Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA280282
`ESTTA Tracking number:
`04/25/2009
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`92049784
`Defendant
`Toytrackerz LLC
`Toytrackerz LLC
`Terri Lynn Coop
`302 South Lowman Street
`Fort Scott, KS 66701
`UNITED STATES
`circlexranch@sbcglobal.net
`Motion for Summary Judgment
`Terri Lynn Coop
`circlexranch@sbcglobal.net
`/Terri Lynn Coop/
`04/25/2009
`ttabsumjudgment1.pdf ( 8 pages )(28506 bytes )
`Ex1KoehlerWebsite.pdf ( 30 pages )(2237530 bytes )
`Ex2Koehlerebay.pdf ( 3 pages )(75699 bytes )
`Ex3KoehlerEmail.pdf ( 2 pages )(132934 bytes )
`Ex4BBConsentJudge.pdf ( 2 pages )(47087 bytes )
`Ex5KansasOrder.pdf ( 32 pages )(102417 bytes )
`Ex6KoehlerTROresponse.pdf ( 12 pages )(51019 bytes )
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`
`In the matter of Cancellation Proceeding No.: 92049784
`
`In the matter of trademark Registration No: 3178499, 3413412, 3197601
`
`For the mark: Johnny West Adventure , ABest of the West@, AJed Gibson@
`
`Jill Koehler
`An Individual
`
`vs.
`
`Toytrackerz LLC
`A Kansas Limited Liability Company
`
`
`
`MOTION FOR SUMMARY JUDGMENT
`
`
`
`COMES NOW the Respondent, Toytrackerz LLC, and respectfully submits the following
`
`Motion for Summary Judgment. In support of this motion, respondent states the following:
`
`STATEMENT OF UNCONTROVERTED FACTS
`
`1.
`
`It is uncontroverted that Koehler is a trademark licensee of American Plastic Equipment,
`
`Inc. as of April of 2006.
`
`SOURCE: Exhibits 1, 2, 3 and accompanying affidavits showing Koehler’s public
`
`assertions that she is a licensee of American Plastic Equipment, Inc. regarding the
`
`trademarks at issue in this cause of action. Also Exhibit 6, a Koehler pleading filed in the
`
`District of Kansas ceding trademark ownership to American Plastic.
`
`2.
`
`It is uncontroverted that American Plastic Equipment, Inc. entered into a consent
`
`agreement with Toytrackerz in the District Court of Bourbon County Kansas stating it
`
`had no protectible or actionable interest in a series of disputed trademarks. This consent
`
`1
`
`
`
`

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`agreement was dated August 1, 2007.
`
`
`
`SOURCE:
`
`Exhibit 4, a copy of the executed consent agreement bearing the signature
`
`of the presiding judge and the file stamp of the Bourbon County Court Clerk.
`
`3.
`
`It is uncontroverted that in the District of Kansas, case number 2:07-cv-2253, that all of
`
`American’s trademark related counts, including the trademarks listed above, were
`
`dismissed, with prejudice, on the grounds of res judicata, collateral estoppel and failure to
`
`maintain a compulsory counterclaim. This opinion is dated March 1, 2008.
`
`SOURCE:
`
`Exhibit 5, District of Kansas opinion dated March 1, 2008.
`
`
`
`
`
`MEMORANDUM IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT
`
`The standard for granting summary judgment is familiar. Summary judgment is
`
`appropriate if, Athere is no genuine issue as to any material fact and . . . the moving party is
`
`entitled to a judgment as a matter of law.@ Thomas v. Wichita Coca-Cola Bottling Co., 968 F.2d
`
`1022, 1024 (10th Cir. 1992). Furthermore, Athe plain language of Rule 56(c) mandates the entry
`
`of summary judgment . . . against a party who fails to make a showing sufficient to establish the
`
`existence of an element essential to that party=s case, and on which that party will bear the
`
`burden of proof at trial.@ Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). In other words, if
`
`the party cannot establish an essential element of their claim, Athere can be no genuine issue as
`
`to any material fact, since a complete failure of proof concerning an essential element of the
`
`nonmoving party=s case necessarily renders all other facts immaterial.@ Id. at 323.
`
`Section 14 of the trademark statute “has been interpreted as requiring a cancellation
`
`petitioner to show (1) that it possesses standing to challenge the continued presence on the
`
`2
`
`
`
`

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`register of the subject registration and (2) that there is a valid ground why the registrant is not
`
`entitled under law to maintain the registration.” Young v. AGB Corp., 152 F.3d 1377, 1379 (Fed.
`
`Cir. 1998), Lipton Indus., Inc. v. Ralston Purina Co., 670 F.2d 1024, 1026 ( C.C.P.A. 1982).
`
`The court further said that the Lanham Act rule that a person who believes they may be damaged
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`by the continued registration of a trademark must “prove that the registered mark was likely to
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`cause confusion with a mark in which the petitioner has superior rights . . . If the petitioner was
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`unable to establish such damage, the petition for cancellation would be dismissed even in
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`instances of [other grounds for cancellation]. Lipton, at 1026 (emphasis added).
`
`In this unusual case, judgment as a matter of law should be granted to respondent,
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`because there is no set of facts under which Koehler can prove that she has superior rights to the
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`trademarks. Failure to prove this element obviates her standing as a cancellation petitioner. As
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`this requires the Board to consider matters that Koehler neglected to include in her pleadings,
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`respondent is filing this as a motion for summary judgment under Fed. R. Civ. P. 56 rather than
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`Fed. R. Civ. P. 12(b).
`
`
`
`Koehler, as a licensee of American Plastic Equipment, cannot claim to be the senior user.
`
`1.
`
`
`Koehler claims to be ‘senior user’ of the three trademarks. However, what she does not
`
`say is that since April of 2006, Koehler has been operating and marketing her goods under a
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`license from American Plastic Equipment, Inc. [Ex. 1, Ex. 2, Ex. 3]. Koehler conveniently omits
`
`this relevant and material fact from her petition, despite the Board’s sua sponte opportunity to
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`amend. For the reasons stated below, the existence of the trademark license obviates Koehler’s
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`standing as a cancellation petitioner.
`
`3
`
`
`
`

`
`A.
`
`Koehler’s common law use-in-commerce claims merged into her license.
`
`
`
`Any common law rights Koehler may have established, which respondents deny, were
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`extinguished when she entered into the license with American Plastic Equipment (American).
`
`The courts have called this the ‘merger rule’ and stated, “A licensee’s prior claims of any
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`independent rights to a trademark are lost, or merged into the license, when he accepts his
`
`position as licensee, thereby acknowledging the licensor owns the marks and that his rights are
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`derived from the licensor and ensure to the benefit of the licensor.” Bunn-O-Matic Corp. v.
`
`Bunn Coffee Serv., Inc. 88 F.Supp 2d 914, 923 (C.D. Ill. 2000). See also, Dress For Success
`
`Worldwide v. Dress 4 Success, #08-Civ-6744, page 16 (S.D.N.Y. 12-5-2008), Hot Stuff Foods,
`
`LLC v. Mean Gene’s Enters., 468 F.Supp.2d 1078, 1095 (D.S.D. 2006), Nat’l Board of YWCA v.
`
`YWCA of Charleston, 335 F.Supp. 615 (D.S.C. 1971), U.S. Jaycees v. S.F. Junion Chamber of
`
`Commerce, 354 F.Supp. 61, 72 (N.D. Cal. 1972). This rule of law has been applied in an
`
`unbroken string of cases dating back to 1940. See, e.g. Grand Lodge Improved v. Eureka Lodge,
`
`114 F.2d 46, 48 (4th Cir. 1940).
`
`
`
`The application of the merger rule is appropriate in this case. Koehler seeks to cancel
`
`respondent’s registrations based on an allegation of fraud that respondents knew that Koehler
`
`had superior rights. Respondent denies this contention and states that it had a subjective good
`
`faith belief that, when it signed its registration applications, that no other party had superior
`
`rights. Koehler, by entering into the licensing agreement, concedes that she did not have
`
`superior rights. This negates an element of her fraud claim, to-wit: that Toytrackerz ‘knew’ she
`
`had superior rights.
`
`The Board in Yocum summed it up nicely, “the statement of an applicant that no other
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`4
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`

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`person ‘to the best of his knowledge’ has the right to use the mark does no require the applicant
`
`to disclose those person whom he may have heard are using the mark if he feels that the rights of
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`such others are not superior to his.” Yocum v. Covington, 216 USPQ 210, 216 (TTAB 1982).
`
`Respondent, after due diligence, concluded that no other user had superior rights, and were
`
`correct, because Koehler clearly did not believe she had rights to the trademarks otherwise she
`
`would have not entered into the license with American Plastic.
`
`Koehler’s double-dealing continues to this day. In one of her pleadings from the first-
`
`filed case currently before the District of Kansas, Koehler, in her own words and under her own
`
`signature states: “Defendant Koehler still maintains the belief that American Plastic is the
`
`rightful owner of all referenced trademarks. This does not negate the fact that Koehler can
`
`prove prior and concurrent use of the referenced trademarks to the Plaintiff’s [sic] first claimed
`
`dates of use in commerce. Under the right of prior use, Defendant Koehler claims the right to
`
`use all of the referenced trademarks lawfully and legitimately in commerce.” [Ex. 4, page 10,
`
`paragraph e].
`
`
`
`Koehler offers no legal authority for this statement. Wishful thinking aside and despite
`
`her wish to have her cake and eat it too, the ‘merger rule’ negates Koehler’s claims of prior and
`
`concurrent use of the referenced trademarks. Koehler offered no legal authority that gets around
`
`this doctrine that has been accepted widely across several federal districts as recently as
`
`December of 2008. See, e.g. Dress For Success, at 16.
`
`Koehler’s entry into the licensing agreement negates any question of material fact about
`
`her rights, negates an essential element of her claim, and makes summary judgment for the
`
`5
`
`respondent appropriate.
`
`
`
`

`
`B.
`
`Koehler, as a licensee, cannot assert rights in the trademarks against other parties.
`
`A trademark licensee cannot maintain an action for infringement in its own name without
`
`a joinder of the licensor. Assn. of CO-OP Members v. Farmland Ind., 684 F.2d 1134, 1143 (5th
`
`Cir. 1982), Marrero Enter. of Palm Beach v. Estefan Enter., #06-81036-CIV, page 4 (S.D. Fla.
`
`11-29-2007). The prima facie elements of infringement are similar to cancellation. The movant
`
`must show an actionable interest in the trademark and that the respondent’s actions have, or
`
`could, cause damage to the movant. See, e.g. Young, at 1379, and Lipton, at 1026.
`
`Consequently, Koehler, in her position as a licensee of American cannot proceed alone in
`
`an action for cancellation as she cannot show sufficient actionable interest in the trademarks. As
`
`of the date of her license, all rights she may have claimed merged into that license and all of her
`
`claimed rights to the trademarks now flow from that license. As a result, Koehler cannot make
`
`an essential element of her claim – standing – and summary judgment for respondent is
`
`appropriate.
`
`C.
`
`American and its privies are legally barred from asserting trademark rights.
`
`
`
`Through a mutually held interest in a property right, a trademark licensee is in privity
`
`with a licensor. The concept of privity has changed little in over a hundred years. In 1887, the
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`Supreme Court in Litchfield, stated “[T]he term privity denotes mutual or successive relationship
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`to the same rights of property. The ground, therefore, upon which persons standing in this
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`relation to the litigating party are bound by the proceedings to which he was a party is, that they
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`are identified with him in interest; and whenever this identity is found to exist, all are alike
`
`concluded. Hence, all privies, . . . in law, are estopped from litigating that which is conclusive on
`
`him with whom they are in privity.” Litchfield v. Goodnow, 123 U.S. 549, 551 (1887).
`
`6
`
`
`
`

`
`
`
`In the district court of Bourbon County on August 1, 2007, American Plastic entered into
`
`a consent agreement stating it had no protectible or actionable rights in the disputed trademarks.
`
` [Ex. 5] This surrender and abandonment of protectible rights in the trademarks was affirmed on
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`March 31, 2008 by the District of Kansas in 2:07-cv-2253 when that court dismissed, with
`
`prejudice, all of American’s infringement claims against plaintiffs – including the trademarks in
`
`this action. These counts were dismissed on the grounds of collateral estoppel, res judicata, and
`
`failure to maintain a compulsory counterclaim. [Ex. 6] Under the doctrine of collateral estoppel,
`
`the issue of ownership is settled and cannot be litigated again. Consequently, American, and by
`
`privity, Koehler, are permanently enjoined and estopped from asserting any ownership rights in
`
`the disputed trademarks against Toytrackerz. As a result of the District of Kansas decision,
`
`American, and by privity, Koehler, cannot establish that it has superior rights that would be
`
`damaged by continuing registration of the trademarks. This petition by Koehler is a collateral
`
`attack on the District of Kansas ruling and, as Koehler is a privy of American, is barred from
`
`making that attack by res judicata and collateral estoppel. Consequently, Koehler cannot make
`
`an essential element of her claim – standing – and summary judgment in favor of respondent is
`
`appropriate.
`
`CONCLUSION
`
`
`
`What started out as a motion to dismiss based on the license merger rule quickly grew to
`
`expand matters conveniently omitted from the pleadings by Koehler. Namely, her entry into a
`
`trademark license with American Plastic and the results of three years of litigation with
`
`American Plastic over these trademarks. Koehler attempts a collateral attack on these decisions,
`
`all of which were against American, by remaking herself into the ‘senior user’ and launching
`
`7
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`
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`

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`these cancellations. However, as a privy to American, she is as bound by the decisions as is her
`
`licensor. She is also bound by the rule of law regarding license merger. In her pleadings before
`
`the District of Kansas she attempts to cover her position by saying “American is the owner” and
`
`“I am the owner.” The truth is that both of those statements are false. Koehler cannot establish a
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`criticial and threshold element of her claim, that she has superior rights subject to damage by
`
`respondent’s registration. Hence, summary judgment in favor of respondent is proper, along
`
`with any other equitable relief the Board deems proper.
`
`
`
`
`
`/Terri Lynn Coop/
`Terri Lynn Coop
`Owner - Toytrackerz LLC
`302 South Lowman Street
`Fort Scott KS 66701
`620-215-3512
`circlexranch@sbcglobal.net
`
`
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`
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`
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`
`
`
`CERTIFICATE OF SERVICE
`
`
`I, Terri Lynn Coop, hereby certify that a true and complete copy of the foregoing Motion for
`Summary Judgment has been served on Jill Koehler by mailing said copy on the 25th day of
`April 2009, via First Class Mail, postage prepaid to:
`
`Jill Koehler
`403 Rankin Dr
`Englewood, OH 45322-1141
`
`
`
`
`
`
`
`
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`
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`
`
`
`/Terri Lynn Coop/
`Terri Lynn Coop
`Owner - Toytrackerz LLC
`302 South Lowman Street
`Fort Scott KS 66701
`620-215-3512
`circlexranch@sbcglobal.net
`
`8
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`
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`
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`

`
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`Ell-iii.
`
`

`
`
`
`
`
`More F.O.J is on the way!
`Keep an eye out here and on the Friends of
`Johnny site for updates. New items from original
`Marx molds are being produced and will be
`available for purchase very soon. Some of the
`items will be exclusives-available only through
`Koehler Customs!
`
`

`
`
`
`Bush Tours America To Survey Damage Caused By His Disastrous Presidency
`
`Check out The Onion for a good laugh-we all need one these days.
`
`Hi everyone. I have decided to take the summer
`off, as of June 1/08, and will not be doing custom
`orders until the fall. Feel free to contact me with
`any requests though, in the meanwhile, and be
`sure to check eBay for auctions. Have a happy
`summer!
`
`
`
`
`
`Welcome to Koehler Customs, the
`source for custom boxes, horses and
`custom heads!
` Hello everyone, I am Jill Koehler. I owned Johnny West figures and horses as
`a child, and rediscovered my childhood collection in November of 2003. I
`
`

`
`decided, at that time, to add to my existing figures and horses, and established
`an extensive collection. I also fell into customizing Marx horses, and have some
`of the photos of completed horses here in the Custom Horses page.
`
`Since April 2006, I have had the privilege of being the only person licensed to
`create custom and reproduction Marx boxes.
`
`I have a legal contract with American Plastic Equipment, Inc., the rightful
`owner of the Marx trademarks and copyrights, and I pay royalties on every
`item of approved Marx reproduction merchandise I sell.
`
`All custom items from Koehler Customs are created with high quality materials and
`exacting standards. The boxes I create are not just scanned from vintage boxes, but
`additionally, the graphics have been cleaned up so the boxes appear as new as the
`day they first appeared on store shelves three decades ago. Each box ordered is
`individually hand crafted-there is no mass production here.
`All boxes are replicated to look exactly like the vintage boxes, in the various styles
`that Marx produced in the past. The manuals are replicated from vintage manuals.
`Quality and customer satisfaction are my highest priority. Your
`satisfaction is guaranteed.
`
`
`WE ACCEPT
`
`Click on photos to go to each respective page.
` Custom Horses Custom Figures
`Custom Boxes
`
`

`
`
`
`
`
`
`
` Marx for Sale Personal
`Stuff
`
`
`
`
`
`
`
`
`
`

`
`
`
`
`
` Darkness Follows
`
`I am very happy to say that I have finally completed the novel I have been
`writing for the past 12 years, that I started when my son James was 18
`months old. I have had it published in hardcover at Lulu Publishing, and it
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`
`I have also decided to make it more affordable and accessible by offering
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`Darkness Follows digital download-737 pages
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`
`Synopsis
`
`WARNING: novel contains graphic and explicit sexual content, violence, and strong
`language.
`
`Darkness Follows is a novel about a young man trying to come to terms with the
`
`

`
`physical, sexual and emotional abuse suffered at the hands of his father, at a time, in
`the late 1800’s, when there were no government agencies protecting children against
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`home with his younger brother James in tow, seeking sanctuary for them both.
`James is the one shining beacon in Bay’s personal darkness, and the brothers’
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`George Carlson, where they finally acquire decent lodgings and three square meals a
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`
`
`
`Free Wallpapers! Click HERE:
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`
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`
`
`Check out my eBay listings for vintage items for sale.
`
`
`
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`
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`

`
`
`
`You can purchase items directly from
`this website!
`
`
`
`
`
`Thanks to all my friends and customers who are supporting me in my
`new eBay venture. ;) Here are some feedback comments from a few of my
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`
`Super item, marvelous and creative craftsmanship, great shipping and service A+
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`WOW!! Items are great. Excellent service. A++++++++++++
`VERY NICE BOX YOU DO GOOD WORK THANKS AAAAA+++++
`JILL'S REPRO AND ORIGINAL BOXES ARE SPECTACULAR!!!!!!!!!!!!!!!
`Excellent Quality and workmanship!!!!!****** True artist ! Gr8 Ebayer!
`The Repro box is amazing. I couldn't have asked for anything better. Thanks
`I'm a repeat! Buy with confidence! They're the best on Ebay!!!!!!!
`Excellent transaction! Boxes look great! Fast shipping! Packaged well!
`Thanks!
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`If you are interested in joining a really great group of people in
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`

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`their appreciation of the Johnny West line of action figures, come
`and join the JW Corral2, in Yahoo Groups.
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`Click to join jwcorral2
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`This site is © Jill Koehler - 2008
`Reproduction of any of the photos on this site is strictly prohibited.
`The Marx logo and all related copyrights and trademarks belong to American Plastic Equipment, Inc. Used
`with permission.
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`This counter was started on July 19, 2006
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`Me and my Canadian Buckskin, circa 1971.
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` Home Custom Vintage Marx Custom Custom
`My Marx Personal Marx
` Boxes for Sale Horses Figures
`Collection Stuff! Trials
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`REPRODUCTION MARX BOXES
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`Prices stated on items below do not include shipping.
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`All box sets are constructed exactly as the originals were, with the same
`type of flaps, closures, etc. All sets include box and manual.
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`I have access to almost all of the Marx/Johnny West box templates. If
`there is anything you are looking for that you don't see here on this site,
`just contact me directly .
`
`Keep checking back for more photos soon to be added of additional items!
`Fort Apache Fighter Boxes
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` FAF Fighting Eagle $27.99
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` FAF Bill Buck $27.99
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` FAF Zeb Zachary $27.99
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` FAF Captain Maddox
`$27.99
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` FAF Geronimo $27.99
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` FAF Custer $27.99
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` Cactus Boxes
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`Cactus Fighting Eagle $27.99
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`Cactus Chief
`Cherokee
`$27.99
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` Cactus Garrett
`$27.99
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` Best of the West
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` BOTW Johnny West $29.99
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` BOTW Jane West $29.99
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` BOTW Sam Cobra $29.99
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` BOTW Sheriff Garrett $29.99
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`BOTW Custer $29.99
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`BOTW Maddox $29.99
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` BOTW Fighting Eagle $29.99
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` BOTW Chief Cherokee $29.99
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` BOTW Geronimo $29.99
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` BOTW Princess Wildflower $29.99
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` BOTW Josie West $24.99
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`BOTW Janice West $24.99
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`BOTW Jamie West $24.99
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`BOTW Jay West $24.99
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` Home Custom Vintage Marx Custom Custom
`My Marx Personal Marx
` Boxes for Sale Horses Figures
`Collection Stuff! Trials
`
`
`
`

`
`
`
`
`
`This site is © Jill Koehler - 2008
`Reproduction of any of the photos on this site is strictly prohibited.
`The Marx logo and all related copyrights and trademarks belong to American Plastic Equipment, Inc. Used
`with permission.
`
`

`
`
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` Home Custom Vintage Marx Custom Custom My Marx
`Personal Marx
` Boxes for Sale Horses Figures Collection
`Stuff! Trials
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`
`
`REPRODUCTION MARX BOXES
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`
`
`Prices stated on items below do not include shipping.
`
`All box sets are constructed exactly as the originals were, with the same type of flaps, closures, etc.
`All sets include box and manual.
`
`I have access to almost all of the Marx/Johnny West box templates. If there is anything you are
`looking for that you don't see here on this site, just contact me directly .
`
`Keep checking back for more photos soon to be added of additional items!
`
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`Johnny West Adventure Box/Manual Sets
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` JWA Jamie West $24.99
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` JWA Janice West $24.99
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` JWA Jay West $24.99
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` JWA Josie West $24.99
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` JWA Non-quick draw Johnny West $29.99
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`JWA Quick draw Johnny West $29.99
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` JWA Jed Gibson $29.99
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` JWA Fighting Eagle $29.99
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`JWA Captain Maddox $29.99
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` JWA Chief Cherokee $29.99
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` JWA Quick Draw Sam Cobra $29.99
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`NEW!!!
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` JWA non-Quick Draw Sam Cobra $29.99
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`NEW!!!
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` JWA Jane West $29.99
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`NEW!!!
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` JWA Geronimo $29.99
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`NEW!!!!
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` JWA Princess Wildflower $29.99
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`Mike Hazard, Double Agent box/manual $25.99
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` Original Scan Reproduction box
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`Girl from Uncle box/manual $29.99
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`United Kingdom Boxes
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`NEW! UK THUNDERBOLT BOX/MANUAL!
`Now available, thanks to Rhonda Riley, is the reproduction UK
`Thunderbolt box and manual. Order yours today!
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`UK Thunderbolt box/manual $39.99
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`UK FLAME BOX/MANUAL
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`UK Flame box/manual $39.99
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`I want to extend a special thanks to Rob from the UK for his help in obtaining box scans of the
`very hard to find vintage UK Fighting Eagle box. Thanks Rob!
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` UK Chief Cherokee box/manual $25.99 UK Fighting Eagle box/manual
`$25.99
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`UK Cowboy Kid box/manual $25.99
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`UK Heroes box/insert-your choice of vintage manual for your figure. $29.99
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`UK Jane West -box only $29.99
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`UK Johnny West box/manual $29.99
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`UK Johnty West box/manual $29.99
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`UK Wigwam box/manual $29.99 (Thank you Bruno!)
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`UK Mike Hazard box/manual $29.99 (Thanks Rob!)
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`Spanish Indian Canoe box and stickers $39.99
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`UK Indian Canoe box and stickers $39.99
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` Home Custom Vintage Marx Custom Custom My Marx Personal
`
`

`
`Marx
` Boxes for Sale Horses Figures Collection Stuff!
` Trials
`
`This site is © Jill Koehler - 2008
`Reproduction of any of the photos on this site is strictly prohibited.
`The Marx logo and all related copyrights and trademarks belong to American Plastic Equipment, Inc. Used with permission.
`
`
`
`

`
`
`
`Buy Sell My eBay Community Help
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