CUMMINGSIMCCLOREY
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`ATTORNEYS AN1) COUNSELORS AT LAW
`33900 SCHoo1.CRA1~T ROAD I L1voN1A. MICHIGAN 48150 I PHONE: (734)261-2400 I FACs1M11-1~:: (734)261-4510
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`
`December 7, 2015
`
`VIA UNITED STATES MAILS
`
`United States Patent and Trademark Office
`
`Trademark Trial and Appeal Board
`P.O. Box 1451
`
`Alexandria, VA 22313-1451
`
`Re:
`
`Chaldean American Chamber of Commerce v. Kalasho
`Registration No. 4,516,721
`MARK: San Diego East County Chaldean American Chamber of Commerce 1,
`Filed: November 8, 2013
`M
`I
`( 3/
`Registered: April 15, 2014
`I
`USPTO TTAB Cancellation No. 92059277
`Confirmation No. 1-363-432-150
`
`pi.‘
`if
`
`‘V
`
`1
`
`l
`
`Dear Sir or Madam:
`
`I am the attorney of records for Petitioner, Chaldean American Chamber of
`Commerce, in the above captioned matter.
`
`Enclosed please find the Trial Deposition Transcript of Martin Manna which was
`taken in the above captioned matter on November 16, 2015,
`together with a set of
`Exhibits Nos. 1 through 166, which were admitted into evidence during the deposition. In
`previous contacts with the Trademark Trial and Appeal Board, we were given the
`Confirmation Number of 1-363-432-150 for this submission.
`
`Cl.l\'|'()1\'T()\VN5111|’_Ml
`
`I(11<.\N1>R.\1=11)s.1v1II|,1v1)N1A.1V11I'1'1<.\v1-.1<s1.(‘11Y.M1
`K\\'\.’\.\'C1l\',lVl(.)'R1V1RS[171-..C/\
`
`111111
`
`I111111111111111l|1l11|11l|1ll11111111111
`*12-10—2015*
`U,S. P‘a'ter1tand Trademarkotfioe #72
`
`

`
`United States Patent and Trademark Office
`
`Trademark Trial and Appeal Board
`December 7, 2015
`
`Page 2
`
`In addition to the transcript and the exhibits, I am also enclosing the following
`four letters of support:
`
`0 Mr. Toufic Baaklini of In Defense of Christians;
`
`0 Mr. Carlo K. Ganjeh of the Assyrian Universal Alliance — California;
`
`0 Mr. Guilana Younan of the Assyrian American Association of Chicago; and
`
`0 Mr. Michael G. Sarafa, of the Bank of Michigan.
`
`Please be advised that on December 3, 2015, we electronically filed the transcript
`and the four letters of support with the TTAB.
`
`On December 3, 2015, we also submitted the trial transcript, and the four letters of
`support to Respondent, Mr. Ben Kalasho, who is appearing on his own behalf, pro se. Per
`the enclosed Certificate of Service, these documents are been sent to the Respondent via
`email at the email address of president@chaldeanamericanchamber.com.
`
`Further, we also advised Mr. Kalasho on December 3, 2015, that we shipped to
`him a duplicate of our submission to the TTAB, including the November 16, 2015 Trial
`Deposition Transcript of Mr. Manna, together with an entire
`set of Exhibits Nos.
`1
`through 166. Mr. Kalasho has provided us a street address for UPS delivery of 1620
`Cliffdale Road, El Cajon, CA 92020.
`
`Should you have any questions, please do not hesitate to contact me.
`
`Sincerely yours,
`
`CUMMINGS, MCCLOREY, DAVIS & ACHO, PLC
`
`$4/£22
`
`Ronald G. Acho
`
`/j ac
`Enclosures
`
`cc: Mr. Ben Kalasho (without enclosures)
`
`I TRAVl~,|(.\'I:CIl\'. Ml
`I S1I.l<I.n\'(;HI,ImH'.\. MI
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`K.\.\'.\‘/\.\C||\'.lVI()' R1v1,|<sn>i..CA I A(’('R.’\.(lIl.r\N,\
`
`

`
`
`
`November 27, 2015
`
`To:
`
`United States Patent and Trademark Office
`
`Trademark Trial and Appeal Board
`P.O.Box 1451
`
`Alexandria, VA 22313-1451
`
`Re:
`
`Registration No. 4,516,721
`Mark: SAN DIEGO EAST COUNTY CHALDEAN
`
`AMERICAN CHAMBER OF COMMERCE
`
`Filed: November 8,2013
`
`Registered: April 15, 2014
`Cancellation No.: 92059277
`
`Letter of Support of Petitioner:
`
`CHALDEAN AMERICAN
`
`CHAMBER OF COMMERCE
`
`
`
`Dear Sir/Madame,
`
`Please know that I am the President of the organization called In
`Defense of Christians.
`I started the organization two years ago to help
`the plight of Christians in the Middle East.
`
`I have had the pleasure of working with Mr. Martin Manna and the
`Chaldean American Chamber of Commerce. They have been
`invaluable in helping my organization dealing with the serious
`problems facing Christians of the Middle East.
`
`On one occasion, I contacted the San Diego East County Chaldean
`American Chamber of Commerce.
`I was confused because I believed
`
`they were the same organization as the Chaldean American Chamber
`of Commerce run by Mr. Martin Manna.
`I found out that they were a
`completely different organization. The San Diego people's name
`confused me, as I know it has confused some others.
`
`I am writing this letter in support of the Chaldean American Chamber
`of Commerce, and their exclusive use of the name.
`
`Sinc
`
`ely,ZJ?5,/
`
`Toufic Baaklini
`President
`
`In Defense of Christians
`
`400 N Capitol St NW. Suite 585 Washington, DC 20001
`'3?» E
`’= “,3 ‘CH1 i"!.:i‘-.4if2{‘f$.l??1£,
`
`

`
`November 24, 2015
`
`Mr. Carlo K Ganjeh
`Assyrian Universal Alliance - California
`125 East Campbell Ave. suite 100
`Campbell, CA 95008
`Phone: 4083697620 Ext 202
`
`E Cl;i7;E§.i’_1id"!@31.J 8 3 -“El 9 i l ‘33 3 - ’~ 1‘ 0.3.
`
`United States Patent and Trademark Office
`
`Trademark Trial and Appeal Board
`P.O. Box 1451
`
`Alexandria, Virginia 22313-1451
`
`RE:
`
`Registration No: 4,516,721
`Mark: SAN DIEGO EAST COUNTY CHALDEAN AMERICAN CHAMBER OF COMMERCE
`Filed: November 8, 2013
`Registered: April 15, 2014
`Cancellation No: 92059277
`
`Letter of Support of Petitioner: CHALDEAN AMERICAN CHAMBER OF COMMERCE
`
`Dear Sir/Madame:
`
`I was introduced to Chaldean American Chamber of Commerce back in 2004 in Detroit Michigan. Since
`then I have met, worked 8: cooperated with the leadership of Chaldean American Chamber of
`Commerce.
`
`I had been working very closely with Mr. Martin Mana current president of Chaldean American Chamber
`of Commerce for over 3 years. The Chaldean American Chamber of Commerce is one of the success
`story of our community in United State.
`
`Please feel free to contact me for more information.
`
`Sincerely,
`
`.//Z
`
`
`
`
`Carlo Kooktapeh Ganjeh
`Chapter Secretariat
`Assyrian Universal Alliance Americas Chapter
`
`

`
`Mr. Guiliana Younan
`
`Assyrian American Association of Chicago
`Chaldean Syriac Assyrian Council of America — Illinois
`4955 W. Coyle Ave.
`Skokie, IL. 60077
`312-735-2848
`
`3% iii M? l‘;'1€§ ii @.§f’J.iL%1l |
`
`. .ci.~f.>D;?.
`
`November 30, 2015
`
`United States Patent and Trademark Office
`
`Trademark Trial and Appeal Board
`P.O. Box 1451
`
`Alexandria, Virginia 22313-1451
`
`RE:
`
`Registration No: 4,516,721
`
`Mark: SAN DIEGO EAST COUNTY CHALDEAN AMERICAN CHAMBER OF COMMERCE
`Filed: November 8, 2013
`
`Registered: April 15, 2014
`Cancellation No: 92059277
`
`Letter of Support of Petitioner: CHALDEAN AMERICAN CHAMBER OF COMMERCE
`
`Dear Sir/Madame:
`
`My name is Guiliana Younan, I am a member of the board of the Chaldean Syriac Assyrian Council of
`America and also presently the president of the Assyrian American Association of Chicago that was
`established and duly registered in the State of Illinois in 1917. I have been a member of AAA of Chicago
`for over forty years and on the executive committee of the Association for most of the years.
`
`land my colleagues are familiar with Mr. Martin Manna and the Chaldean American Chamber of
`
`Commerce in Michigan for more than ten years. We are familiar with their services to the community
`and their successful businesses that not only helpful to them but to the city and the state. We have been
`attending most of their Annual Dinners and have met many VlP at these events and to name few:
`Governor Jennifer Granholm, U.S. Senators Carl Levin and Debbie Stabenow, His Beatitude Emmanuel
`Delly, the Chaldean Patriarch and many others.
`
`We noticed recently that another organization with the same name and general appearance when
`searching the name is showing as if the Michigan CACC have moved to San Diego or they have opened a
`branch in California. it is confusing to many of us who are familiar and worked closely with Mr. Martin
`Manna and the Chaldean American Chamber of Commerce in Michigan.
`
`Thank you,
`Sincerely,
`
`
`
`Guiliana Younan,
`
`

`
`BANK
`
`Of.
`
`IG
`
`-
`
`-
`
`November 30, 2015
`
`United States Patent and 'l'radcmark Office
`Trademark Trial and Appeal Board
`l’.O. Box 1451
`Alexandria, Virginia 223134451
`
`30095 Nortliwcstcrn Hwy.
`
`Farniington Hills, i\'Il 48334
`1): 248-865-1300
`1‘; 248~865—0355
`
`Registration No: 4,516,721
`RE:
`1\/Iark: SAN DIEGO EAST COUNTY CHALDEAN AMERICAN CHAMBER OF COMMERCE
`Filed: November 8, 2013
`Registered: April 15,2014
`Cancellation No: 92059277
`
`Letter ofSupport ot‘Petitioner: CHALDEAN AMERICAN CHAMBER O17 COMMERCE
`
`Dear Sir/Madame:
`
`l have worked with the Chaldean Chamber of Commerce and Mr. Martin Manna since the
`organization \vas founded. Over those years, the entity has grown from a fledgling group to a robust,
`expansive and hugely successful organization.
`it has its own brand, special events and publications.
`11 has spawned a successful foundation which serves the needs of the Iraqi Refugees and others.
`
`The ('.‘h2ildean Chamber of Commerce has built this brand and these programs with hard work,
`dedication and perseverance. The name is associated with the group, their efforts, their office
`locations and their results. This is true not only at the community level but in the corridors ofthe
`state and national capitols, with the news media, other ethnic organizations, the Chaldean Church
`and opinion leaders throughout Michigan and the United States.
`
`Sincerely,
`
`1’:'
`
`Michael G. Sarafa, President
`Bank of Michigan
`
`Member FDIC Qre:
`
`- w
`as-.'.
`( .:
`
`
`

`
`CHALDEAN AMERICAN CHAMBER OF COMMERCE
`
`V. KALASHO
`
`MARTIN MAN NA
`
`November 16, 2015
`
`Preparedfor you by
`
`/éIENENSTOCK
`
`NATIONWIDE COURT REPORTING 8: VIDEO
`
`Bingham Farms / Southfield 0 Grand Rapids
`Ann Arbor 0 Detroit 0 Flint 0 Jackson 0 Lansing 0 Mt. Clemens 0 Saginaw
`
`

`
`MART I N MANNA
`
`November 16, 2015
`
`Page 1
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Registration No:
`Mark:
`
`Filed:
`Registered:
`
`4,515,721
`SAN DIEGO EAST COUNTY CHALDEAN
`AMERICAN CHAMBER OF COMMERCE
`November 8, 2013
`April 15, 2014
`
`CHALDEAN AMERICAN CHAMBER OF
`COMMERCE,
`Petitioner,
`Cancellation No. 92059277
`
`vs.
`
`BEN KALASHO,
`Registrant.
`
`The Deposition of MARTIN 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
`
`APPEARANCES:
`
`RONALD G. ACHO
`
`Cummings, McC|orey, Davis & Acho, PLC
`33900 Schoolcralt Road
`Livonia, Michigan 48150
`734.261.2400
`racho@cmda-law.com
`Appearing on behalf of the Petitioner.
`
`ALSO PRESENT:
`
`Julie Callahan - Paralegal
`
`»J>UJI\)l—‘@KOG)\IO\L)'1n1>-(;)I\)l—‘
`
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`
`l—‘l—'l—’l—’i—‘
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`i\)RJl\)l\)l\Jl\)
`
`Page 3
`TABLE OF CONTENTS
`
`KO&)\IO‘\UTJ>(,«JK)l~4
`
`WITNESS
`MARTIN MANNA
`
`EXAMINATION
`BY MR. ACHO:
`
`PAGE
`
`EXHIBITS
`
`EXHIBIT
`
`PAGE
`
`(Exhibits attached to transcript.)
`
`EXHIBIT 1
`EXHIBIT 2
`EXHIBIT 3
`EXHIBIT 4
`EXHIBIT 5
`EXHIBIT 6
`EXHIBIT 7
`EXHIBIT 8
`EXHIBIT 9
`EXHIBIT 10
`EXHIBIT 11
`EXHIBIT 12
`EXHIBIT 13
`EXHIBIT 14
`EXHIBIT 15
`EXHIBIT 16
`EXHIBIT 17
`EXHIBIT 18
`EXHIBIT 19
`EXHIBIT 20
`
`24
`81
`82
`82
`85
`85
`85
`85
`91
`91
`97
`103
`103
`103
`103
`103
`103
`103
`103
`103
`
`i—‘©kOOO\I(hUT»l>L;Jf\)i—‘
`
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`
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`
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`
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`
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`
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`
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`u.‘\\‘\\ I|ii‘1Ii'Il‘I|H I-.,i -,v!Il
`
`Pages 1 to 4
`
`

`
`MART I N MANNA
`
`November 16,
`
`2015
`
`!\)l\)l\)l\)I\)l\)>—’|—‘|—‘>—‘I—‘I—’I—-‘I—*}-‘I-1
`
`U1»J>Lul\)|—‘®\.O(I)\IO\UW>1>(_A)l\)b—‘©UD®\IO‘ILJ‘1..l>L.«Jl\)|—|
`
`®\lG\U'I..t>L,«.)l\.)|—*
`
`EXHIBIT 21
`EXHIBIT 22
`EXHIBIT 23
`EXHIBIT 24
`EXHIBIT 25
`EXHIBIT 26
`EXHIBIT 27
`EXHIBIT 28
`EXHIBIT 29
`EXHIBIT 30
`EXHIBIT 31
`EXHIBIT 32
`EXHIBIT 33
`EXHIBIT 34
`EXHIBIT 35
`EXHIBIT 36
`EXHIBIT 37
`EXHIBIT 38
`EXHIBIT 39
`EXHIBIT 40
`EXHIBIT 41
`EXHIBIT 42
`EXHIBIT 43
`EXHIBIT 44
`
`EXHIBIT 45
`EXHIBIT 46
`EXHIBIT 47
`EXHIBIT 48
`EXHIBIT 49
`EXHIBIT 50
`EXHIBIT 51
`EXHIBIT 52
`EXHIBIT 53
`EXHIBIT 54
`EXHIBIT 55
`EXHIBIT 56
`EXHIBIT 57
`EXHIBIT 58
`EXHIBIT 59
`EXHIBIT 60
`EXHIBIT 61
`EXHIBIT 62
`EXHIBIT 63
`EXHIBIT 64
`EXHIBIT 65
`EXHIBIT 66
`EXHIBIT 67
`EXHIBIT 68
`
`kOCO\IO‘\U'lJ>LA)f\)|-‘
`
`EXHIBIT 69
`EXHIBIT 70
`EXHIBIT 71
`EXHIBIT 72
`EXHIBIT 73
`EXHIBIT 74
`EXHIBIT 75
`EXHIBIT 76
`EXHIBIT 77
`EXHIBIT 78
`EXHIBIT 79
`EXHIBIT 80
`EXHIBIT 81
`EXHIBIT 82
`EXHIBIT 83
`EXHIBIT 84
`EXHIBIT 85
`EXHIBIT 86
`EXHIBIT 87
`EXHIBIT 88
`EXHIBIT 89
`EXHIBIT 90
`EXHIBIT 91
`EXHIBIT 92
`
`EXHIBIT 93
`EXHIBIT 94
`EXHIBIT 95
`EXHIBIT 96
`EXHIBIT 97
`EXHIBIT 98
`EXHIBIT 99
`EXHIBIT 100
`EXHIBIT 101
`EXHIBIT 102
`EXHIBIT 103
`EXHIBIT 104
`EXHIBIT 105
`EXHIBIT 106
`EXHIBIT 107
`EXHIBIT 108
`EXHIBIT 109
`EXHIBIT 110
`EXHIBIT 111
`EXHIBIT 112
`EXHIBIT 113
`EXHIBIT 114
`EXHIBIT 115
`EXHIBIT 116
`
`Pages 5 to 8
`
`x
`
`‘.
`
`/3’1ENENsToC1<
`
`l(I\\‘.l|‘I l (H-‘I-.I m‘i’K|I*Z|i1’-.K~
`\.\'u\\ IxIo‘Il1'H*IIIt kn-:21
`
`~.\1iHIH
`
`

`
`EXHIBIT 165
`EXHIBIT I66
`
`Livonia, Michigan
`Monday, November 16, 2015
`9:00 a.m.
`
`MARTIN MANN A,
`was thereupon called as a witness herein, and after
`having first been duly sworn to testify to the truth,
`the whole tmth and nothing but the trufli, was
`examined and testified as follows:
`MR. ACHO: Let this be known that this is
`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.
`It is also pursuant to 2.123 of the Trademark Rules of
`Practice.
`The notice of deposition was communicated
`to the Respondent's attorney, Martin Becker, on
`October 22nd, 2015, for this deposition on
`November 16, 2015.
`I have not heard from Mr. Becker
`in three weeks, the attorney for the Respondent, and
`no one, Mr. Becker is not here and no one is here on
`behalf of the Respondent, San Diego East County
`Chaldean American Chamber of Commerce, that is why we
`
`U‘!>b{A)K)l~—‘©kDCO\IO\UT>J>-L;Jl\)l-4©\OCZ)\IO\UTsh(,J[\)|—|
`
`I\)l\)I\)I\)I\)I\)i—‘i—'i—‘l4|—‘i—‘l—‘|—‘l-“I-’
`
`1 2 3 4 S 6 7 8 x
`
`0
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`>—‘
`Ix.)
`
`>—-._- Am
`.—- UT
`ch
`._- \l
`
`MART I N MANNA
`
`November 16,
`
`2015
`
`CD\iO‘\U'|J>-L2Ji\)l—|
`
`EXHIBIT 117
`EXHIBIT 118
`EXHIBIT 119
`EXHIBIT 120
`EXHIBIT 121
`EXHIBIT 122
`EXHIBIT 123
`EXHIBIT 124
`EXHIBIT 125
`EXHIBIT 126
`EXHIBIT 127
`EXHIBIT 128
`EXHIBIT 129
`EXHIBIT 130
`EXHIBIT 131
`EXHIBIT 132
`EXHIBIT 133
`EXHIBIT 134
`EXHIBIT 135
`EXHIBIT 136
`EXHIBIT 137
`EXHIBIT 138
`EXHIBIT 139
`EXHIBIT 140
`
`EXHIBIT 141
`EXHIBIT 142
`EXHIBIT 143
`EXHIBIT 144
`EXHIBIT 145
`EXHIBIT 146
`EXHIBIT 147
`EXHIBIT 148
`EXHIBIT 149
`EXHIBIT 150
`EXHIBIT 151
`EXHIBIT 152
`EXHIBIT 153
`EXHIBIT 154
`EXHIBIT 155
`EXHIBIT 156
`EXHIBIT 157
`EXHIBIT 158
`EXHIBIT 159
`EXHIBIT 160
`EXHIBIT 161
`EXHIBIT 162
`EXHIBIT 163
`EXHIBIT 164
`
`/9’1ENENsToC1<
`
`-. ‘.fi<.Y'~.‘i\Il'1 lillll-I 3::i'l’<ll§iiF.{- -»
`\u\\\l=iw1lv li~l-u|\.i.»:il
`
`‘xillvllll
`
`Pages 9 to 12
`
`

`
`MART I N MANNA
`
`November 16, 2015
`
`are proceeding.
`
`But I want the record to reflect that 30
`minutes ago I received notice of a fax sent by a man
`by the name of Ben Kalasho, who said that he wanted
`this matter adjourned.
`I have not heard from his
`counsel and I cannot recognize Mr. Kalasho anyway. He
`is not the representative for the organization for the
`purposes of this litigation. He is the registrant,
`but he is not the client and this notice was sent out
`three weeks ago and so we are proceeding.
`EXAMINATION
`
`BY MR. ACHO:
`Q. would you please state your name.
`A. Martin Manna.
`Q. And where are you employed, sir?
`A. The Chalden American Chamber of Commerce.
`Q. And where are the offices of the Chaldean American
`Chamber of Commerce?
`
`A. 30850 Telegraph Road in Bingham Farms, Michigan, and
`3601 15 Mile Road, Sterling Heights, Michigan.
`
`Q. Now, you are the president of the organization?
`A. Correct.
`Q. How long have you been associated with the Chaldean
`American Chamber of Commerce?
`A. Since its inception and even prior to that in
`
`Page 14
`
`organizing.
`
`Okay. And am I correct in that the organization began
`in 2011?
`
`. No, sir, in mm.
`I'm sorry, strike that.
`The organization began in 2001?
`. Correct.
`Now, has it been operating since 2001?
`. Yes, it has been in operation since 2001, exclusively
`and through that length and continuously as an
`organization repraentlng the Chaldean American
`community.
`
`Has that continuous use been uninterrupted?
`It has been uninterrupted.
`A.
`Q. So it's been every day, every week, every month, every
`
`year since 2001?
`A. Correct.
`
`Q. Now, the organization does what?
`. The Chaldean American Chamber of Commerce repruents
`the Chaldean, Assyrian, Syriac community in many
`ditferent aspects. One, it's to educate the general
`public about the contributions Chaldeans are making;
`two, the organization also wants to be a network for
`others to understand who the Chaldean community is and
`give them the ability to do business together and also
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`Page 15
`support the many causes lnithin the Olaldean oontnuniy.
`
`It was also brmed to helpdispel the
`nemtive stereotypes that eaisted about Chaldeans,
`both here andalroad, and the organization dso wants
`to art as an amlnssador for the Chaldean, Assyrian,
`flriac people throughout the world.
`. Let ne ask you this. The Chaldean Amaican Chanber of
`tbmmerce is really an umbrella which includs other
`organizations within it, corect?
`. Yes, sir. Shoe our inception we've bundled several
`afliliates and have nany partner organizations and
`part of the m‘ssion is to reiresent Ararraic speaking
`people, again throughout the wold.
`And so the organhation has laumhed
`several afiliata, iritially the Olaldean Olamher of
`Political Action Corrlnittee whizh is ilvolved
`politirzlly. We've also launched many other
`affiliates ilcluding the Detroit Incbpaldent Gocers
`
`in whi:h we were resmnding to negative stereotyps
`that existed about Ddroit grocas in general and
`
`wanted to a better jobof serving thatsqment of our
`population.
`Q. So that's two 15 there a third?
`A. Thee are several others, s'r.
`Q. Let's take it a step at a time. What is thethird?
`
`Page 16
`A. The Chaldean Cannulniy Founation was launched in 2006
`
`as a mans ilitially to help stop the violalce against
`Chaldean business owners. one of our founding menllers
`
`was killed in his place or business solie launchal a
`foundation, our charitatie ann, it's a 501(c)(3) that
`was focused on proviring reward money for those who
`are other injured or killed in their place ol
`business.
`. Well now, just so I'm dear, has the Chaldean
`Communty Founchtion, which is part of the Chaldean
`Amerialn Chambe of Commerce, has it been in
`continuous use since 2006?
`
`. Yes.
`. And has it been exdusive?
`.
`It has been excluive anl continuous sime 20%.
`
`. Now, and that has grown since, mrrect?
`. Significantly.
`
`. Let's go to the fourth organization that's part of the
`Chaldean American Chamber of Commerce.
`. We have lad alfiliats and partners, are of III!’ other
`partners was the Claldean, Syriac, Assyrian Council of
`Ant-.rica, and also the Ninevdl Collidl of America.
`Thse organizations are focused on doing advocacy,
`locally, nationally and intanationally for the
`benefit of the persecuted Christians in the Middle
`
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`Pages 13 to 16
`
`

`
`MARTIN MANNA
`November 16, 2015
`
`Page 17
`
`East, again specifically Chaldean, Assyrian, Syriac.
`Q. Any others?
`A. Any other affiliates?
`Q. Or part of the organization, isn't there one dealing
`with healthcare?
`. Yes, there is also --
`It's part of the Chaldean America n Chamber of
`Commerce?
`Sure, it's called Project Bismutha. Bi smutha 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
`placa.
`So these all come within the umbrella of the Chaldean
`American Chamber of Commerce?
`. Yes, they do.
`Has this been part of the natural expansion growth of
`the Chaldean American Chamber of Commerce since 2001?
`
`Yes, it has, and again, as part of our mission was
`always to be proactive to the needs of our community
`locally, nationally, internationally.
`
`Page 18
`. The Trademark Trial and Appeal Board has a question
`regarding whether the Chaldean American Chamber of
`Commerce, your organization, has an acquired
`distinctiveness. Do you know whether your
`organization has an acquired distinctiveness?
`Y6.
`
`Why do you say that? Can you elaborate?
`Well, I look at it this way. There's been many
`instance 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 include
`the prime minister of Turkey, their foreign minister,
`the prime minister of Iraq, 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 coma to
`recognizing who is speaking on behalf of the
`community, if it involvs our members, whether abroad
`or on a national level.
`
`Q. Let's deal real quickly with the international and
`then we'll go back.
`Internationally, is the Chaldean American
`
`Page 19
`Chamber of Commerce recognized by these various
`international governments, sudw as Turkey, such as
`Syria, such as Iraq?
`Y6.
`How do you know that? How would —— how would the
`Trademark Trial and Appeal Board members know that
`that's the case?
`We have had several instanca in which we've beeru
`communicating directly with heads of state, just more
`recentiy the president of the Kurdistan regional
`government has come to Washington, D.C., and invited
`us for a one-on-one meeting with members of our
`community. We are there reprsenting the Chaldean
`American Chamber of Commerce and invited others at
`that meeting.
`Just last week we've hosted the Turkish
`consulate general from Chicago came into town, reached
`out to the Chaldean American Chamber of Commerce,
`asked if we could get community members involved and
`engaged. After the meeting the Turkish consulate
`himself personally has beeru communicating with me all
`weekend in regards to an inciderut in Brussels with one
`of the Chaldean Catholic priests.
`He's also requated that I communicate with
`His Excellency, our patriarch, Luis Sako, regarding a
`
`Page 20
`monument sign beiry erected in Brussels in which the
`Turkish government wanted us to intervene because they
`felt it migrt cause or iucite some regative raction
`by Turkish residents in that area.
`I've been in communication with the
`Chaldean Catholic bishop here, our church hierarchy in
`Iraq, and we we workhg with the Turkish goverrtnent.
`He is getting these orders from directly from Ankara,
`the capital of Turkey, and asked us to intervene to
`assist. That is just one examde.
`I have, you know, probably hundreds more of
`all of our work tha is belrg done on an irtemational
`level. We were rcently, when I say "recently,"
`within the last few years, guests of the Turkish
`govemmert in wlich they had a conference on the Arab
`Spring art! the relationiiip between Muslims and
`Christians. I was one of only tlree people ‘Invited
`from the United Stats to represert the Midlle Eastern
`Christian perspective as a repruentative of tie
`Chaldean American Clnmber of Comnerce.
`Now, has any other organization in America in any way,
`shape or form rivaled the Chaldean American Chamber of
`Commerce and what it is doing?
`No, not to my understanding.
`And this respondent, this organization in San Diego,
`
`Q.
`
`A.
`Q.
`
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`Pages 17 to 20
`
`

`
`MARTIN MANNA
`
`November 16, 2015
`
`Page 21
`
`have they done anything like this?
`Not that I'm aware of.
`And I'm trying to determine how important is that name
`and reputation, first of all, does the Chaldean
`American Chamber of Co mmerce have a repu tation7
`Of course it does.
`15 the reputation only internationally, these foreign
`countries overseas?
`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."
`But what about if there's, you know, like, well, you
`know, a San Diego or Ea st San Diego, does that really
`matter?
`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
`
`Page 22
`Hispanic Chamber of Commerce. This Hispanic Chamber
`of Commerce like the National Women's Businas
`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 l:he name and has
`been continuously using that name for several years.
`And the San Diego people never did such a thing. They
`never approached you about --
`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 inifially launched, the
`reason we were so concerned immediately is most of
`their materials on their website was material t:hat was
`just plagiarized fron1 our website.
`The photos that they used for their events
`were actually the photos from our events, and there's
`many other instance in which they were using our
`material.
`We‘ll get back to that later.
`You briefly identified the international
`relationship, which we'll go into later, but let me
`
`Page 23
`ask you, does the Chaldean American Chamber of
`Commerce have a national reputation?
`. Yes.
`What is that reputation?
`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.
`The United States government?
`For the United Stats govanment.
`Why do you say that?
`we have a great relationship with the current
`administration, previous administration, the U.S.
`State Department, several senators, several members of
`Congress, other govemment agencies.
`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?
`Yes.
`is that reputation a good one?
`It's a great one.
`And how important is the name of the Chaldean American
`Chamber of Commerce in terms of dealing with the
`United States government?
`It's extremely important. This is the organization
`that they look upon, again, for resources and the
`
`Page 24
`organization they go to for assistance and also the
`organization they go to when it come to setting
`policy and dealing with issues impacting minorities in
`the Middle East.
`You talking about the United States government looks
`to the Chaldean American Chamber of Commerce?
`. Absolutely.
`For assistance?
`. Yes.
`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?
`. Yes, for both.
`Could you explain.
`. Sure. In 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 committee, but also with the state House and
`the state Senate and many other departments within the
`state of Midiigan.
`Are there any other states in which the Chaldean
`American Chamber of Commerce has dealt besides
`Washington, DC?
`A. we have dealt with our states such as California,
`
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`
`

`
`MARTIN MANNA
`
`November 16, 2015
`
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`Page 25
`Illinois, and other states in which there may have
`been issue impacting Chaldeans. I remember more
`recently we had some Iraqi 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 IDENTIFICATION
`EXHIBIT I
`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?
`. Yes, sir.
`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.
`The reason I'm going to do that is to
`assist the Trademark Trial and Appeal Board to follow
`your testimony, as well as to assist you in order to
`
`Page 26
`
`streamline this process. Do you understand?
`I do.
`
`.
`
`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.
`Sure.
`. Please do.
`. Yeah. I was one of about 15 members of the Chaldean
`community that set out to help organize the Chaldean
`American Chamber of Commerce.
`And what year was that?
`2001.
`The same organization that's the petitioner here, you
`helped organize it in 2001.
`Correct.
`And has it been in continuous use since you began the
`organization?
`It's been exclusive and in continuous since 2001.
`Now, what is your other history prior to the Chaldean
`American Chamber of Commerce?
`Prior to the Chaldean American Chamber of Commerce I
`worked at a financial firm and until 2001, and I also
`started an organization called InterLink Media.
`InterLink Media was focused on helping start up new
`businesses and also did some advertising.
`
`.
`
`Page 27
`Interlink hdped estdalish the Oialdean
`News, which is a montliy publication, and also helped
`organize tie Bank of Mihigan, a community barlt.
`Q. So you have a deep bad<ground with the Gialdean
`community.
`A. Well, prior to the chamber I wasalso involved in an
`ormnization called CARE, Chaldean Americans Reaching
`and Encouraging, whidu was a youth-based organization,
`all volunteer-based organization that was affiiated
`with the Chaldean Catholic church focused on
`prserving the language, history and culture of tie
`Chaldean people.
`Are you Chaldean?
`. Yes
`Now, what is a Chaldean?
`Chddean by defnition are eastern right Catholic
`they speak Aramaic, the language of Christ, and have a
`history tlat spans some 5500 yeas. The Oualdeans are
`indigenous to Iraq, Syria, parts of Turkey and Iran.
`They're like tie American Indians of Iraq.
`All right And the sad story is, aren't like 90
`percent of Chaldeans, since the problems with the
`Muslims, like 90 percent have been driven out of their
`country?
`In 2003 whenthe U.S. invaded Iraq there was
`
`Page 28
`1.4 million Iraqi Christians. Today less than 2,000
`remain. There were 340 churches in operation in Iraq
`in 2003 and fewer than 40 remain today.
`since 2003, more than 80 churches in Iraq
`have been bombed, three quarters of our population has
`tied, and more recently because of the violence
`perpetuated against them by ISIS. The remaining
`villages in, Christian villages in northern Ira