ESTTA Tracking number:
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`ESTTA1363441
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`Filing date:
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`06/06/2024
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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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`91291200
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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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`Defendant
`Lighthouse Enterprises Inc.
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`JACOB M. WARD
`WARD LAW OFFICE LLC
`120 1/2 SOUTH WASHINGTON ST, SUITE 207
`TIFFIN, OH 44883
`UNITED STATES
`Primary email: legal@wardpatent.com
`Secondary email(s): jenn@wardpatent.com, amy@wardpatent.com
`419-408-5500
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`Answer
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`/Amy E. Rinaldo/
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`jenn@wardpatent.com, legal@wardpatent.com, amy@wardpatent.com
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`/Amy E. Rinaldo/
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`06/06/2024
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`Attachments
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`73381-1 Answer to Notice of Opposition 06-06-24.pdf(173733 bytes )
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Cup of Joe, LLC,
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`v.
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`Lighthouse Enterprises Inc.,
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`Applicant
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`Opposer,
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`Application No.: 98/122,626
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` Filing Date: August 8, 2023
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`Mark: ZEND
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` Opposition No.: 91291200
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`ANSWER TO NOTICE OF OPPOSITION
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`Applicant Lighthouse Enterprises Inc. submits this Answer to the Notice of Opposition,
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`filed by Opposer Cup of Joe, LLC.
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`PREAMBLE: Applicant denies that Opposer is and will be damaged by the continued
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`registration of Applicant’s ZEND mark shown in U.S. Application Serial No. 98/122,626.
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`Applicant admits that it owns U.S. Application Serial No. 98/122,626, that it is a corporation in
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`the Country of Barbados with an address at Radley Court, Upper Collymore Rock, St. Michael,
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`Barbados 14004. Otherwise, Applicant does not have sufficient information to admit or deny the
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`remaining allegations in the PREAMBLE and therefore denies the same.
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`1.
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`Applicant is without sufficient information to admit or deny the allegations
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`contained in Paragraph 1 of the Opposition and, therefore denies the same.
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`2.
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`Applicant is without sufficient information to admit or deny the allegations
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`contained in Paragraph 2 of the Opposition and, therefore, denies the same.
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`3.
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`Applicant is without sufficient information to admit or deny the allegations
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`contained in Paragraph 3 of the Opposition and, therefore, denies the same.
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`4.
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`Applicant admits that Opposer has numerous trademark registrations, but
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`Application is without sufficient information to admit or deny the remaining allegations contained
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`in Paragraph 4 of the Opposition, and therefore denies the same.
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`5.
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`Applicant is without sufficient information to admit or deny the allegations
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`contained in Paragraph 5 of the Opposition and, therefore, denies the same.
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`6.
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`Applicant is without sufficient information to admit or deny the allegations
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`contained in Paragraph 6 of the Opposition and, therefore, denies the same.
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`7.
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`8.
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`Applicant admits the allegations contained in Paragraph 7 of the Opposition.
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`Applicant admits filing the application as shown in Paragraph 8, but Applicant
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`denies the remaining allegations included in Paragraph 8 of the Opposition.
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`9.
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`Applicant admits the allegations contained in Paragraph 9 of the Opposition.
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`10.
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`Applicant admits the allegations contained in Paragraph 10 of the Opposition.
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`11.
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`Applicant is without sufficient information to admit or deny the allegations
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`contained in Paragraph 11 of the Opposition and, therefore, denies the same.
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`12.
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`Applicant is without sufficient information to admit or deny the allegations
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`contained in Paragraph 12 of the Opposition and, therefore, denies the same.
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`13.
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`Applicant denies the allegations contained in Paragraph 13 of the Opposition.
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`14.
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`Applicant denies the allegations contained in Paragraph 14 of the Opposition.
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`15.
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`Applicant denies the allegations contained in Paragraph 15 of the Opposition.
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`16.
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`Applicant denies the allegations contained in Paragraph 16 of the Opposition.
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`17.
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`Applicant denies the allegations contained in Paragraph 17 of the Opposition.
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`18.
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`Applicant denies the allegations contained in Paragraph 18 of the Opposition.
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`19.
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`Applicant denies the allegations contained in Paragraph 19 of the Opposition.
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`20.
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`Applicant denies the allegations contained in Paragraph 20 of the Opposition.
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`Opposition No.: 91291200
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`73381-1
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`AFFIRMATIVE DEFENSES
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`Applicant reserves the right to amend its Answer to assert any and all affirmative defenses
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`as may be supported by the facts to be determined through full and complete discovery.
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`CONCLUSION
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`WHEREFORE, Applicant respectfully requests that the Opposition be dismissed with
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`prejudice.
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`Please recognize as the attorney for Lighthouse Enterprises Inc. in this proceeding, Jacob
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`M. Ward (a member of the bar of the state of Michigan), whose address is 120 ½ S. Washington
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`Street, Suite 207, Tiffin, Ohio 44883. Please address all communications to Jacob M. Ward at the
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`above address.
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`WARD LAW OFFICE LLC
`120 ½ S. Washington Street, Suite 207
`Tiffin, Ohio 44883
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`(419) 408-5500
`legal@wardpatent.com
`amy@wardpatent.com
`jenn@wardpatent.com
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`Dated: June 6, 2024
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`Respectfully submitted,
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`Jacob M. Ward
`Attorney for Applicant
`Michigan Bar Member
`419-408-5801
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and complete copy of the foregoing ANSWER TO NOTICE OF
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`OPPOSITION has been served on the following counsel of record for Opposer by forwarding said
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`copy
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`on
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`June
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`6,
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`2024,
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`via
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`email
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`to:
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`trademarkslv@dickinsonwright.com,
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`SLNorton@dickinsonwright.com, and JKrieger@dickinsonwright.com .
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`Dated: June 6, 2024
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`Opposition No.: 91291200
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` .
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`Jacob M. Ward
`Attorney for Applicant
`Michigan Bar Member
`419-408-5801
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`73381-1
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