ESTTA Tracking number:
`
`Filing date:
`
`ESTTA1398889
`11/29/2024
`
`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
`
`Entity
`
`Address
`
`Attorney informa-
`tion
`
`NUCKL Gin, Ltd.
`
`BC Company
`
`Incorporated or
`registered in
`
`Canada
`
`460 E. 9TH ST.
`NORTH VANCOUVER, BC V7L2B4
`CANADA
`
`JEFFREY HERMAN
`LAW OFFICE OF JEFFREY HERMAN PLC
`7272 E. INDIAN SCHOOL RD SUITE 540
`SCOTTSDALE, AZ 85251
`UNITED STATES
`Primary email: jeffrey@jhermanlaw.com
`Secondary email(s): kevin@jhermanlaw.com
`480-852-1882
`
`Docket no.
`
`LEBEL_P
`
`Applicant information
`
`Application no.
`
`98444589
`
`Opposition filing
`date
`
`Applicant
`
`11/29/2024
`
`Publication date
`
`10/29/2024
`
`Opposition period
`ends
`
`11/28/2024
`
`TRIKKI LTD
`LITTLE MANOR, PIPERS GREEN LANE
`EDGWARE, HA88DG
`UNITED KINGDOM
`
`Goods/services affected by opposition
`
`Class 014. First Use: None First Use In Commerce: None
`All goods and services in the class are opposed, namely: Amulets; Automatic watches; Earrings;
`Jewellery boxes; Jewellery chains; Key chains; Key rings; Medallions; Necklaces; Rings; Watch
`bands; Watches; Wristwatches
`
`Class 018. First Use: None First Use In Commerce: None
`All goods and services in the class are opposed, namely: All-purpose carrying bags; Card wallets;
`Carry-on bags; Leather purses; Luggage tags; Purses not made of precious metal; Small purses;
`Suitcases; Travel cases; Traveling bags; Wallets
`
`Class 025. First Use: Oct 15, 2023 First Use In Commerce: Mar 4, 2024
`All goods and services in the class are opposed, namely: Hoodies; Sweatshirts; T-shirts
`
`Grounds for opposition
`
`Priority and likelihood of confusion
`
`Deceptiveness
`
`Trademark Act Section 2(d)
`
`Trademark Act Section 2(a)
`
`
`
`Filing date:
`
`ESTTA1398889
`11/29/2024
`
`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
`
`Entity
`
`Address
`
`Attorney informa-
`tion
`
`NUCKL Gin, Ltd.
`
`BC Company
`
`Incorporated or
`registered in
`
`Canada
`
`460 E. 9TH ST.
`NORTH VANCOUVER, BC V7L2B4
`CANADA
`
`JEFFREY HERMAN
`LAW OFFICE OF JEFFREY HERMAN PLC
`7272 E. INDIAN SCHOOL RD SUITE 540
`SCOTTSDALE, AZ 85251
`UNITED STATES
`Primary email: jeffrey@jhermanlaw.com
`Secondary email(s): kevin@jhermanlaw.com
`480-852-1882
`
`Docket no.
`
`LEBEL_P
`
`Applicant information
`
`Application no.
`
`98444589
`
`Opposition filing
`date
`
`Applicant
`
`11/29/2024
`
`Publication date
`
`10/29/2024
`
`Opposition period
`ends
`
`11/28/2024
`
`TRIKKI LTD
`LITTLE MANOR, PIPERS GREEN LANE
`EDGWARE, HA88DG
`UNITED KINGDOM
`
`Goods/services affected by opposition
`
`Class 014. First Use: None First Use In Commerce: None
`All goods and services in the class are opposed, namely: Amulets; Automatic watches; Earrings;
`Jewellery boxes; Jewellery chains; Key chains; Key rings; Medallions; Necklaces; Rings; Watch
`bands; Watches; Wristwatches
`
`Class 018. First Use: None First Use In Commerce: None
`All goods and services in the class are opposed, namely: All-purpose carrying bags; Card wallets;
`Carry-on bags; Leather purses; Luggage tags; Purses not made of precious metal; Small purses;
`Suitcases; Travel cases; Traveling bags; Wallets
`
`Class 025. First Use: Oct 15, 2023 First Use In Commerce: Mar 4, 2024
`All goods and services in the class are opposed, namely: Hoodies; Sweatshirts; T-shirts
`
`Grounds for opposition
`
`Priority and likelihood of confusion
`
`Deceptiveness
`
`Trademark Act Section 2(d)
`
`Trademark Act Section 2(a)
`
`
`
`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.
`
`98448279
`
`Application date
`
`03/13/2024
`
`Registration date
`
`NONE
`
`Word mark
`
`Design mark
`
`NUCKL
`
`Foreign priority
`date
`
`NONE
`
`Description of
`mark
`
`Goods/services
`
`NONE
`
`Class 003. First use: First Use: None First Use In Commerce: None
`Cologne; Aftershave cologne; Eau de toilette and eau de cologne; Eau-
`de-cologne; Perfumes, aftershaves and colognes
`Class 025. First use: First Use: None First Use In Commerce: None
`Hats; Hoodies; Shorts; Sweatpants; Toques; Long-sleeved shirts; Shirts; T-shirts
`Class 033. First use: First Use: None First Use In Commerce: None
`Gin; Alcoholic beverages except beers; Distilled alcoholic beverages
`
`Attachments
`
`98448279#TMSN.png( bytes )
`Notice of Opposition re Nuckl.pdf(229222 bytes )
`EXHIBIT A Part1.pdf(6034347 bytes )
`EXHIBIT A Part2.pdf(6034181 bytes )
`EXHIBIT A Part3.pdf(6088060 bytes )
`EXHIBIT A Part4.pdf(4262165 bytes )
`EXHIBIT A Part5.pdf(2451428 bytes )
`EXHIBIT B and C.pdf(5780804 bytes )
`
`Signature
`
`Name
`
`Date
`
`/Jeffrey Herman/
`
`Jeffrey Herman
`
`11/29/2024
`
`
`
`Jeffrey R. Herman
`Law Office of Jeffrey Herman, PLC
`7272 E. Indian School Rd. Ste. 540
`Scottsdale, AZ 85251
`Tel: (480) 852-1882
`jeffrey@jhermanlaw.com
`kevin@jhermanlaw.com
`Attorney for Opposer
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`NUCKL Gin Ltd., a Canadian Corporation,
`Opposer,
`
`v.
`
`Opposition No.
`
`TRIKKI Ltd., a UK Private Limited Company
`Applicant.
`
`NOTICE OF OPPOSITION
`
`In the matter of U.S. Trademark Application Serial No. 98444589 (the “Present Application”),
`
`NUCKL Gin Ltd., a Canadian Corporation having a business address of 460 E. 9th St., North
`
`Vancouver, British Columbia, CA V7L2B4 (“Opposer”), believes it is or will be damaged by the
`
`registration of the Present Application for “NUCKL” (hereinafter, “Applicant’s Mark”), filed by
`
`TRIKKI Ltd., a UK Private Limited Company with an address of Little Manor, Pipers Green Lane,
`
`Edgware, UK HA88DG (“Applicant”).
`
`Opposer, by and through its undersigned counsel, hereby opposes registration of Applicant’s
`
`Mark and, as grounds for its opposition, alleges the following:
`
`
`
`BACKGROUND
`
`1.
`
`The apparel industry is a highly competitive and rapidly evolving sector that spans
`
`from casual wear to luxury fashion. Companies within the industry invest substantial resources into
`
`developing their brand identity, including unique designs, and cultivating consumer loyalty and
`
`recognition. Trademarks serve a critical function within the apparel industry by serving as the primary
`
`means for a consumer to identify the source of the goods they purchase, helping ensure that their
`
`purchases meet expectations of quality and style. The apparel industry is one in which consumers are
`
`more prone to impulse purchases and are of overall low sophistication.
`
`2.
`
`Opposer is a long-standing creator and purveyor of casual and athletic apparel
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`products. At least as early as 2013, Opposer began using Opposer’s Mark on social media and appeared
`
`in famous magazines as shown in EXHIBIT C using the mark “NUCKL” to promote its apparel
`
`products.
`
`3.
`
`Opposer first began using its mark in commerce with apparel products in Canada in
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`2013, and in the United States as early as December 16, 2020.
`
`4.
`
`Opposer has purchased booths at events held by Ultimate Fighting Championship
`
`(“UFC”) and made sales to US customers. A copy of several of these invoices for US sales and
`
`evidence of the shipment of such products to the United States are shown at EXHIBIT A.
`
`5.
`
`Opposer has engaged in bona fide interstate commerce by selling goods under
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`Opposer’s Mark throughout the United States. Affidavits from the employees of Opposer’s business
`
`are provided as EXHIBIT B, attesting to the authenticity of the commercial transactions.
`
`6.
`
`Further, Opposer markets its apparel products via its website as well as through social
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`media on Facebook, Instagram, and X (formerly Twitter).
`
`
`
`7.
`
`According to the Present Application, Applicant’s claimed date of first use in
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`commerce is March 4, 2024 for apparel products.
`
`8.
`
`Opposer has continuously engaged in bona fide use o f Opposer’s Mark in commerce in
`
`The United States since at least as early as April 30, 2021.
`
`9.
`
`Opposer has expended significant time, effort, and money in developing, advertising,
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`and publicizing its apparel products under Opposer’s Mark.
`
`10.
`
`Opposer’s use of Opposer’s Mark in commerce has been sufficient to establish its U.S.
`
`Federal rights to the mark.
`
`11.
`
`Opposer filed an application on standard character mark “NUCKL” on March 13,
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`2024 (“Opposer’s Mark”), bearing serial number 98448279 for, in relevant part, International Class
`
`025 “Hats; Hoodies; Shorts; Sweatpants; Toques; Long-sleeved shirts; shirts; t-shirts.”
`
`12.
`
`Opposer’s bona fide use in commerce of Opposer’s Mark predates Applicant’s use in
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`commerce of Applicant’s Mark.
`
`13.
`
`All goods listed in Applicant’s Application, namely, International Classes 014 for
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`“amulets; automatic watches; earrings; jewelry boxes; jewelry chains; key chains; key rings; necklaces;
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`rings; watch bands; watches; wristwatches”, 018 for “all-purpose carrying bags; card wallets; carry-on
`
`bags; leather purses; luggage tags; purses not made of precious metal; small purses; suitcases; travel
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`cases; traveling bags; wallets”, 025 for “hoodies; sweatshirts; t-shirts”, constitute either analogous
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`goods to those named in Opposer’s Application, are natural areas of expansion for the goods named
`
`in Opposer’s Application, or are so closely associated with the goods named in Opposer’s Application
`
`as to support a likelihood of confusion with the named marks.
`
`14.
`
`Opposer engaged in continuous bona fide use of Opposer’s Mark in commerce for more
`
`than three years, related to apparel products, prior to said first use in commerce of Applicant’s Mark,
`
`and will suffer irreparable harm should Applicant’s Mark be permitted to register.
`
`
`
`COUNT ONE – LIKELIHOOD OF CONFUSION
`
`15.
`
`Opposer repeats and re-alleges each and every allegation set forth in the foregoing
`
`paragraphs as though fully set forth herein.
`
`16.
`
`Applicant’s Mark “NUCKL” is identical to Opposer’s Mark “NUCKL” in its unique
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`spelling, pronunciation, stylized font, and commercial impression, and is likely to cause confusion,
`
`mistake, or deception as to the origin or sponsorship of apparel and related products in connection
`
`with which the Marks are used or are intended to be used.
`
`17.
`
`Applicant’s Mark is likely to cause the mistaken belief that Applicant’s Goods
`
`originate with, are sponsored by, and/or are otherwise affiliated with Opposer.
`
`18.
`
`Applicant’s goods as set forth in the Present Application are the same as, similar to, or
`
`within the natural scope of expansion of Opposer’s goods and are or will be sold through the same
`
`or similar channels of trade in which Opposer’s goods or services are or will be sold.
`
`19.
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`Opposer engaged in bona fide use of Opposer’s Mark in commerce before both the
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`Present Application was filed, and approximately (39) thirty-nine months before Applicant’s listed use
`
`in commerce.
`
`20.
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`The identical nature of the Marks, and similarity in products, precludes any coexistence
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`or concurrent use agreement between Applicant and Opposer.
`
`21.
`
`On information and belief, both Applicant and Opposer predominantly market their
`
`respective products on the internet via e-commerce websites and on popular social media platforms.
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`22.
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`On information and belief, potential consumers reacting to an advertisement by
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`Applicant or Opposer will be confused as to the true source of the goods.
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`23.
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`Applicant’s Mark is a colorable imitation or misappropriation of Opposer’s Mark and
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`
`
`will enable Applicant to reap where it has not sown by trading on the goodwill of Opposer’s business
`
`as symbolized by Opposer’s Mark.
`
`24.
`
`Opposer has a personal stake in the outcome of this proceeding, as Applicant’s Mark,
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`if registered, is likely to cause irreparable loss, injury, and damage to Opposer’s business and to the
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`goodwill and reputation associated with Opposer’s Mark.
`
`COUNT TWO – BAD FAITH BY APPLICANT
`
`25.
`
`Opposer repeats and re-alleges each and every allegation set forth in the foregoing
`
`paragraphs as though fully set forth herein.
`
`26.
`
`On information and belief, Applicant knew of Opposer’s Mark and intended to copy
`
`it, due to the obvious and striking similarities of the name and stylized font, as shown below:
`
`Opposer’s Mark
`
`Applicant’s Mark
`
`27.
`
`On information and belief, Applicant failed to conduct a reasonably adequate
`
`trademark search, or otherwise culpably disregarded the risk of reverse confusion.
`
`28.
`
`On information and belief, Applicant adopted Applicant’s Mark with knowledge,
`
`actual or constructive, that it was Opposer’s Mark and that Applicant deliberately intended to push
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`Opposer out of the market by flooding the market with advertising to create reverse confusion.
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`29.
`
`On information and belief, Applicant adopted Applicant’s Mark deliberately to
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`capitalize on Opposer's Mark and thus cause and benefit from confusion.
`
`30.
`
`Applicant has no right to registration of Applicant’s Mark as Opposer’s Mark has
`
`senior rights and Applicant showed bad faith in intentionally choosing an identical mark which would
`
`
`
`cause confusion and by blatantly copying Opposer’s stylized font.
`
`31.
`
`On information and belief, Applicant knowingly submitted a false statement in its
`
`trademark application by declaring that “[t]o the best of the signatory’s knowledge and belief, no other
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`persons, except, if applicable, concurrent users, have the right to use this mark in commerce, either in
`
`the identical form or in such near resemblance as to be likely, when used on or in connection with the
`
`goods/services of such other persons, to cause confusion or mistake, or to deceive.”
`
`WHEREFORE, NUCKL Gin, Ltd., requests that Applicant’s Application bearing the Serial
`
`Number 98444589 be refused registration, and requests such further relief as the Trademark Trial and
`
`Appeal Board may deem appropriate.
`
`RESPECTFULLY SUBMITTED via ESTTA this 29th day of November, 2024.
`
`/Jeffrey R. Herman/
`
`Jeffrey R. Herman, Esq.
`Attorney of Record for Opposer
`Law Office of Jeffrey Herman, PLC.
`7272 E. Indian School Rd. Ste. 540
`Scottsdale, AZ 85251
`Telephone (480) 852-1882
`jeffrey@jhermanlaw.com
`keving@jhermanlaw.com
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that I have caused this NOTICE OF OPPOSITION to be electronically delivered
`
`this 29th day of November, 2024, to Applicant’s attorney of record, Marek Krizka, Sparring Legal
`
`LLP, 477 Madison Ave., 6th Floor, New York, New York 10022, at office@tramatm.com.
`
`Dated: 11/29/2024
`
` /Jeffrey R. Herman/
`
`Jeffrey R. Herman, Esq.
`Attorney of Record for Opposer
`Law Office of Jeffrey Herman, PLC.
`7272 E. Indian School Rd. Ste. 540
`Scottsdale, Arizona 85251
`Telephone (480) 852-1882
`jeffrey@jhermanlaw.com
`kevin@jhermanlaw.com
`
`
`
`EXHIBIT A
`EXHIBIT A
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`Nuckl Invoice No. 254 for apparel products to A. Johnson/Blackzillions at 7561 N. Federal Hwy
`Boca Raton, FL 33487
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`Nuckl Invoice No. 259 for apparel products to 4161 Sheila Crescent
`Las Vegas, NV 89003
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`Nuckl Invoice No. 267 for apparel products to J. Mercer at 501 Cricket Ln.
`Woodbridge, NJ 07095
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`Nuckl Invoice No. 270 to L-J at 28 Rocky Ridge Dr.
`Bellingham, WA 98229
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`Nuckl Invoice No. 275 to K.R. at 6417 Mt. Baker Hwy
`Deming, WA 98244
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`Nuckl Invoice No. 277 to K.R. at 6417 Mt. Baker Hwy
`Deming, WA 98244
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`Nuckl Invoice No. 280 to Performance Institute at 6650 S. Torrey Pines Dr.
`Las Vegas, NV 89118
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`Nuckl Invoice No. 282 to 3517 Dale Avenue
`Seattle, WA 98109
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`Nuckl Invoice No. 286 to K.R. at 6417 Mt Baker Hwy.
`Deming, WA 98244
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`Nuckl Invoice No. 288 to 1019 Granary Ave. Unit 201
`Bellingham, WA 98225
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`Nuckl Invoice No. 289 to 6417 Mt. Baker, Hwy 5
`Deming, WA 98244
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`Nuckl Invoice No. 294 to K.R. at 6417 Mt. Baker Hwy
`Deming, WA 98244
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`Nuckl Invoice No. 298 to K.R. at 6417 Mt. Baker Hwy
`Deming, WA 98244
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`Nuckl Invoice No. 505 to K.R. at 6417 Mt. Baker Hwy
`Deming, WA 98244
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`Bill of Lading from December 17, 2020, showing shipment to Black/Zillions
`referenced in Invoice No. 254
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`Bill of Lading from January 12, 2021, showing shipment to 4161 Shiela Crescent in Las Vegas, NV
`Referenced in Invoice No. 259
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`Bill of Lading from March 19, 2021, showing shipment to K.R.
`Referenced in Invoice No. 275
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`Bill of Lading from April 12, 2021 showing shipment to J. Mercer
`Referenced in Invoice No. 267
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`Bill of Lading from April 30, 2021, showing shipment to L-J
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`Referenced in Invoice No. 270
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`Bill of Lading from January 17, 2023, showing shipment to Performance Institute
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`Referenced in Invoice No. 280
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`EXHIBIT B
`EXHIBIT B
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`NUCKL GROUP INC.
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`460 East 9"Street
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`North Vancouver, BC
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`V7L 2B4
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`Canada
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`November21, 2024
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`Good Day,
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`My nameis Paul Le Bel, | am the president of Nuckl GroupInc. | am writing this letter regarding
`confirmation confirming that | help Nuckl GroupInc. with invoices/ladings for orders and
`promotional complimentary packages sent out in Canada and the USA.
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`We have been working hard in the Nuckl Brand and obtained our Canadian Trademark July 24,
`2013. We have sponsored many amateur and pro athletes in Canada, the USA and other
`countries,
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`We've been marketing our brand for over 10 years, promoting, sponsoring many sporting
`events and athletes throughout Canada and the USA. We have also donated manyof our
`products and sent out many promotional and complimentary packages throughout Canada, the
`USA and many othercountries.
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`Wenoticed our Nuckl Brand name etc... being copied in and around February/March, 2023 by a
`company called Trikki Ltd. They were going by Nuckl.co and noticed our Nucklfont logo and
`Nuckl inspirational words that they have now removedfrom their website Nuckl.co.
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`Notarized statement from Paul Le Bel, President of NUCKL Gin, Ltd.
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`Notarized statement of Elizabeth Patriquin, longtime employee of NUCKL Gin, Ltd.
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`EXHIBIT C
`EXHIBIT C
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`Screenshots of Opposer’s X (formerly twitter) account showing that the account
`was created in February of 2013 and posts from as early as 2017.
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`Screenshots of Opposer’s Facebook page showing the stylized font and images
`showing apparel branded with Opposer’s Mark.
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`Images of FIGHT! Magazine, in which an article shows a professional fighter
`wearing a shirt bearing Opposer’s Mark.
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`Additional images from Opposer’s social media pages showing Opposer’s Mark.
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