Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA712419
`ESTTA Tracking number:
`12/03/2015
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`92059277
`Plaintiff
`Chaldean American Chamber of Commerce
`PATRICK R STURDY
`CUMMINGS MCCLOREY DAVIS & ACHO PLC
`33900 SCHOOLCRAFT
`LIVONIA, MI 48150
`UNITED STATES
`psturdy@cmda-law.com, dwaldenmayer@cmda-law.com, jcalla-
`han@cmda-law.com, rancho@cmda-law.com
`Testimony For Plaintiff
`Ronald G. Acho
`racho@cmda-law.com, jcallahan@cmda-law.com, kueberroth@cmda-law.com
`/s/ Ronald G. Acho
`12/03/2015
`CACC_Martin-Manna-_mini-transcript.pdf(590234 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
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`

`
`CHALDEAN AMERI CAN CHAMBER OF COMMERCE
`v. KALASHO
`
`MARTI N MANNA
`
`November 16, 2015
`
`Prepared for you by
`
`Bingham Farms/Southfield • Grand Rapids
`Ann Arbor • Detroit • Flint • Jackson • Lansing • Mt. Clemens • Saginaw
`
`

`
`
`MARTIN MANNAMARTIN MANNA
`
`November 16, 2015November 16, 2015
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`Page 1
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`Page 3
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` TABLE OF CONTENTS
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`WI TNESS PAGE
`MARTI N MANNA
`
` EXAMI NATI ON
` BY MR. ACHO: 12
`
`Page 4
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` EXHIBI TS
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` EXHIBI T PAGE
` (Exhibits attached to transcript.)
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` EXHIBI T 1 24
` EXHIBI T 2 81
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` I N THE UNI TED STATES PATENT AND TRADEMARK OFFI CE
`
` BEFORE THE TRADEMARK TRI AL AND APPEAL BOARD
`
`Registration No: 4,516,721
`
`Mark: SAN DI EGO EAST COUNTY CHALDEAN
`
` AMERI CAN CHAMBER OF COMMERCE
`
`Filed: November 8, 2013
`
`Registered: April 15, 2014
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`CHALDEAN AMERI CAN CHAMBER OF
`
`COMMERCE,
`
` Petitioner,
`
` vs. Cancellation No. 92059277
`
`BEN KALASHO,
`
` Registrant.
`
`______________________________________
`
` The Deposition of MARTI N MANNA,
`
` Taken at 33900 Schoolcraft Road,
`
` Livonia, Michigan,
`
` Commencing at 9:00 a.m.,
`
` Monday, November 16, 2015,
`
` Before Kathy Adkins, CSR-4697, RMR, RPR, B.A.
`
`Page 2
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`APPEARANCES:
`
`RONALD G. ACHO
`Cummings, McClorey, Davis & Acho, PLC
`33900 Schoolcraft Road
`Livonia, Michigan 48150
`734.261.2400
`racho@cmda-law.com
` Appearing on behalf of the Petitioner.
`
`ALSO PRESENT:
`Julie Callahan - Paralegal
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`MARTIN MANNAMARTIN MANNA
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`November 16, 2015November 16, 2015
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`Pages 5 to 8Pages 5 to 8
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`

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`MARTIN MANNAMARTIN MANNA
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`November 16, 2015November 16, 2015
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`Livonia, Michigan
`
`Monday, November 16, 2015
`
`9:00 a.m.
`
` MARTIN MANNA,
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` was thereupon called as a witness herein, and after
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` having first been duly sworn to testify to the truth,
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` the whole truth and nothing but the truth, was
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` examined and testified as follows:
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` MR. ACHO: Let this be known that this is
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` the deposition of Martin Manna who is the president of
`
` the Petitioner, Chaldean American Chamber of Commerce.
`
` This deposition is being taken pursuant to the Code of
`
` Federal Regulations, 37 CFR 2.123 E, and pursuant to
`
` the Trademark Trial Appeal Board Rule Manual 703.01 R.
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` I t is also pursuant to 2.123 of the Trademark Rules of
`
` Practice.
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` The notice of deposition was communicated
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` to the Respondent's attorney, Martin Becker, on
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` October 22nd, 2015, for this deposition on
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` November 16, 2015. I have not heard from Mr. Becker
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` in three weeks, the attorney for the Respondent, and
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` no one, Mr. Becker is not here and no one is here on
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` behalf of the Respondent, San Diego East County
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` Chaldean American Chamber of Commerce, that is why we
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`
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`Pages 9 to 12Pages 9 to 12
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`

`
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`MARTIN MANNAMARTIN MANNA
`
`November 16, 2015November 16, 2015
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`Page 13
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` are proceeding.
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` But I want the record to reflect that 30
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` minutes ago I received notice of a fax sent by a man
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` by the name of Ben Kalasho, who said that he wanted
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` this matter adjourned. I have not heard from his
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` counsel and I cannot recognize Mr. Kalasho anyway. He
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` is not the representative for the organization for the
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` purposes of this litigation. He is the registrant,
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` but he is not the client and this notice was sent out
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` three weeks ago and so we are proceeding.
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` EXAMI NATI ON
`
`BY MR. ACHO:
`
` support the many causes within the Chaldean community.
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` I t was also formed to help dispel the
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` negative stereotypes that existed about Chaldeans,
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` both here and abroad, and the organization also wants
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` to act as an ambassador for the Chaldean, Assyrian,
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` Syriac people throughout the world.
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`Q. Let me ask you this. The Chaldean American Chamber of
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` Commerce is really an umbrella which includes other
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` organizations within it, correct?
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`A. Yes, sir. Since our inception we've launched several
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` affiliates and have many partner organizations and
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` part of the mission is to represent Aramaic speaking
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`Q. Would you please state your name.
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`A. Martin Manna.
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`Q. And where are you employed, sir?
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`A. The Chaldean American Chamber of Commerce.
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`Q. And where are the offices of the Chaldean American
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` Chamber of Commerce?
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`A. 30850 Telegraph Road in Bingham Farms, Michigan, and
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` 3601 15 Mile Road, Sterling Heights, Michigan.
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`Q. Now, you are the president of the organization?
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`A. Correct.
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`Q. How long have you been associated with the Chaldean
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` American Chamber of Commerce?
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`A. Since its inception and even prior to that in
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` people, again throughout the world.
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` And so the organization has launched
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` several affiliates, initially the Chaldean Chamber of
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` Political Action Committee which is involved
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` politically. We've also launched many other
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` affiliates including the Detroit I ndependent Grocers
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` in which we were responding to negative stereotypes
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` that existed about Detroit grocers in general and
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` wanted to a better job of serving that segment of our
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` population.
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`Q. So that's two. Is there a third?
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`A. There are several others, sir.
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`Q. Let's take it a step at a time. What is the third?
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` organizing.
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`Q. Okay. And am I correct in that the organization began
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` in 2011?
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`A. No, sir, in 2001.
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`Q. I 'm sorry, strike that.
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` The organization began in 2001?
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`A. Correct.
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`Q. Now, has it been operating since 2001?
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`A. Yes, it has been in operation since 2001, exclusively
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` and through that length and continuously as an
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` organization representing the Chaldean American
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` community.
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`A. The Chaldean Community Foundation was launched in 2006
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` as a means initially to help stop the violence against
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` Chaldean business owners. One of our founding members
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` was killed in his place of business so he launched a
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` foundation, our charitable arm, it's a 501(c)(3) that
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` was focused on providing reward money for those who
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` are either injured or killed in their place of
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` business.
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`Q. Well now, just so I 'm clear, has the Chaldean
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` Community Foundation, which is part of the Chaldean
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` American Chamber of Commerce, has it been in
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` continuous use since 2006?
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`A. Yes.
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`Q. Has that continuous use been uninterrupted?
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`A. I t has been uninterrupted.
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`Q. So it's been every day, every week, every month, every
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` year since 2001?
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`A. Correct.
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`Q. Now, the organization does what?
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`A. The Chaldean American Chamber of Commerce represents
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` the Chaldean, Assyrian, Syriac community in many
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` different aspects. One, it's to educate the general
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` public about the contributions Chaldeans are making;
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` two, the organization also wants to be a network for
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` others to understand who the Chaldean community is and
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` give them the ability to do business together and also
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`Q. And has it been exclusive?
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`A. I t has been exclusive and continuous since 2006.
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`Q. Now, and that has grown since, correct?
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`A. Significantly.
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`Q. Let's go to the fourth organization that's part of the
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` Chaldean American Chamber of Commerce.
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`A. We have had affiliates and partners, one of our other
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` partners was the Chaldean, Syriac, Assyrian Council of
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` America, and also the Ninevah Council of America.
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` These organizations are focused on doing advocacy,
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` locally, nationally and internationally for the
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` benefit of the persecuted Christians in the Middle
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`
`
`Pages 13 to 16Pages 13 to 16
`
`

`
`
`MARTIN MANNAMARTIN MANNA
`
`November 16, 2015November 16, 2015
`
`Page 17
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`Page 19
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` East, again specifically Chaldean, Assyrian, Syriac.
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`Q. Any others?
`A. Any other affiliates?
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`Q. Or part of the organization, isn't there one dealing
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` with healthcare?
`A. Yes, there is also --
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`Q. I t's part of the Chaldean American Chamber of
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` Commerce?
`A. Sure, it's called Project Bismutha. Bismutha means
` healing in Aramaic, our language, and Bismutha is
` focused on providing free healthcare for the uninsured
` in our community and we also have more recently
` launched the Civil Liberties Advocates, CLA as I refer
` to it, is an organization that's focused on defending
` the rights of members of our community who might be
` discriminated against in the workforce or in other
` places.
`
`Q. So these all come within the umbrella of the Chaldean
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` American Chamber of Commerce?
`A. Yes, they do.
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`Q. Has this been part of the natural expansion growth of
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` the Chaldean American Chamber of Commerce since 2001?
`A. Yes, it has, and again, as part of our mission was
` always to be proactive to the needs of our community
` locally, nationally, internationally.
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` Chamber of Commerce recognized by these various
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` international governments, such as Turkey, such as
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` Syria, such as I raq?
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`A. Yes.
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`Q. How do you know that? How would -- how would the
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` Trademark Trial and Appeal Board members know that
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` that's the case?
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`A. We have had several instances in which we've been
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` communicating directly with heads of state, just more
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` recently the president of the Kurdistan regional
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` government has come to Washington, D.C., and invited
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` us for a one-on-one meeting with members of our
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` community. We are there representing the Chaldean
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` American Chamber of Commerce and invited others at
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` that meeting.
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` Just last week we've hosted the Turkish
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` consulate general from Chicago came into town, reached
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` out to the Chaldean American Chamber of Commerce,
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` asked if we could get community members involved and
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` engaged. After the meeting the Turkish consulate
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` himself personally has been communicating with me all
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` weekend in regards to an incident in Brussels with one
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` of the Chaldean Catholic priests.
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` He's also requested that I communicate with
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` His Excellency, our patriarch, Luis Sako, regarding a
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`Page 20
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`Page 18
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`Q. The Trademark Trial and Appeal Board has a question
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` regarding whether the Chaldean American Chamber of
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` Commerce, your organization, has an acquired
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` distinctiveness. Do you know whether your
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` organization has an acquired distinctiveness?
`
`A. Yes.
`
`Q. Why do you say that? Can you elaborate?
`
`A. Well, I look at it this way. There's been many
` instances where we've been called upon, again, not
` just locally, but nationally and internationally, to
` be a representative of our community.
` And so the Chaldean American Chamber of
` Commerce has built a network and that network includes
` the prime minister of Turkey, their foreign minister,
` the prime minister of I raq, many leaders and
` dignitaries from Lebanon, members of Syria's
` government, members of the Kurdistan regional
` government, but also throughout various media outlets
` we are typically the source when it comes to
` recognizing who is speaking on behalf of the
` community, if it involves our members, whether abroad
` or on a national level.
`
`Q. Let's deal real quickly with the international and
`
` then we'll go back.
`
` I nternationally, is the Chaldean American
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` monument sign being erected in Brussels in which the
`
` Turkish government wanted us to intervene because they
`
` felt it might cause or incite some negative reaction
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` by Turkish residents in that area.
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` I 've been in communication with the
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` Chaldean Catholic bishop here, our church hierarchy in
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` I raq, and we are working with the Turkish government.
`
` He is getting these orders from directly from Ankara,
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` the capital of Turkey, and asked us to intervene to
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` assist. That is just one example.
`
` I have, you know, probably hundreds more of
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` all of our work that is being done on an international
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` level. We were recently, when I say "recently,"
`
` within the last few years, guests of the Turkish
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` government in which they had a conference on the Arab
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` Spring and the relationship between Muslims and
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` Christians. I was one of only three people invited
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` from the United States to represent the Middle Eastern
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` Christian perspective as a representative of the
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` Chaldean American Chamber of Commerce.
`
`Q. Now, has any other organization in America in any way,
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` shape or form rivaled the Chaldean American Chamber of
`
` Commerce and what it is doing?
`
`A. No, not to my understanding.
`
`Q. And this respondent, this organization in San Diego,
`
`
`
`Pages 17 to 20Pages 17 to 20
`
`

`
`
`MARTIN MANNAMARTIN MANNA
`
`November 16, 2015November 16, 2015
`
`Page 21
`
`Page 23
`
` have they done anything like this?
`A. Not that I 'm aware of.
`
`Q. And I 'm trying to determine how important is that name
`
` and reputation, first of all, does the Chaldean
`
` American Chamber of Commerce have a reputation?
`A. Of course it does.
`
`Q. Is the reputation only internationally, these foreign
`
` countries overseas?
`A. No, it's also here locally and on a national level.
` This is why there's so much danger in anybody else
` trying to duplicate the name "Chaldean American
` Chamber of Commerce."
`
`Q. But what about if there's, you know, like, well, you
`
` know, a San Diego or East San Diego, does that really
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` ask you, does the Chaldean American Chamber of
`
` Commerce have a national reputation?
`
`A. Yes.
`
`Q. What is that reputation?
`
`A. Well, I believe it to be one of which we are highly
` regarded and also an organization that is looked upon
` as a resource for the U.S. government.
`
`Q. The United States government?
`
`A. For the United States government.
`
`Q. Why do you say that?
`
`A. We have a great relationship with the current
` administration, previous administration, the U.S.
` State Department, several senators, several members of
` Congress, other government agencies.
`
`Q. And you'll be able to back this up later in more
`
` specific detail about the national reputation of the
`
` Chaldean American Chamber of Commerce?
`
`A. Yes.
`
`Q. I s that reputation a good one?
`
`A. I t's a great one.
`
`Q. And how important is the name of the Chaldean American
`
` Chamber of Commerce in terms of dealing with the
`
` United States government?
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` matter?
`A. Well sure it does. I think if you look historically
` in the context of other groups similar, or they may be
` ethnic in nature. I give you one example, the
` Hispanic community. There's a Hispanic Chamber of
` Commerce and there was a similar dispute and the
` challenges are people recognize the name Chamber of
` Commerce and Hispanic as the core leading group here
` in southeast Detroit.
` The resolution was there should be a
` Hispanic business alliance but not necessarily a
`
`A. I t's extremely important. This is the organization
` that they look upon, again, for resources and the
`
`Page 22
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` Hispanic Chamber of Commerce. This Hispanic Chamber
` of Commerce like the National Women's Business
` Association wants to -- creates chapters throughout
` the country, so there's one representing body that is
` affiliated with the core organizer, the host
` organization, the one that founded the name and has
` been continuously using that name for several years.
`
`Q. And the San Diego people never did such a thing. They
`
` never approached you about --
`A. They did not approach us. As a matter of fact, when
` we brought up the issue, not only did they not
` approach us, they caused a ton of confusion because
` although it might be San Diego East County, the San
` Diego East County portion of their name really was
` never visible, and when they initially launched, the
` reason we were so concerned immediately is most of
` their materials on their website was material that was
` just plagiarized from our website.
` The photos that they used for their events
` were actually the photos from our events, and there's
` many other instances in which they were using our
` material.
`
`Q. We'll get back to that later.
`
` You briefly identified the international
`
` relationship, which we'll go into later, but let me
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` organization they go to for assistance and also the
` organization they go to when it comes to setting
` policy and dealing with issues impacting minorities in
` the Middle East.
`
`Q. You talking about the United States government looks
`
` to the Chaldean American Chamber of Commerce?
`
`A. Absolutely.
`
`Q. For assistance?
`
`A. Yes.
`
`Q. Now, in terms of the state, does the Chaldean American
`
` Chamber of Commerce have a reputation in the state of
`
` Michigan and does it have any reputation outside of
`
` the state of Michigan?
`
`A. Yes, for both.
`
`Q. Could you explain.
`
`A. Sure. I n the state of Michigan our organization is
` deeply involved in state government in many different
` aspects, mainly through the current governor and many
` of his committees, but also with the state House and
` the state Senate and many other departments within the
` state of Michigan.
`
`Q. Are there any other states in which the Chaldean
`
` American Chamber of Commerce has dealt besides
`
` Washington, D.C.?
`
`A. We have dealt with our states such as California,
`
`
`
`Pages 21 to 24Pages 21 to 24
`
`

`
`
`MARTIN MANNAMARTIN MANNA
`
`November 16, 2015November 16, 2015
`
`Page 25
`
`Page 27
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` I llinois, and other states in which there may have
`
` been issues impacting Chaldeans. I remember more
`
` recently we had some I raqi Chaldean refugees who were
`
` being intimidated in North Carolina and which we had
`
` to intervene.
`
`Q. Now, Mr. Manna, what I 'm going to do, I 'm going to
`
` hand you the Petitioner's Exhibit Number 1.
`
` MARKED FOR I DENTI FI CATI ON
`
` EXHI BI T 1
`
` 9:19 a.m.
`
`BY MR. ACHO:
`
`Q. Now, you have before you, and I move for its
`
` admission. I know it's not required, but all the
`
` exhibits that I present I move for their admission.
`
` Exhibit Number 1 is Petitioner's outline of
`
` trial testimony by deposition of Martin Manna, do you
`
` see that, sir?
`
`A. Yes, sir.
`
`Q. What I 'm going to do, I 'm going to direct your
`
` attention to page number three. Now, Mr. Manna, what
`
` I 'm going to do, I am going to be asking you a series
`
` of questions that are going to follow this outline.
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` I nterlink helped establish the Chaldean
`
` News, which is a monthly publication, and also helped
`
` organize the Bank of Michigan, a community bank.
`
`Q. So you have a deep background with the Chaldean
`
` community.
`
`A. Well, prior to the chamber I was also involved in an
`
` organization called CARE, Chaldean Americans Reaching
`
` and Encouraging, which was a youth-based organization,
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` all volunteer-based organization that was affiliated
`
` with the Chaldean Catholic church focused on
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` preserving the language, history and culture of the
`
` Chaldean people.
`
`Q. Are you Chaldean?
`
`A. Yes.
`
`Q. Now, what is a Chaldean?
`
`A. Chaldean by definition are eastern right Catholic,
`
` they speak Aramaic, the language of Christ, and have a
`
` history that spans some 5500 years. The Chaldeans are
`
` indigenous to I raq, Syria, parts of Turkey and I ran.
`
` They're like the American I ndians of I raq.
`
`Q. All right. And the sad story is, aren't like 90
`
` percent of Chaldeans, since the problems with the
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` The reason I 'm going to do that is to
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` Muslims, like 90 percent have been driven out of their
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` assist the Trademark Trial and Appeal Board to follow
`
` your testimony, as well as to assist you in order to
`
`Page 26
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` streamline this process. Do you understand?
`
`A. I do.
`
`Q. Okay. Now, I will be asking you questions with
`
` regards to each topic, so let's begin with this. Can
`
` you give us your employment history.
`
`A. Sure.
`
`Q. Please do.
`
`A. Yeah. I was one of about 15 members of the Chaldean
` community that set out to help organize the Chaldean
` American Chamber of Commerce.
`
`Q. And what year was that?
`
`A. 2001.
`
`Q. The same organization that's the petitioner here, you
`
` helped organize it in 2001.
`
`A. Correct.
`
`Q. And has it been in continuous use since you began the
`
` organization?
`
`A. I t's been exclusive and in continuous since 2001.
`
`Q. Now, what is your other history prior to the Chaldean
`
` American Chamber of Commerce?
`
`A. Prior to the Chaldean American Chamber of Commerce I
` worked at a financial firm and until 2001, and I also
` started an organization called I nterLink Media.
` I nterLink Media was focused on helping start up new
` businesses and also did some advertising.
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` country?
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`A.