NICOLET LAW OFFICE,S.C.,
`
`Applicant-
`Respondent.
`
`Opposition No. 91285757
`
`CERTIFICATE OF SERVICE
`
`I, Christie J. Carper, of the City of Hudson, County of St. Croix, State of Wisconsin,
`
`hereby certify that a true and complete copy of the foregoing Notice of Motion and Motion for
`
`Relief from Default Judgment and Declaration in Support of Motion for Relief from Default
`
`Judgment has been served on Russell M. Spence, Jr., The Spence Law Firm by forwarding said
`
`ie
`
`e(@spence.law, beeman@spence.law, and
`copy on October 3, 2023, via email to: spenc
`
`
`
`Date: October 3, 2023
`
`inner and Associates
`
`