ESTTA Tracking number:
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`ESTTA1408981
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`Filing date:
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`01/17/2025
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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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`91295502
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`Party
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`Correspondence
`address
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`Defendant
`Abigail Ottley
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`ROSEZENA J. PIERCE
`R.J. PIERCE LAW GROUP, P.C.
`205 N. MICHIGAN
`SUITE 810
`CHICAGO, IL 60601
`UNITED STATES
`Primary email: legal@rjpiercelaw.com
`Secondary email(s): info@rjpiercelaw.com, oscar@rjpiercelaw.com, ant-
`oinette@rjpiercelaw.com, rosezena@rjpiercelaw.com
`312-973-3872
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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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`Antoinette Martin
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`antoinette@rjpiercelaw.com
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`/Antoinette Martin/
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`01/17/2025
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`Attachments
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`AnswerESTHIE BOSS 91295502.pdf(94324 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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`HUGO BOSS AG,
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`OPPOSER,
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`APPLICANT.
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` ) Opposition No. 91295502
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` Mark: ESTHIE BOSS
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` Serial No.: 98141913
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`Abigail Ottley,
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`v.
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`ANSWER TO OPPOSITION
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`APPLICANT STATES IN RESPONSE, Applicant DENIES that the Opposer will
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`be damaged by the registration of the Applicant’s Mark.
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`1. Applicant ADMITS allegations contained in paragraph 1.
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`2. Applicant ADMITS allegations contained in paragraph 2.
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`3. Applicant ADMITS allegations contained in paragraph 3.
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`4. Applicant ADMITS allegations contained in paragraph 4.
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`5. Applicant ADMITS allegations contained in paragraph 5.
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`6. Applicant LACKS INFORMATION to admit or deny the allegations
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`contained in paragraph 6.
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`7. Applicant LACKS INFORMATION to admit or deny the allegations
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`contained in paragraph 7.
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`8. Applicant LACKS INFORMATION to admit or deny the allegations
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`contained in paragraph 8.
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`9. Applicant LACKS INFORMATION to admit or deny the allegations
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`contained in paragraph 9.
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`10. Applicant LACKS INFORMATION to admit or deny the allegations
`contained in paragraph 10.
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`11. Applicant LACKS INFORMATION to admit or deny the allegations
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`contained in paragraph 11.
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`12. Applicant LACKS INFORMATION to admit or deny the allegations
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`contained in paragraph 12.
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`13. Applicant DENIES allegations contained in paragraph 13.
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`14. Applicant repeats the provided answers to every allegation set forth
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`in Paragraphs 1 through 13.
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`15. Applicant ADMITS allegations contained in paragraph 15.
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`16. Applicant LACKS INFORMATION to admit or deny the allegations
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`contained in paragraph 16.
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`17. Applicant DENIES allegations contained in paragraph 17.
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`18. Applicant DENIES allegations contained in paragraph 18.
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`19. Applicant ADMITS allegations contained in paragraph 19.
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`20. Applicant DENIES allegations contained in paragraph 20.
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`21. Applicant DENIES allegations contained in paragraph 21.
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`22. Applicant DENIES allegations contained in paragraph 22.
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`23. Applicant DENIES allegations contained in paragraph 23.
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`24. Applicant DENIES allegations contained in paragraph 24.
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`25. Applicant DENIES allegations contained in paragraph 25.
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`26. Applicant DENIES allegations contained in paragraph 26.
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`27. Applicant DENIES allegations contained in paragraph 27.
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`28. Applicant DENIES allegations contained in paragraph 28.
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`29. Applicant repeats the provided answers to every allegation set forth
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`in Paragraphs 1 through 28.
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`30. Applicant LACKS INFORMATION to admit or deny the allegations
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`contained in paragraph 30.
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`31. Applicant DENIES allegations contained in paragraph 31.
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`32. Applicant DENIES allegations contained in paragraph 32.
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`33. Applicant DENIES allegations contained in paragraph 33.
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`34. Applicant DENIES allegations contained in paragraph 34.
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`35. Applicant DENIES allegations contained in paragraph 35.
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`AFFIRMATIVE DEFENSES
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`Applicant alleges and asserts the following defenses in response to the allegations
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`in the Notice of Opposition. In addition to the defenses described below, Applicant
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`specifically reserves all rights to allege additional defenses that become known through
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`the course of discovery. For its separate defenses to the Notice of Opposition, Applicant
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`alleges as follows:
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`1. The Notice of Opposition fails to state a claim upon which relief can be
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`granted.
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`2. There is no likelihood of confusion, mistake, or deception between Opposer’s
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`marks and Applicant’s mark as Esthie Boss is sufficiently distinct from Hugo
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`Boss’s marks and Applicant’s mark has its own distinct commercial
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`impression.
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`3. Applicant’s mark and Opposer’s marks are not likely to disparage or falsely
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`suggest a trade connection between Opposer and Applicant.
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` WHEREFORE, the Applicant believes that there is no likelihood of confusion
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`between the Applicant's mark and any marks asserted by the Opposer.
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`Date: January 17, 2025
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`Respectfully Submitted,
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`/Antoinette Martin/
`Antoinette Martin
`GA Bar No. 382936
`Attorney for Applicant
`R.J. Pierce Law Group, P.C.
`205 N. Michigan
`Suite 810
`Chicago, IL 60601
`antoinette@rjpiercelaw.com
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the foregoing was served, via email, on
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`Respondent’s attorney of record:
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`SIXTINE LAURE BOUSQUET-LAMBERT
`HUGO BOSS
`55 WATER STREET
`NEW YORK, NY 10041
`UNITED STATES
`sixtine_bousquet-lambert@hugoboss.com, Sixtine_Bousquet-
`Lambert@hugoboss.com, luisa_schwabe@hugoboss.com,
`legal_department@hugoboss.com
`Phone: 9126011791
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`Date: January 17, 2025
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`Respectfully Submitted,
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`/Antoinette Martin/
`Antoinette Martin
`GA Bar No. 382936
`Attorney for Applicant
`R.J. Pierce Law Group, P.C.
`205 N. Michigan
`Suite 810
`Chicago, IL 60601
`antoinette@rjpiercelaw.com
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