ESTTA Tracking number:
`
`Filing date:
`
`ESTTA1312340
`09/26/2023
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Notice of Opposition
`
`Notice is hereby given that the following party opposes registration of the indicated application.
`
`Opposer information
`
`Name
`
`All-Fit Automotive, Inc.
`
`Granted to date
`of previous ex-
`tension
`
`Address
`
`Attorney informa-
`tion
`
`09/30/2023
`
`4475 ASHTON ROAD, UNIT F
`SARASOTA, FL 34233
`UNITED STATES
`
`ROBERT CURCIO
`DELIO PETERSON & CURCIO LLC
`700 STATE STREET, SUITE 402
`NEW HAVEN, CT 06511
`UNITED STATES
`Primary email: delpet@delpet.com
`Secondary email(s): efilings@delpet.com, bsullivan@delpet.com,
`rcurcio@delpet.com, bschlosser@delpet.com
`203-787-0595
`
`Docket no.
`
`ALLF901
`
`Applicant information
`
`Application no.
`
`97586344
`
`Opposition filing
`date
`
`Applicant
`
`09/26/2023
`
`Publication date
`
`08/01/2023
`
`Opposition period
`ends
`
`09/30/2023
`
`Dangleman Enterprises LLC
`61-278 KAMEHAMEHA HWY UNIT #3
`HALEIWA, HI 96712
`UNITED STATES
`
`Goods/services affected by opposition
`
`Class 012. First Use: None First Use In Commerce: None
`All goods and services in the class are opposed, namely: Wheel rim protectors for automobiles
`
`Grounds for opposition
`
`Priority and likelihood of confusion
`
`Trademark Act Section 2(d)
`
`Fraud on the USPTO
`
`In re Bose Corp., 580 F.3d 1240, 91 USPQ2d
`1938 (Fed. Cir. 2009)
`
`Mark cited by opposer as basis for opposition
`
`U.S. application
`no.
`
`98145906
`
`Application date
`
`08/23/2023
`
`

`

`Registration date
`
`NONE
`
`Foreign priority
`date
`
`NONE
`
`Word mark
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`Attachments
`
`RIM TRIM
`
`NONE
`
`Class 012. First use: First Use: Oct 31, 2017 First Use In Commerce: Oct 31,
`2017
`Vehicle wheel protection trim; Aftermarket automotive accessories
`
`ALLF901-Notice of Opposition 97586344.pdf(613834 bytes )
`Exhibit 1- Dangleman Linkedin.pdf(1826007 bytes )
`Exhibit 2- Rimblades Social Media.pdf(2256051 bytes )
`Exhibit 3- catalog copy.pdf(2335005 bytes )
`Exhibit 5- RIM TRIM TESS.pdf(1584639 bytes )
`Exhibit 4 - All-Fit Social Media copy.pdf(2328219 bytes )
`Exhibit 6 - Declaration of Anthony Dudon with Supporting Exhibits cop
`y2.pdf(5210031 bytes )
`Exhibit 7 - Serial No 97586344.pdf(1763180 bytes )
`Exhibit 8 Darren Bowden email to Allfit.pdf(811644 bytes )
`Exhibit 9 - Letter to Atty Fedde-.pdf(1698997 bytes )
`
`Signature
`
`/Robert Curcio/
`
`Name
`
`Date
`
`ROBERT CURCIO
`
`09/26/2023
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`All-Fit Automotive, Inc.,
`
`
`
`Opposer,
`
`
`
`
`
`
`
`
`
`
`
`
`
`v.
`
`Dangleman Enterprises LLC,
`
`
`
`
`
`
`
`
`
`Applicant.
`
`
`
`Opposition No.: __________________
`
`
`
`Serial No.: 97586344
`
`
`
`Mark:
`
`
`
`
`
`
`
`NOTICE OF OPPOSITION
`
`Commissioner for Trademarks
`P.O. Box 1451
`Alexandria, VA 22313-1451
`Dear Sir:
`All-Fit Automotive, Inc., a Florida corporation, located and doing business at 4475
`
`
`
`Ashton Road, Unit F, Sarasota FL, 34233, ("Opposer") believes that it will be damaged by the
`
`registration of U.S. Trademark Serial No. 97586344 (the "'344 Application") for the mark
`
`applied for by Dangleman Enterprises LLC, ("Applicant") and therefore opposes
`
`the same.
`
`
`
`As grounds for the opposition, it is alleged:
`
`1. By the '344 Application filed on September 10, 2022, Applicant seeks to obtain
`
`registration on the Principal Register for the trademark
`
`for "Wheel rims protectors for
`
`automobiles" in International Class 12.
`
`2. For reasons delineated herein, Opposer respectfully submits a registration of Applicant's
`
`mark is likely to cause confusion in the marketplace, when used on or in connection with the
`
`-1-
`
`

`

`goods and services as identified in the '344 Application, as to cause confusion, or cause mistake,
`
`or to deceive as to the affiliation, connection, or association within the meaning of Section 2(d)
`
`of the Trademark Act, 15 U.S.C. §1052(d).
`
`3. Opposer further submits that Applicant fraudulently represented, under notice of penalty
`
`of perjury (18 U.S.C. §1001), that Applicant had exclusive rights to use the mark in connection
`
`with the goods and services listed in the '344 Application, and that there were no other marks in
`
`such near resemblance thereto as to likely cause confusion.
`
`4. Since at least 2017, long before the filing date of the '344 Application, Opposer has been
`
`using, and continues to use the mark RIM TRIM in connection with the development, marketing,
`
`offering for sale, and selling of aftermarket automotive accessories, and more particularly,
`
`vehicle wheel protection trim, and Opposer has acquired distinctiveness in the mark as a source
`
`identifier for these goods. Every aftermarket vehicle wheel protection trim accessory of Opposer
`
`bears Opposer's RIM TRIM mark.
`
`5. Opposer relies on its extensive common law rights in its RIM TRIM mark throughout the
`
`United States. Since 2018, Opposer has sold over 1.5 million dollars' worth of goods under
`
`Opposer's RIM TRIM mark to consumers in all 50 states throughout the United States.
`
`6. Opposer's promotional activities include, among other things, attending trade shows
`
`nationwide and internationally, where Opposer's RIM TRIM mark is prominently featured.
`
`7. Examples of some of Opposer's promotional activities and events featuring Opposer's RIM
`
`TRIM mark are shown below:
`
`-2-
`
`

`

`Above: All-FIT's 2016 SEMA Show booth in Las Vegas; November 2, 2016 (annotated).
`
`
`
`Above: All-FIT's RIM TRIM mark displayed during a 2018 Tradeshow in Abu Dhabi.
`
`
`
`
`8. Applicant's principal, Adam Dangleman, was the owner of RimBladesUSA as early as
`
`2014. A true and correct copy of a screenshot of Adam Dangleman's LinkedIn page is attached as
`
`Exhibit 1.
`
`9. On information and belief, RimBladesUSA is the U.S. branch of Rimblades Ltd., a
`
`Private limited Company of the United Kingdom, having a place of business at Unit B11 Block
`
`B, Westpark, Wellington, Somerset, England, TA21 9FN.
`
`-3-
`
`

`

`10. On many occasions, including as early as the 2017 SEMA Show in Las Vegas, Opposer
`
`and Mr. Dangleman were in attendance at trade shows. At that time, upon information and belief,
`
`Mr. Dangleman was working in his capacity for RimBladesUSA and Rimblades Ltd. (collectively,
`
`"Rimblades"). Dangleman was aware of Opposer's presence at the 2017 SEMA show, and of
`
`Opposer's use of the RIM TRIM mark for wheel rim protectors. Attached as Exhibit 2 is a true and
`
`correct copy of a social media post promoting Mr. Dangleman's Rimblades booth at the 2017
`
`SEMA Show in Las Vegas.
`
`11. Opposer's RIM TRIM mark is the subject of substantial and continuous marketing and
`
`promotion by Opposer in connection with its line of aftermarket automotive accessories in the
`
`nature of wheel trim protectors. Attached as Exhibit 3 is a true and correct copy of a 2017 All-Fit
`
`Automotive Product Catalog which was distributed during the 2017 SEMA Show in Las Vegas,
`
`Nevada. The RIM TRIM products are identified on pages 4 and 9 of Exhibit 3.
`
`12. Opposer has and continues to widely market and promote its RIM TRIM mark in the
`
`industry and to consumers, by example, displaying the RIM TRIM mark extensively on its
`
`aftermarket automotive wheel trim protector accessories; on promotional and point of sale
`
`materials; in magazines and other industry publications; on the allfitautomotive.com website; on
`
`various social media webpages including Facebook, Instagram, YouTube, and X (formerly
`
`Twitter); and at trade shows (nationally and internationally). Attached as Exhibit 4 is a true and
`
`correct copy of screenshots of Opposer's various social media webpages.
`
`13. By virtue of Opposer's continuous and substantial use, Opposer has developed ample
`
`goodwill, strong common law rights, and acquired distinctiveness in the mark, and Opposer's
`
`RIM TRIM mark has become well-known, identifying Opposer as the source of these goods
`
`since well before the filing of Applicant's Intent-to-Use '344 Application. Opposer's RIM TRIM
`
`-4-
`
`

`

`mark is a global brand that has appeared on over 36,000 aftermarket automotive accessory wheel
`
`trim protection products and in extensive nationwide promotions. As a result, Opposer has built,
`
`at great expense and effort, valuable goodwill in its RIM TRIM mark. See, Exhibit 6, Declaration
`
`of Anthony Dudon, ¶ 15.
`
`14. The intrinsic connection between Opposer's unique RIM TRIM identifier and the
`
`intangible value (goodwill) associated with its reputation, trustworthiness, and overall standing
`
`in the marketplace, for the automotive accessory products such as wheel trim protectors,
`
`influences the buying habits of consumers. That is, when faced with a well-known and respected
`
`trademark, customers are more likely to trust that the product or service they are purchasing will
`
`meet their expectations in terms of quality and performance.
`
`15. In addition to the protection afforded Opposer by its extensive common law rights, and in
`
`view of Applicant's encroachment on, and attempted usurpation of, Opposer's trademark rights,
`
`on August 23, 2023 Opposer filed U.S. Trademark Serial No. 98145906 (the "'906 Application")
`
`for the mark RIM TRIM for "Vehicle wheel protection trim; Aftermarket automotive
`
`accessories" in International Class 12, for the purpose of confirming nationwide trademark
`
`coverage for its long-standing common law rights, for which Opposer has acquired
`
`distinctiveness over five years as a source identifier for wheel protection trim products under this
`
`mark. In the '906 Application, Opposer has established a date of first use of at least as early as
`
`October 31, 2017. A true and correct copy of the specifics of the '906 Application obtained from
`
`the PTO's TESS database is attached hereto as Exhibit 5 and made of record.
`
`16. Opposer's RIM TRIM mark has been used continually in interstate commerce since as
`
`early as 2017, such that, Opposer's RIM TRIM mark has acquired distinctiveness and has
`
`become distinctive in indicating Opposer as a source of origin for goods and services relating to
`
`-5-
`
`

`

`aftermarket automotive accessories long before Applicant's filing of its Intent-to-Use '344
`
`Application on September 10, 2022.
`
`17. As evidence that Opposer's RIM TRIM mark has acquired distinctiveness as an indicator
`
`of source, Anthony Dudon, President of Opposer All-Fit Automotive, Inc., has attached hereto as
`
`Exhibit 6 a signed declaration providing information and supporting exhibits showing the
`
`widespread use, promotion, and recognition of the RIM TRIM mark in connection with wheel
`
`rim protectors for automobiles.
`
`18. Opposer has continuously used the mark RIM TRIM since its inception in the
`
`marketplace, and has never abandoned the mark RIM TRIM or ceased using the mark with the
`
`intention not to use it again.
`
`19. Applicant's
`
`mark is confusingly similar to Opposer's RIM TRIM mark,
`
`incorporating Opposer's mark in its entirety therein, and the goods with which the marks are used
`
`are identical, likely causing confusion in the marketplace, and deceiving the consuming public as
`
`to the affiliation, connection, or association of Applicant with Opposer.
`
`20. The channels of trade in which the respective marks and goods of Opposer and Applicant
`
`are used are identical and/or overlapping. For instance, Applicant and Opposer sell competing
`
`products, and attend the same trade shows within the aftermarket automotive industry, including
`
`the annual SEMA Shows in Las Vegas, Nevada.
`
`21. Both Applicant's
`
`mark and Opposer's RIM TRIM mark include the identical
`
`term "RIM TRIM."
`
`22. The combination of the design with the words RIMTRIMS in the Intent-to-Use '344
`
`Application reinforces the singular impression conveyed by the mark as a whole, which is
`
`nothing more than the significance of "RIM TRIM."
`
`-6-
`
`

`

`23. The clear and dominant impression of both Applicant's
`
` mark and Opposer's
`
`RIM TRIM mark is the virtually-identical "RIM TRIM."
`
`24. Applicant's
`
`mark and Opposer's RIM TRIM mark are virtually identical in
`
`appearance, sound, meaning, and create essentially the same commercial impression when
`
`applied to aftermarket automotive accessories and/or vehicle wheel protection trim.
`
`25. Contemporaneous use of the marks
`
` and RIM TRIM are likely to cause
`
`confusion when applied to goods which, as respectively identified in Opposer's mark and the
`
`Intent-to-Use '344 Application, must be considered identical and/or closely related.
`
`
`
`26. For the above-cited reasons, Opposer would be injured, its goodwill damaged, and public
`
`confusion introduced into the marketplace, by the granting of the '344 Application.
`
`27. In the '344 Application, Applicant represented under notice of penalty of perjury (18
`
`U.S.C. §1001) that Applicant had exclusive rights to use the
`
`mark in connection with
`
`the goods listed in the '344 Application, and that there were no other marks in such near
`
`resemblance thereto as to be likely to cause confusion, mistake, or to deceive. A true and correct
`
`copy of the specifics of the '344 Application obtained from the PTO's TESS database is attached
`
`hereto as Exhibit 7 and made of record.
`
`28. At the time of the filing of the '344 Application, Applicant represented that there were no
`
`other marks in such near resemblance thereto as to be likely to cause confusion. See, Exhibit 7,
`
`p.8.
`
`29. Mr. Dangleman, as well as Mr. Dangleman's Attorney Kenton Fedde (signatory of the
`
`'344 Application), knew of Opposer's ownership and use of its RIM TRIM mark in view of
`
`Opposer's continuous and substantial use of the RIM TRIM mark before Applicant's filing of its
`
`-7-
`
`

`

`Intent-to-Use application on September 10, 2022. This knowledge is affirmed by an adverse,
`
`preexisting relationship established between Applicant and Opposer.
`
`30. As an illustrative example of Mr. Dangleman's and Attorney Fedde's prior knowledge of
`
`Opposer's mark RIM TRIM before Applicant's filing of its Intent-to-Use '344 Application,
`
`Rimblades Ltd., had previously acknowledged Opposer's ownership of the RIM TRIM mark in
`
`an August 2018 email to Opposer. In the correspondence, a principal of Rimblades, Darren
`
`Bowden alleged Opposer's RIM TRIM mark "breaches [Rimblades'] European Design Patent"
`
`and notes "[Opposer] will be taking [their] All Fit Rim Trim" to Automechanika in Frankfurt,
`
`where Rimblades and All-Fit would be featured "in the same hall." (emphasis added). A true and
`
`correct copy of Mr. Bowden's August 2018 email to Opposer (with phone number redactions) is
`
`attached hereto as Exhibit 8.
`
`31. As further evidence of Applicant's and Attorney Fedde's prior knowledge of Opposer's
`
`RIM TRIM mark before Applicant's filing of the '344 Application, in 2018 Opposer filed a
`
`Declaratory Judgment Action of non-infringement of U.S. Patent No. 7,296,860 for a wheel rim
`
`protector in United States District Court for the District of Connecticut (Civil Action No. 3:18-
`
`cv-01745). Mr. Dangleman is the sole inventor of U.S. Patent No. 7,296,860.
`
`32. On October 23, 2018, Opposer's counsel sent Attorney Fedde via certified mail a letter
`
`notifying Mr. Dangleman and RimBladesUSA LLC of the declaratory judgment action. A true
`
`and correct copy of the letter is attached hereto as Exhibit 9.
`
`33. The letter states, "[a]s Mr. Dangleman and RimBladesUSA, (collectively or
`
`independently) are aware, [C. Cowles & Co. d/b/a Cowles Products, and All-Fit Automotive,
`
`LLC] manufacture and sell automotive accessories including the "Rim Trim" product…Mr.
`
`Dangleman [has] threatened litigation … for patent infringement of U.S. Patent No. 7,296,860
`
`-8-
`
`

`

`due to the manufacturing, marketing, offering for sale, and selling of the Rim Trim product." See
`
`Exhibit 9 (emphasis added).
`
`34. The letter of Exhibit 9 evidences that Mr. Dangleman, RimBladesUSA, as well as
`
`Attorney Fedde, clearly knew of Opposer's ownership and use of Opposer's RIM TRIM mark
`
`years before the filing of the Intent-to-Use '344 Application on September 10, 2022.
`
`35. By failing to inform the PTO that its rights to the
`
`mark were not exclusive,
`
`Applicant acted in bad faith and with the intent to deceive.
`
`36. Applicant's representations to the PTO regarding its rights to the
`
`mark in
`
`connection with the goods listed in the '344 Application were false. As a result, Applicant's
`
`attempted procurement of a registration from the '344 Application is fraudulent and void, ab
`
`initio.
`
`37. Opposer is informed and believes that Applicant's filing date of the '344 Application on
`
`September 10, 2022 occurred well after Opposer's first use in U.S. interstate commerce of the
`
`RIM TRIM mark for its aforementioned goods.
`
`38. Opposer will be injured and its goodwill damaged by the registration of Applicant's
`
`mark, because aside from the introduction of Applicant's goods into the marketplace
`
`causing confusion, such registration would deceive the consuming public as to the affiliation,
`
`connection, or association of Applicant with Opposer, or as to the origin, sponsorship, or
`
`approval of Applicant's goods, services, or commercial activities by the Opposer, in violation of
`
`15 U.S.C. § 1125(a)(1)(A).
`
`39. Opposer respectfully requests that the registration sought by Applicant be refused.
`
`-9-
`
`

`

`40. Opposer has priority of use of its RIM TRIM mark in interstate commerce, and Opposer
`
`has acquired distinctiveness for Opposer's mark in the same channel of commerce as identified in
`
`the '344 Application.
`
`41. Opposer will be damaged by registration of the '344 Application in that the
`
`
`
`mark so resembles Opposers RIM TRIM mark in which Opposer owns common law trademark
`
`rights, as to be likely, when used on or in connection with the goods and services as identified in
`
`the '344 Application, as to cause confusion, or cause mistake, or to deceive within the meaning of
`
`Section 2(d) of the Trademark Act, 15 U.S.C. §1052(d).
`
`42. In view of Opposer's prior rights in its RIM TRIM mark, Applicant is not entitled to
`
`federal registration of the
`
`mark pursuant to Section 2(d) of the Trademark Act, 15
`
`U.S.C. §1052(d).
`
`43. In view of Applicant's fraudulent statements during procurement of the '344 Application,
`
`Applicant is not entitled to federal registration of the
`
`mark, insomuch as Applicant
`
`intentionally made material misrepresentations that it knew or should have known to be false or
`
`misleading, without any reasonable or honest belief that it was true.
`
`WHEREFORE, Opposer prays that U.S. Trademark Application Serial No. 97586344 be
`
`rejected and stricken, that no registration be issued thereon to Applicant, and that this Opposition
`
`be sustained in favor of Opposer.
`
`
`
`
`
`-10-
`
`

`

`Opposer submits herewith the requisite filing fee of $600.00. Please charge Deposit Account
`
`No. 040566 to cover any additional fees which may be required, or credit any overpayment to
`
`this account.
`
`
`
`Dated: September 26, 2023
`
`
`
`
`
`
`
`
`
`
`
`
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`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`By: /Robert Curcio/
`Robert Curcio
`By: /Brian Schlosser/
`Brian Schlosser
`DeLIO PETERSON & CURCIO LLC
`700 State Street, Suite 402
`New Haven, CT 06511
`rcurcio@delpet.com
`bschlosser@delpet.com
`efilings@delpet.com
`Telephone: (203) 787-0595
`Facsimile: (203) 757-5818
`Attorneys for Opposer,
`All-Fit Automotive, Inc.
`
`
`
`
`
`
`
`-11-
`
`

`

`CERTIFICATE OF SERVICE
`I hereby certify that a true and complete copy of the foregoing Notice of Opposition has
`
`
`
`been served on Applicant's counsel by mailing said copy on September 26, 2023 via electronic
`
`mail and First Class US Mail, postage prepaid to:
`
`Kenton Fedde
`THE FEDDE LAW FIRM
`18325 Allenton Woods CT
`Wildwood, Missouri 63069
`
`By:
`
`
`
`/Brian Schlosser/
`Brian Schlosser
`
`
`
`
`
`
`
`
`
`-12-
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 1
`
`Exhibit 1 Page 1 of 3
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
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`
`Exhibit 1 Page 2 of 3
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`hpmb kmatwcbma
`
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`
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`Exhibit 1 Page 3 of 3
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 2
`
`Exhibit 2 Page 1 of 2
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 2 Page 2 of 2
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3
`
`Exhibit 3 Page 1 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 2 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 3 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 4 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 5 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 6 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 7 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 8 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 9 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 10 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 11 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 12 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 13 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 14 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 15 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 16 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 3 Page 17 of 17
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 5
`
`Exhibit 5 Page 1 of 2
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
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`Exhibit 5 Page 2 of 2
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 4
`
`Exhibit 4 Page 1 of 7
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`For as
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`Exhibit 4 Page 2 of 7
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`For as
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`Exhibit 4 Page 3 of 7
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Lerr,2
`
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`
`Exhibit 4 Page 4 of 7
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`iVol Dok, couTu hkoD ewwhtTeSToDoTtR,
`
`Exhibit 4 Page 5 of 7
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 4 Page 6 of 7
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
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`Exhibit 4 Page 7 of 7
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 6 Page 1 of 5
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 6 Page 2 of 5
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 6 Page 3 of 5
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 6 Page 4 of 5
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit 6 Page 5 of 5
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit A
`
`Exhibit A Page 1 of 3
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit A Page 2 of 3
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit A Page 3 of 3
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit B
`
`Exhibit B Page 1 of 4
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit B Page 2 of 4
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit B Page 3 of 4
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit B Page 4 of 4
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C
`
`Exhibit C Page 1 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C Page 2 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C Page 3 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C Page 4 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C Page 5 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C Page 6 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C Page 7 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C Page 8 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C Page 9 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit C Page 10 of 10
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
`Exhibit D
`
`Exhibit D Page 1 of 4
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
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`Exhibit D Page 2 of 4
`
`

`

`TTAB Opposition No. ____________
`All-Fit Automotive, Inc. v. Dangleman Enterprises LLC
`
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