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`ESTTA Tracking number:
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`ESTTA1019117
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`Filing date:
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`11/30/2019
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding
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`92057485
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`Party
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`Correspondence
`Address
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`Defendant
`Juan Rodriguez
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`ERNESTO GARCIA
`WHO
`SAN AGUSTIN #837SILVIA Y FERNANDO
`PARRAGA-HAVANA, 00000
`CUBA
`asus@republicofcuba.life, cocaleafcompany@gmail.com, uremailcon-
`tact@gmail.com
`no phone number provided
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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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`Reply in Support of Motion
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`Juan Rodriguez
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`asus@coca.life
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`/JR/
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`11/30/2019
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`Attachments
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`Middlefinger.pdf(153305 bytes )
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` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`__________________________________
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`Cancellation Nos. 92057485
`____________________________________________________
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`
`JUAN RODRIGUEZ
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`&
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`ALBERTO SOLER-SOMOHANO
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`Registrants
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`v.
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`THE COCA-COLA COMPANY
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`Claimant.
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`__________________________________________
`REPLY TO COKE’S RESPONSE
`___________________________________________
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` COMES NOW the Registrants, moves by replying to Coke’s response of Nov.
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`29, 2019 [49].
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`COKE’S RESPONSE
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` 1. Coke response states that Registrant’s motion for relief from judgment does
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`not provide the relief they seek they didn’t even say which part of Rule 60(1) thru
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`(4) they seek to apply.
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` 2. Coke response also further stated that Registrants are in the position as
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`everyone else nothing special for requesting relief from judgment.
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` 3. Coke’s response adds that the Board w/o authority to consider the
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`constitution objection in the first place so the Rule 60 motion is meaningless.
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`REGISTRANT’S REPLY
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` 4. Coke’s representative response was just another of those pleadings being
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`filed to over bill their client since it’s obviously frivolous ridiculously.
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` 5. Registrants are the only one of all in their own position no one else position
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`raising the constitutional objection (2) times during the proceedings in 2014. June
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`24th, 2014 [25] and August 27th, 2014 [29]
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` 6. The issue raised was more compounded to the greatest extent to a
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`constitutional challenge than what it was upon the appointment clause challenge in
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`Arthrex, Inc, v. Smith & Nephew, 2018-2140 (Fed. Cir. Oct 31st, 2019).
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` 7. The Registrant said directly that the Board members must be a President
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`appointee Senate consented and why all of Registrant’s comments to them why
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`corrupted in the first place.
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` 8. Registrants don’t regret any of those comments to them 3 and 4 because it
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`was the truth and truth is unstoppable and those that can’t handle it, is simple since
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`them the ones doing the wrong in the first place.
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` 9. Extraordinary circumstances under Rule 60 is simple and why it applies here
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`and no matter not even applying at all what does apply is the law of the United
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`States Supreme Court directly on point.
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`2
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`“one who makes a timely challenge to the constitutional validity of the
`appointment of a n officer who adjudicates his case’ is entitled to relief.” That
`relief—“a new “hearing before a properly appointed’ official”
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`Lucia v. SEC, 138 S. Ct. 2044 (2018
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` 10. The Board does not cannot w/o authority to do that entertain any
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`constitutional objection is silly if that is really that, since in registrant current
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`proceeding #91232090 the Board did ruled on that and said they adopt the
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`government position in Arthrex about that. September 27th, 2019 Doc. 59 page.12
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` 11. What came about that Board adopting the Govt. position-the government got
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`the nob so the Board will be having mobs and Coke here got the finger.
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`Dated: Nov. 20th, 2019
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`/ASUS/
`ALBERTO SOLER-SOMOHANO
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`/JR/
`JUAN RODRIGUEZ
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`CERTIFICATE OF SERVICE
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` WE HEREBY CERTIFY that a true and correct copy of the foregoing was
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`furnished to Opposer email address of record this 30th day of Nov.2019
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`/ASUS/
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`3
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