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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`JON L. NORINSBERG,
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`Petitioner,
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`v.
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`CONSOLIDATED
`CANCELLATION
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`PROCEEDINGS:
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`CANCELLATION NO. 92044641
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`JUST ENTERPRISES, INC.,
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`CANCELLATION NO. 92044772
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`Respondent-Registrant.
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`JUST ENTERPRISES, INC.,
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`Petitioner,
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`v.
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`JON L. NORINSBERG,
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`Respondent-Registrant.
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`ANSWERS TO JUST ENTERPRISES’
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`FIRST SET OF INTERROGATORIES
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`TO JON L. NORINSBERG
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`Jon L. Norinsberg, by and through his attorneys, Wildman, Harrold, Allen & Dixon LLP,
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`as and for his answer to Just Enterprises’ Interrogatories, states as follows:
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`GENERAL OBJECTIONS
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`Norinsberg expressly incorporates all of the General Objections set forth below into each
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`of the following to the Interrogatories. Any specific objections provided below are made in
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`addition to these General Objections and a failure to reiterate a General Objection below does
`/1T-"*T—‘%“‘T
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`Norinsberg Answers to lnterrogatories
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`IllllllIllll|||||l||||||||||||||||ll|||||||l||||||
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`O2-1 6-2006
`U.S. Patent & TMOfcITM Mail Rcpt D1. #26
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`5:
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`Cancellation No. No. 92,044,641
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`Page 2
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`not constitute a waiver or limitation of that or any other objection. To the extent that Norinsberg
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`states that he will provide information or produce documents responsive to any interrogatory,
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`that statement is made subject to, and without waiver or limitation of, all specific objections
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`stated in response to that interrogatory and all General Objections set forth below.
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`A.
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`By responding to these interrogatories, Norinsberg does not waive or intend to
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`waive: (i) any objections as to the competency, relevancy, materiality, or admissibility as
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`evidence, for any purpose, of any documents or information produced in response to these
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`interrogatories; (ii) the right to object on any ground to the use of the documents or information
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`produced in response to these interrogatories at any hearing or trial; (iii) the right to object on
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`any ground at any time to a demand for further responses to these interrogatories; or (iv) the right
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`at any time to revise, correct, add to, supplement, or clarify any of the responses contained
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`herein.
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`B.
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`By responding to these interrogatories, Norinsberg does not waive or intend to
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`waive any privilege, for any purpose, of any documents or information produced in response to
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`these interrogatories, and, in particular, Norinsberg objects to each interrogatory to the extent
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`that it purports to seek information protected by the attorney-client privilege, work-product
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`doctrine, common-interest doctrine, joint-defense privilege, or any other applicable privileges or
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`protections. If necessary and required, Norinsberg will produce a timely privilege log in
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`accordance with the applicable rules.
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`C.
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`By responding that it will produce information or documents in response to a
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`particular interrogatory, Norinsberg does not assert that it has responsive information, documents
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`or materials or that such materials exist, but asserts only that it will conduct a reasonable search
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`Norinsberg Answers to lnterrogatories
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`2
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`Cancellation No. No. 92,044,641
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`and make available responsive, non-privileged information or documents. No objection, or lack
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`thereof, is an admission by Norinsberg as to the existence or non-existence of any information or
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`documents.
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`D.
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`These responses are based on Norinsberg’s investigation to date of those sources
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`within his control where he reasonably believes responsive documents or information may exist.
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`Norinsberg reserves the right to amend or supplement these responses, in accordance with the
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`applicable rules with additional information, documents, or objections that may become
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`available or come to Norinsberg’s attention, and to rely upon such information, documents, or
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`objections in any hearing, trial or other proceeding in this litigation.
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`E.
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`Norinsberg objects to Just Enterprises’ “Instructions and Definitions” to the extent
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`that they purport to expand upon or alter Norinsberg’s obligations under the Federal Rules of
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`Civil Procedure.
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`F.
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`Norinsberg objects to these interrogatories to the extent that they purport to
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`require the production of information or documents not in Norinsberg’s custody or control,
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`publicly available information or documents, information or documents equally available to Just
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`Enterprises or information or documents more appropriately sought from third parties to whom
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`subpoenas or requests could be or have been directed.
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`INTERROGATORY ANSWERS
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`INTERROGATORY NO. 1
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`Describe the nature of Norinsberg’s business,
`licensees.
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`including business conducted through
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Without waiver of the forgoing and General Objections, Norinsberg
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`Norinsberg Answers to lnterrogatories
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`3
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`

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`responds that he has used the mark (212) JUSTICE to advertise and promote his civil
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`rights law practice in New York. Norinsberg does not license the (212) JUSTICE mark
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`to any third parties.
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`INTERROGATORY NO. 2
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`Describe in detail each of Norinsberg’s Services that Norinsberg offers under each of
`Norinsberg’s Marks in the U.S., delineating each service provided under each individual mark.
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` : Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that he uses the (212) JUSTICE to advertise and promote his civil rights law
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`practice in New York.
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`INTERROGATORY NO. 3
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`For Norinsberg’s Services in connection with which Norinsberg has at any time used any
`of Norinsberg’s Marks:
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`state the date when and geographic location where each of Norinsberg’s Marks
`(a)
`was first used in commerce in the United States.
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`describe the circumstances of such first use, including the manner of use, the
`(b)
`details of any sale or other provision of service involved, the type and/or class of customers, and
`the trade, sale and/or distribution channels;
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`state whether the use of each of Norinsberg’s Marks has changed in any respect
`(c)
`since the first use and describe all such changes; and
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`state the date of the last sale or other provision of Norinsberg’s Services under
`((1)
`each of Norinsberg’s Marks in the U.S.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Without waiver of the forgoing and General
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`Objections, Norinsberg responds that he first used (212) JUSTICE in commerce in
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`Norinsberg Answers to lnterrogatories
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`4
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`Cancellation No. No. 92,044,641
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`September 1998 and that he has continuously advertised with this mark since September
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`1998. Norinsberg has advertised with the (212) JUSTICE mark both in newspapers and
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`magazines, as well as on television and in movie theaters. Norinsberg initially used the
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`(212) JUSTICE mark to generate both personal injury and civil rights cases. At present,
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`Norinsberg uses the (212) IUSTICE mark exclusively for the purpose of generating civil
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`rights cases, and has done so for approximately six years. The (212) IUSTICE mark has
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`not changed at all since its first use in September 1998.
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`INTERROGATORY NO. 4
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`in the design, wording,
`Describe each alteration that has been made, or proposed,
`presentation or use of each of Norinsberg’s Marks for any reason, including as a result of the
`findings of any search or investigation, and give the circumstances surrounding each such
`alteration or proposed alteration.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Norinsberg further objects to this request to the
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`extent that it calls for information that is subject to the attomey-client privilege and work
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`product doctrine. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that there have been no alterations to the (212) JUSTICE mark since its first use
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`in September 1998.
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`INTERROGATORY NO. 5
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`Indicate each state, territory or possession of the United States in which Norinsberg has
`advertised, provided, or sold any of Norinsberg’s Services under each of Norinsberg’s Marks.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`Norinsberg Answers to Intenogatories
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`5
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`

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`Cancellation No. No. 92,044,641
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`Page 6
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`confidential proprietary information. Without waiver of the forgoing and General
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`Objections, Norinsberg responds that he has used the (212) JUSTICE mark exclusively
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`within the United States.
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`INTERROGATORY NO. 6
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`Describe in detail Norinsberg’s selection and adoption of each of Norinsberg’s Marks
`including, without limitation, the date of adoption, the reasons for and process used in selecting
`and adopting each of Norinsberg’s Marks, all details as to the origin of each of Norinsberg’s
`Marks, and the meaning or impression intended to be conveyed by each of Norinsberg’s Marks.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Norinsberg further objects to this request to the
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`extent that it calls for information that is subject to the attorney-client privilege and work
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`product doctrine. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that he selected the mark (212) IUSTICE in July 1998. The reason for adopting
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`this mark was to help advertise and promote Norinsberg’s civil rights and personal injury
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`law practice.
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`INTERROGATORY NO. 7
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`Identify all persons having any knowledge or responsibility, directly or indirectly,
`relating to any applications, assignments, or other documents filed with the United States Patent
`and Trademark Office, or any state agency or office, to register each of Norinsberg’s Marks.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg further objects to this request to the extent that it calls
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`for information that is subject to the attorney-client privilege and work product doctrine.
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`Without waiver of the forgoing and General Objections, Norinsberg identifies Jon L.
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`Norinsberg Answers to Interrogatories
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`6
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`Cancellation No. No. 92,044,641‘
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`Page 7
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`Norinsberg, Jordan & Hamburg, Bruce Hamburg, Thomas Furth, Wildman, Harrold,
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`Allen & Dixon, and Bryan Sugar.
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`INTERROGATORY NO. 8
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`including the Internet,
`type of media in the United States,
`Describe in detail all
`publications, radio and television, where Norinsberg has advertised Norinsberg’s Services, and
`state the U.S. dollar amounts, by type of media and by date, which have been expended by
`Norinsberg in promoting, advertising, or offering Norinsberg’s Services for each calendar year
`from the date of first use of each of Norinsberg’s Marks to the present.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Norinsberg further objects to this request to the
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`extent that it calls for information that is subject to the attomey-client privilege and work
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`product doctrine. Without waiver of the forgoing’ and General Objections, Norinsberg
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`responds that he has advertised (212) JUSTICE in newspapers and magazines, as well as
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`on TV, in movie theaters and on the Internet.
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`INTERROGATORY NO. 9
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`For each of Norinsberg’s Services state, by U.S. dollar volume, the amount of sales in the
`United States of Norinsberg’s Services under each of Norinsberg’s Marks for each calendar year
`from the date of first use of each of Norinsberg’s Marks to the present.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Norinsberg further objects to this request to the
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`extent that it calls for information that is subject to the attorney-client privilege and work
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`product doctrine. Without waiver of the forgoing and General Objections, Norinsberg
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`Norinsberg Answers to Interrogatories
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`7
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`

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`Cancellation No. No. 92,044,641
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`Page 8
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`responds that the legal services offered by Norinsberg are rendered on a contingency
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`basis and therefore cannot be calculated as an “amount of sales.”
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`INTERROGATORY NO. 10
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`tag, wrapper,
`label,
`including each different
`Identify each item of printed matter,
`container, advertisement, promotional brochure, web site, and the like, which contains or bears
`any of Norinsberg’s Marks in any manner or form, and which is used in connection with the sale,
`offering for sale, provision, advertising, or marketing of Norinsberg’s Services in the U.S. from
`the date of first use to the present.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that
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`the (212) IUSTICE mark has appearediin advertisements,
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`letterhead,
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`business cards and brochures.
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`INTERROGATORY NO. 11
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`tag, wrapper,
`label,
`including each different
`Identify each item of printed matter,
`container, advertisement, promotional brochure, web site and the like, on which Norinsberg uses
`the mark (212)IUSTICE alone or with one or more other letters or words in the U.S., and each
`such item for each of the other Norinsberg’s Marks.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that Norinsberg uses the (212) JUSTICE mark in print ads in local newspapers
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`and over the Internet.
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`INTERROGATORY NO. 12
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`Describe with particularity the channels of trade through which Norinsberg’s Services are
`sold, offered for sale, advertised, provided, or marketed in the U.S.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Without waiver of the forgoing and General
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`Norinsberg Answers to Interrogatories
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`8
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`

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`Cancellation No. No. 92,044,641
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`92,044,772
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`Page 9
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`Objections, Norinsberg responds that he uses the (212) JUSTICE mark in print ads in
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`local newspapers.
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`INTERROGATORY NO. 13
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`Describe with particularity all classes of customers that have purchased or otherwise used
`Norinsberg’s Services in the U.S., and all targeted classes of customers for Norinsberg’s Services
`in the U.S.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Without waiver of the forgoing and General
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`Objections Norinsberg responds that he services those individuals whose civil rights have
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`been violated by the New York City Police Department.
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`INTERROGATORY NO. 14
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`For Norinsberg’s Services,
`Norinsberg’s:
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`identify the individuals who are most
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`familiar with
`
`(a)
`
`(b)
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`(c)
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`(d)
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`advertising and promotion of the Services identified by each of Norinsberg’s
`Marks in the U.S.;
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`enforcement and maintenance of trademark rights in each of Norinsberg’s Marks
`in the U.S.;
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`sale or provision of the Services identified by each of Norinsberg’s Marks in the
`U.S.; and
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`trade channels through which the Services identified by each of Norinsberg’s
`Marks are and have been distributed and sold in the U.S.
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`ANSWER: Norinsberg objects to this request to the extent that it calls for information
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`that is subject to the attomey-client privilege and work product doctrine. Without waiver
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`’ of the forgoing and General Objections, Norinsberg responds that Jon L. Norinsberg is
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`Norinsberg Answers to lnterrogatories
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`the individual most familiar with the information requested in each of the above
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`categories.
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`INTERROGATORY NO. 15
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`Describe any instances of actual confusion or false association between Norinsberg’s
`Mark (212) JUSTICE and JEI’s Marks, and any instances on confusion or false association
`between any other of Norinsberg’s Marks and JEI’s Marks. For illustrative purposes only, and
`without limiting the foregoing, such instances would include misdirected mail, e-mail messages,
`telephone calls, inquiries, requests for information, or customer complaints.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Norinsberg further objects to this request to the
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`extent that it calls for information that is subject to the attomey-client privilege and work
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`product doctrine. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that he is not aware of any instances of actual confusion of false association
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`between Norinsberg’s Mark (212) JUSTICE and JEI’s Marks.
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`INTERROGATORY NO. 16
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`instances in which Norinsberg has objected to the use, registration, or
`Describe all
`application for registration by any third party of any mark containing the term “JUSTICE” or any
`similar mark.
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`ANSWER: Norinsberg objects to this request to the extent that it calls for confidential
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`proprietary information. Norinsberg further objects to this request to the extent that it
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`calls for information that is subject to the attomey-client privilege and work product
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`doctrine. Without waiver of the forgoing and General Objections, Norinsberg responds
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`that not withstanding this proceeding, Norinsberg has not objected to the use registration
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`Norinsberg Answers to lnterrogatories
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`Cancellation No. No. 92,044,641
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`or application for registration by any third party of any mark containing the term
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`“JUSTICE” or any similar mark.
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`INTERROGATORY NO. 17
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`Describe all instances in which Norinsberg’s use, registration, or application to register a
`mark containing the term “JUSTICE” or any similar mark has been the subject of an objection of
`any kind by a third party.
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`ANSWER: Norinsberg objects to this request to the extent that it calls for confidential
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`proprietary information. Norinsberg further objects to this request to the extent that it
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`calls for information that is subject to the attomey-client privilege and work product
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`doctrine. Without waiver of the forgoing and General Objections, Norinsberg responds
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`that Harvey L. Walner and Associates, Ltd. brought an infiingement action in the
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`Northern District of Illinois related to the marks 312 JUSTICE and DIAL 312 JUSTICE.
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`INTERROGATORY NO. 18
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`Identify all parties to any agreements or understandings relating to the sale, provision, or
`distribution of any Services identified by each of Norinsberg’s Marks,
`including, without
`limitation, all license agreements.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Norinsberg further objects to this request to the
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`extent that it calls for information that is subject to the attomey-client privilege and work
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`product doctrine. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that he has entered into a license agreement with Harvey L. Walner &
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`Associates, Ltd.
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`Norinsberg Answers to Interrogatories
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`1 1
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`Cancellation No. No. 92,044,641
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`92,044,772
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`Page 12
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`INTERROGATORY NO. 19
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`State whether Norinsberg has ever entered into any agreements or understandings
`(a)
`constituting or relating to the settlement or resolution, or attempted settlement or resolution, of
`any controversy concerning any of Norinsberg’s Marks.
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`(b)
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`Identify all the parties to the understandings or agreements.
`
` : Norinsberg objects to this request to the extent that it calls for confidential
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`proprietary information. Norinsberg further objects to this request to the extent that it
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`calls for information that is subject to the attorney-client privilege and work product
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`doctrine. Without waiver of the forgoing and General Objections, Norinsberg responds
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`that he has entered into a settlement and license agreement with Harvey L. Walner &
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`Associates, Ltd.
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`INTERROGATORY NO. 20
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`With the exception of this proceeding, describe each civil action or administrative
`proceeding in the United States or elsewhere in which Norinsberg is now or has ever been a
`party and that has involved any of Norinsberg’s Marks, including, but not limited to, proceedings
`where the issues of the ownership of and/or the right to the use of Norinsberg’s Marks was
`raised.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Norinsberg further objects to this request to the
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`extent that it calls for information that is subject to the attomey-client privilege and work
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`product doctrine. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that Harvey L. Walner and Associates, Ltd. brought an infringement action in
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`the Northern District of Illinois related to the marks 312 JUSTICE and DIAL 312
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`JUSTICE.
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`Norinsberg Answers to Interrogatories
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`Cancellation No. No. 92,044,641
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`92,044,772
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`Page 13
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`INTERROGATORY NO. 21
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`Identify all information and documents regarding all studies that refer or relate to the
`1
`proposed or actual sale, marketing, provision, or advertising of Norinsberg’s Services in
`commerce, including, without limitation, all advertising studies, consumer studies and market
`research studies.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
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`confidential proprietary information. Norinsberg further objects to this request to the
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`extent that it calls for information that is subject to the attomey-client privilege and work
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`product doctrine. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that there is no such information or documents.
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`INTERROGATORY NO. 22
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`Identify all periods of time, no matter how short, during which each of Norinsberg’s
`Marks was @ used in connection with or to advertise or provide Norinsberg’s Services in the
`United States and set forth in detail the reason for such non-use and the reasons for resumption
`of use, if any.
`If use has been continuous, identify any and all documents and things that
`establish such continuous use of each of Norinsberg’s Marks.
`If Norinsberg has intentionally
`ceased use of any of Norinsberg’s Marks altogether, so state for the record and provide the
`reasons for and date of such cessation.
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`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
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`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
`
`confidential proprietary information. Norinsberg further objects to this request to the
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`extent that it calls for information that is subject to the attomey-client privilege and work
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`product doctrine. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that the (212) JUSTICE mark has been in continuous use since September 1998.
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`Norinsberg Answers to Interrogatories
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`1 3
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`

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`Cancellation No. No. 92,044,641
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`92,044,772
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`Page 14
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`INTERROGATORY NO. 23
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`Identify each person whom Norinsberg intends to call or use as a witness in this
`proceeding,
`including, but not limited to, expert witnesses, and describe the nature of each
`witness’s expected testimony during Norinsberg’s testimony period.
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`ANSWER: Norinsberg objects to this request to the extent that it calls for information
`
`that is subject to the attorney-client privilege and work product doctrine. Without waiver
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`of the forgoing and General Objections, Norinsberg responds that he has not yet decided
`
`who he intends to call or use as a witness.
`
`INTERROGATORY NO. 24
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`that Norinsberg intends to introduce into evidence in this
`Identify each document
`proceeding, and each and every document upon which Norinsberg has relied in responding to the
`foregoing Interrogatories.
`
`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
`
`unduly burdensome. Norinsberg objects to this request to the extent that it calls for
`
`confidential proprietary information. Norinsberg further objects to this request to the
`
`extent that it calls for information that is subject to the attomey-client privilege and work
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`product doctrine. Without waiver of the forgoing and General Objections, Norinsberg
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`responds that he has not yet decided which documents he intends to introduce into
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`evidence.
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`INTERROGATORY NO. 25
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`regarding any and all documents
`to the extent possible,
`information,
`Identify all
`responsive to the foregoing Interrogatories that are lost, destroyed or are otherwise no longer in
`the custody or control of Norinsberg.
`
`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
`
`unduly burdensome. Norinsberg further objects to this request to the extent that it calls
`
`for information that is subject to the attomey-client privilege and work product doctrine.
`
`Norinsberg Answers to Interrogatories
`
`14
`
`

`
`Cancellation No. No. 92,044,641
`
`92,044,772
`
`Page 15
`
`Without waiver of the forgoing and General Objections, Norinsberg responds that he no
`
`longer has access to the original website for (212) IUSTICE, which was in existence for
`
`approximately three years, from 1999 to 2002. Norinsberg further states that he no
`
`longer has possession of the original
`
`(212)
`
`JUSTICE TV commercial,
`
`filmed
`
`approximately in the year 2000. A significant portion of the original TV commercial was
`
`retained, and later incorporated into, a revised (212) JUSTICE TV commercial made in
`
`2003.
`
`INTERROGATORY NO. 26
`
`Indicate whether Norinsberg has ever had any contact with Harvey L. Walner or his law
`firm H.L. Walner & Associates, or any attorneys representing Mr. Walner or his firm, and, if so,
`identify the dates and circumstances surrounding each such contact.
`
`ANSWER: Norinsberg objects to this request on the basis that it is overly broad and
`
`unduly burdensome. Norinsberg further objects to this request to the extent that it calls
`
`for information that is subject to the attorney-client privilege and work product doctrine.
`
`Without waiver of the forgoing and General Objections, Norinsberg responds that
`
`attorneys acting on Norinsberg’s behalf have had contacts with legal representatives for
`
`Harvey L. Walner and/or Harvey L. Walner & Associates. These contacts took place
`
`over a one-year period, from October 2004 to October 2005.
`
`Respectfully submitted,
`
`
`
`Attorneys 6r Jon L. Norinsberg
`
`
`
`Norinsberg Answers to Interrogatorics
`
`15
`
`

`
`Cancellation No. No. 92,044,641
`
`92,044,772
`
`Page 16
`
`Bryan P. Sugar
`WILDMAN, HARROLD, ALLEN & DIXON LLP
`225 West Wacker Drive
`
`Chicago, IL 60606-1229
`(312) 201-2000
`Facsimile: (312) 201-2555
`
`Norinsberg Answers to Interrogatories
`
`

`
`FEB-14-2886
`
`13585
`
`LRN OFFICES
`
`212 496 5393
`
`F’-E12/U2
`
`Cancellation No. No. 92,044,641
`92,044,772
`Page 17
`
`VERIFICATION
`
`I Jon L. Norinsberg, under penalty of perjury, state that I have read the foregoing
`
`Answers to Just Enteqpxises’ First Set Of Interrogatories To Jon L. Norinsberg and that I believe
`
`the facts contained in them to be true to the best of my knowledge, except as to those matters
`
`stated upon information and belief and, as to those matters, I believe them to be true to the best
`
`of my knowledge.
`
`L. Non'11s erg
`
`Nurinsbctgmswerstolntcrrogatorics
`
`1 7
`
`TFITQI P . I719
`
`

`
`CERTIFICATE OF SERVICE
`
`1, Bryan P. Sugar, counsel for respondent, hereby certify that copies of ANSWERS TO
`
`JUST ENTERPRISES’ FIRST SET OF INTERROGATORIES TO JOHN L. NORINSBERG
`
`and RESPONSESETO JUST ENTERPRISES’ FIRST REQUESTS FOR PRODUCTION OF
`
`DOCUMENTS TO JON L. NORINSBERG were served on this 14th day of February, 2006, on
`
`Susan Neuberger Weller, Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., Suite 900,
`
`12020 Sunset Hills Road, Reston, VA 20190, by first class mail, postage prepaid.
`
`
`
`
`
`Bryan P. Sugar
`
`1633429

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