Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA1019117
`
`Filing date:
`
`11/30/2019
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`92057485
`
`Party
`
`Correspondence
`Address
`
`Defendant
`Juan Rodriguez
`
`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
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Reply in Support of Motion
`
`Juan Rodriguez
`
`asus@coca.life
`
`/JR/
`
`11/30/2019
`
`Attachments
`
`Middlefinger.pdf(153305 bytes )
`
`

`

` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`__________________________________
`
`Cancellation Nos. 92057485
`____________________________________________________
`
`
`JUAN RODRIGUEZ
`
`&
`
`ALBERTO SOLER-SOMOHANO
`
`Registrants
`
`v.
`
`THE COCA-COLA COMPANY
`
`Claimant.
`
`__________________________________________
`REPLY TO COKE’S RESPONSE
`___________________________________________
`
` COMES NOW the Registrants, moves by replying to Coke’s response of Nov.
`
`29, 2019 [49].
`
`COKE’S RESPONSE
`
` 1. Coke response states that Registrant’s motion for relief from judgment does
`
`not provide the relief they seek they didn’t even say which part of Rule 60(1) thru
`
`(4) they seek to apply.
`
` 2. Coke response also further stated that Registrants are in the position as
`
`everyone else nothing special for requesting relief from judgment.
`
`
`
`

`

` 3. Coke’s response adds that the Board w/o authority to consider the
`
`constitution objection in the first place so the Rule 60 motion is meaningless.
`
`REGISTRANT’S REPLY
`
` 4. Coke’s representative response was just another of those pleadings being
`
`filed to over bill their client since it’s obviously frivolous ridiculously.
`
` 5. Registrants are the only one of all in their own position no one else position
`
`raising the constitutional objection (2) times during the proceedings in 2014. June
`
`24th, 2014 [25] and August 27th, 2014 [29]
`
` 6. The issue raised was more compounded to the greatest extent to a
`
`constitutional challenge than what it was upon the appointment clause challenge in
`
`Arthrex, Inc, v. Smith & Nephew, 2018-2140 (Fed. Cir. Oct 31st, 2019).
`
` 7. The Registrant said directly that the Board members must be a President
`
`appointee Senate consented and why all of Registrant’s comments to them why
`
`corrupted in the first place.
`
` 8. Registrants don’t regret any of those comments to them 3 and 4 because it
`
`was the truth and truth is unstoppable and those that can’t handle it, is simple since
`
`them the ones doing the wrong in the first place.
`
` 9. Extraordinary circumstances under Rule 60 is simple and why it applies here
`
`and no matter not even applying at all what does apply is the law of the United
`
`States Supreme Court directly on point.
`
`
`
`2
`
`

`

`“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”
`
`Lucia v. SEC, 138 S. Ct. 2044 (2018
`
` 10. The Board does not cannot w/o authority to do that entertain any
`
`constitutional objection is silly if that is really that, since in registrant current
`
`proceeding #91232090 the Board did ruled on that and said they adopt the
`
`government position in Arthrex about that. September 27th, 2019 Doc. 59 page.12
`
` 11. What came about that Board adopting the Govt. position-the government got
`
`the nob so the Board will be having mobs and Coke here got the finger.
`
`Dated: Nov. 20th, 2019
`
`/ASUS/
`ALBERTO SOLER-SOMOHANO
`
`/JR/
`JUAN RODRIGUEZ
`
`
`CERTIFICATE OF SERVICE
`
` WE HEREBY CERTIFY that a true and correct copy of the foregoing was
`
`furnished to Opposer email address of record this 30th day of Nov.2019
`
`/ASUS/
`
`
`
`
`
`
`
`
`
`3
`
`

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