Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA754666
`
`Filing date:
`
`06/27/2016
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`92059277
`
`Party
`
`Correspondence
`Address
`
`Submission
`
`Filer's Name
`
`Filer's e-mail
`
`Signature
`
`Date
`
`Attachments
`
`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, racho@cmda-law.com
`
`Other Motions/Papers
`
`Parrick R. Sturdy
`
`psturdy@cmda-law.com,dwaldenmayer@cmda-law.com, kueber-
`roth@cmda-law.com
`
`/s/Patrick R. Strudy
`
`06/27/2016
`
`Verification of Deponent Martin Manna Part 1 of 2.pdf(4229855 bytes )
`Verification of Deponent Martin Manna Part 2 0f 2.pdf(4360718 bytes )
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRIAL AND TRADEMARK APPEAL BOARD
`
`Registration No.:
`Mark:
`
`Filed:
`Registered:
`
`4,516,721
`SAN DIEGO EAST COUNTY CHALDEAN
`AMERICAN CHAMBER OF COMMERCE
`Novembers, 2013
`April 15,2014
`
`CHALDEAN AMERICAN CHAMBER OF
`COMMERCE,
`
`Petitioner.
`
`vs.
`
`Cancellation No. 92059277
`
`BEN K.ALASHO.
`
`Registrant.
`
`VERIFICATION OF DEPONENT
`
`I, having read the foregoing deposition consisting of my testimony at
`the aforementioned time and place, subject to the changes ill the attached errata
`sheet, do hereby attest to the correctness and truthfulness of the transcript.
`
`"Martin m^nna
`Dated:
`
`Certificate of Acknowledgement
`
`ss.
`
`) )
`
`)
`
`State of Michigan
`
`County of Wayne
`
`On thisxy, day of June, 2016. personally appeared before me, Martin Manna,
`known to be the individual described in and who executed the within and
`foregoing instrument, and acknowledged that he signed the same as his free and
`voluntary act and deed, for the use and purposes therein mentioned.
`
`Given under my hand and seal ofoffice this~?^ day ofJune, 2016.
`
`lstJ?ej>~^ Asf
`
`o^ML
`
`Notary Public. Wayne County. Michigan
`
`My Commission Expires: V^ Y'^-/
`
`EILEEN M. STONER
`NOTARY PUBLIC,STATE OF Ml
`COUNTY OF WAYNE
`MY COMMISSION EXPIRES Apr 4,2021
`ACTING IN COUNTY OF c^>AyfJ>^
`
`

`
`Page
`
`Line
`
`Change
`
`ERRATASHEET
`
`

`
`In The Matter Of:
`
`Chaldean American Chamber ofCommerce vs.
`
`Kalasho
`
`Martin Manna
`
`November 16, 2015
`
`/^IENENSTOCK
`
`*—^ NATIONWIDE COURT REPORTING &VIDEO
`www.bienenstock.com
`
`Bingham Farms/Southfield • Grand Rapids
`Ann Arbor • Detroit • Flint• Jackson• Lanstng• ML Clemens • Saginaw
`
`Original File MANNA_MARTIN.txt
`
`Min-U-Script® with Word Index
`
`

`
`Martin Manna
`
`November 16, 2015
`
`Page 3
`
`TABLE OF CONTENTS
`
`WITNESS
`
`PAGE
`
`MARTIN MANNA
`
`EXAMINATION
`
`BY MR. ACHO: 12
`
`EXHIBITS
`
`EXHIBIT
`
`(Exhibits attached to transcript.)
`
`Page 4
`
`PAGE
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`1
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`2
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`3
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`4
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`5
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`Chaldean American Chamber of Commerce vs.
`
`Kalasho
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Pagel
`
`Registration No:
`
`4,516,721
`
`Mark:
`
`SAN DIEGO EAST COUNTY CHALDEAN
`
`AMERICAN CHAMBER OF COMMERCE
`
`Filed:
`
`Registered:
`
`November 8, 2013
`
`April 15, 2014
`
`1 2
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`3 4 5
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`6
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`7 8 9
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`10
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`CHALDEAN AMERICAN CHAMBER OF
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`11
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`COMMERCE,
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`3
`
`Petitioner,
`
`v s .
`
`Cancellation No. 92059277
`
`BEN KALASHO,
`
`Registrant.
`
`The Deposition of MARTIN MANNA,
`
`Taken a t 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 6 . ACHO
`
`4 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
`
`5
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`6
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`7
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`EXHIBIT 1
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`EXHIBIT 2
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`EXHIBIT 3
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`EXHIBIT 4
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`EXHIBIT 5
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`EXHIBIT 6
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`EXHIBIT 7
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`EXHIBIT 8
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`EXHIBIT 9
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`EXHIBIT 10
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`EXHIBIT 11
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`EXHIBIT 12
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`EXHIBIT 13
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`EXHIBIT 14
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`EXHIBIT 15
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`EXHIBIT 16
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`EXHIBIT 17
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`EXHIBIT 18
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`EXHIBIT 19
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`EXHIBIT 20
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`Min-U-Script(!
`
`Bienenstock Court Reporting & Video
`
`(1) Pages 1
`
`Ph: 248.644.8888
`
`Toll Free:
`
`888.644.8080
`
`

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`

`
`Chaldean American Chamber of Commerce vs.
`
`Kalasho
`
`Martin Manna
`
`November 16, 2015
`
`1
`
`2
`
`3
`
`4
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`5
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`6
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`EXHIBIT 117
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`EXHIBIT 118
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`EXHIBIT 119
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`EXHIBIT 120
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`EXHIBIT 121
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`EXHIBIT 122
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`EXHIBIT 123
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`EXHIBIT 124
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`EXHIBIT 125
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`EXHIBIT 165
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`EXHIBIT 166
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`Page 11
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`PAGE
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`Page 9
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`EXHIBIT 132
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`EXHIBIT 134
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`EXHIBIT 137
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`23
`
`MARTIN MANNA,
`5
`6 was thereupon called as a witness herein, and after
`7 having first been duly sworn to testify to the truth,
`the whole truth and nothing but the truth, was
`
`8
`
`9 examined and testified as follows:
`
`10 MR. ACHO: Let this be known that this is
`11 the deposition of Martin Manna whois the president of
`12 the Petitioner, Chaldean American Chamber of Commerce.
`13 This deposition is being taken pursuantto the Code of
`14 Federal Regulations, 37 CFR 2.123 E, and pursuant to
`15 the Trademark Trial Appeal Board Rule Manual 703.01 R.
`16 It is also pursuantto 2.123 of the Trademark Rules of
`
`17 Practice.
`The notice of deposition was communicated
`18
`19 to the Respondent'sattorney, Martin Becker, on
`20 October 22nd, 2015, for this deposition on
`21 November 16,2015. I have not heard from Mr. Becker
`22 in three weeks, the attorney for the Respondent, and
`23 no one, Mr. Becker is not here and no one is here on
`24 behalf of the Respondent, San Diego East County
`25 Chaldean American Chamber of Commerce, that is why we
`
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`EXHIBIT 138
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`EXHIBIT 139
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`EXHIBIT 140
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`EXHIBIT
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`EXHIBIT
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`EXHIBIT 143
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`EXHIBIT 163
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`EXHIBIT 164
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`1 2 3
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`Livonia, Michigan
`Monday, November 16,2015
`
`9:00 a.m.
`
`Page 12
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`25
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`Page 10
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`PAGE
`
`1 2 3
`
`4
`
`Min-U-Scriptc
`
`Bienenstock Court Reporting & Video
`
`(3) Pages 9-12
`
`Ph: 248.644.8888
`
`Toll Free:
`
`888.644.8080
`
`

`
`Chaldean American Chamber of Commerce vs.
`
`Kalasho
`
`Page 13
`
`Martin Manna
`
`November 16, 2015
`
`Page 15
`
`1 are proceeding.
`
`2
`But I want the record to reflect that 30
`3 minutes ago I received notice of a fax sent by a man
`4 by the name of Ben Kalasho, who said that he wanted
`5 this matter adjourned. I have not heard from his
`6 counsel and I cannot recognize Mr. Kalasho anyway. He
`7 is not the representative for the organization for the
`8 purposes of this litigation. He is the registrant,
`
`9 but he is not the client and this notice was sent out
`10 three weeks ago and so we are proceeding.
`
`11
`
`12
`
`EXAMINATION
`
`BY MR. ACHO:
`
`13 Q. Would you please state your name.
`
`14 A. Martin Manna.
`
`15 Q. And where are you employed, sir?
`
`16 A. The Chaldean American Chamber of Commerce.
`
`17 Q. And where are the offices of the Chaldean American
`
`18 Chamber of Commerce?
`
`19 A. 30850 Telegraph Road in Bingham Farms, Michigan, and
`2 0
`360115 Mile Road, Sterling Heights, Michigan.
`21 Q. Now, you are the president of the organization?
`
`22 A. Correct.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`9
`
`support the many causes within the Chaldean community.
`It was also formed to help dispel the
`negative stereotypes that existed about Chaldeans,
`both here and abroad, and the organization also wants
`to act as an ambassador for the Chaldean, Assyrian,
`Syriac people throughout the world.
`7 Q. Let me ask you this. The Chaldean American Chamber of
`8 Commerce is really an umbrella which includes other
`organizations within it, correct?
`10 A. Yes, sir. Since our inception we've launched several
`affiliates and have many partner organizations and
`part of the mission is to represent Aramaic speaking
`people, again throughout the world.
`And so the organization has launched
`several affiliates, initially the Chaldean Chamber of
`
`11
`
`12
`
`13
`
`14
`
`15
`
`17
`
`18
`
`19
`
`20
`
`16 Political Action Committee which is involved
`politically. We've also launched many other
`affiliates including the Detroit Independent Grocers
`in which we were responding to negative stereotypes
`that existed about Detroit grocers in general and
`21 wanted to a better job of serving that segment of our
`population.
`
`22
`
`23 Q. How long have you been associated with the Chaldean
`
`23 Q. So that's two.
`
`Is there a third?
`
`2 4 American Chamber of Commerce?
`25 A. Since its inception and even prior to that in
`
`24 A. There are several others, sir.
`25 Q. Let's take it a step at a time. What is the third?
`
`Page 14
`
`Page 16
`
`organizing.
`1
`2 Q. Okay. And am I correct in that the organization began
`
`3
`
`in 2011?
`
`4 A. No, sir, in 2001.
`5 Q.
`I'm sorry, strike that.
`6
`The organization began in 2001?
`
`7 A. Correct.
`8 Q. Now, has it been operating since 2001?
`9 A. Yes, it has been in operation since 2001, exclusively
`and through that length and continuously as an
`10
`11
`organization representing the Chaldean American
`
`1 A. The Chaldean Community Foundation was launched in 2006
`as a means initially to help stop the violence against
`2
`3 Chaldean business owners. One of our founding members
`4 was killed in his place of business so he launched a
`foundation, our charitable arm, it's a 501(c)(3) that
`5
`6 was focused on providing reward money for those who
`are either injured or killed in their place of
`
`7
`
`business.
`8
`9 Q. Well now, just so I'm clear, has the Chaldean
`10 Community Foundation, which is part of the Chaldean
`11 American Chamber of Commerce, has it been in
`
`community.
`12
`13 Q. Has that continuous use been uninterrupted?
`14 A.
`It has been uninterrupted.
`15 Q. So it's been every day, every week, every month, every
`16
`year since 2001?
`
`12
`
`continuous use since 2006?
`
`13 A. Yes.
`14 Q. And has it been exclusive?
`
`It has been exclusive and continuous since 2006.
`15 A.
`16 Q. Now, and that has grown since, correct?
`17 A. Significantly.
`17 A. Correct.
`18 Q. Let's go to the fourth organizationthat's part of the
`18 Q. Now, the organization does what?
`19 A. The Chaldean American Chamber of Commerce represents 19 Chaldean American Chamber of Commerce.
`20 A. We have had affiliates and partners, one of our other
`20
`the Chaldean, Assyrian, Syriac community in many
`partners was the Chaldean, Syriac, Assyrian Council of
`21
`different aspects. One, it's to educate the general
`21
`22 America, and also the Ninevah Council of America.
`22
`public about the contributions Chaldeans are making;
`23 These organizations are focused on doing advocacy,
`23
`two, the organization also wants to be a network for
`locally, nationally and internationally for the
`others to understand who the Chaldean community is and
`24
`benefit of the persecuted Christians in the Middle
`25
`give them the ability to do business together and also
`
`24
`
`25
`
`Min-U-Script®
`
`Bienenstock Court Reporting & Video
`
`(4) Pages 13 - 16
`
`Ph: 248.644.8888
`
`Toll Free:
`
`888.644.8080
`
`

`
`Chaldean American Chamber o f Commerce v s .
`
`Kalasho
`
`Page 17
`
`Martin Manna
`November 16, 2015
`
`Page 19
`
`1 East, again specifically Chaldean, Assyrian, Syriac.
`2 Q. Any others?
`3 A. Any other affiliates?
`4 Q. Or part of the organization, isn't there one dealing
`
`5 with healthcare?
`
`6 A. Yes, there is also—
`
`1 Chamber of Commerce recognized by these various
`international governments, such as Turkey, such as
`Syria, such as Iraq?
`
`3
`
`2
`
`4 A. Yes.
`5 Q. How do you know that? How would —how would the
`6 Trademark Trial and Appeal Board members know that
`
`7 Q.
`
`It's part of the Chaldean American Chamber of
`
`7
`
`that's the case?
`
`8 Commerce?
`
`9 A. Sure, it's called Project Bismutha. Bismutha means
`10
`healing in Aramaic, our language, and Bismutha is
`focused on providing free healthcare for the uninsured
`11
`12
`in our community and we also have more recently
`
`13
`
`launched the Civil Liberties Advocates, CLA as I refer
`
`to it, is an organization that's focused on defending
`14
`the rights of members of our community who might be
`15
`discriminated against in the workforce or in other
`16
`places.
`17
`18 Q. So these all come within the umbrella of the Chaldean
`
`19 American Chamber of Commerce?
`
`20 A. Yes, they do.
`21 Q. Has this been part of the natural expansion growth of
`
`2 2
`the Chaldean American Chamber of Commerce since 2001 ?
`23 A. Yes, it has, and again, as part of our mission was
`
`24
`25
`
`always to be proactive to the needs of our community
`locally, nationally, internationally.
`
`9
`
`8 A. We have had several instances in which we've been
`communicating directly with heads of state, just more
`recently 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 representing the Chaldean
`
`10
`
`11
`
`12
`
`13
`
`14 American Chamber of Commerce and invited others at
`
`15
`
`that meeting.
`
`16
`
`17
`
`18
`
`19
`
`20
`
`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 been communicating with me all
`22 weekend in regards to an incident in Brussels with one
`23 of the Chaldean Catholic priests.
`He's also requested that I communicate with
`24
`25 His Excellency, our patriarch, Luis Sako, regarding a
`
`21
`
`Page 18
`
`Page 20
`
`1 Q. The Trademark Trial and Appeal Board has a question
`2
`regarding whether the Chaldean American Chamber of
`3 Commerce, your organization, has an acquired
`4
`distinctiveness. Do you know whether your
`5
`organization has an acquired distinctiveness?
`
`6 A. Yes.
`7 Q. Why do you say that? Can you elaborate?
`8 A. Well, I look at it this way. There's been many
`9
`instances where we've been called upon, again, not
`10
`just locally, but nationally and internationally, to
`be a representative of our community.
`11
`
`12
`
`And so the Chaldean American Chamber of
`
`13 Commerce has built a network and that network includes
`the prime minister of Turkey, their foreign minister,
`14
`15
`the prime minister of Iraq, many leaders and
`16
`dignitaries from Lebanon, members of Syria's
`government, members of the Kurdistan regional
`17
`18
`government, but also throughout various media outlets
`19 we are typically the source when it comes to
`recognizing who is speaking on behalf of the
`20
`21
`community, if it involves our members, whether abroad
`
`22
`or on a national level.
`23 Q. Let's deal real quickly with the international and
`24
`then we'll go back.
`25
`Internationally, is the Chaldean American
`
`1 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
`by Turkish residents in that area.
`
`2
`
`3
`
`4
`
`9
`
`10
`
`11
`
`12
`
`I've been in communication with the
`5
`6 Chaldean Catholic bishop here, our church hierarchy in
`Iraq, and we are working with the Turkish government.
`7
`8 He is getting these orders from directly from Ankara,
`the capital of Turkey, and asked us to intervene to
`assist. That is just one example.
`I have, you know, probably hundreds more of
`all of our work that is being done on an international
`level. We were recently, when I say "recently,"
`13
`14 within the last few years, guests of the Turkish
`government in which they had a conference on the Arab
`Spring and the relationship between Muslims and
`16
`17 Christians. I was one of only three people invited
`from the United States to represent the Middle Eastern
`18
`19 Christian perspective as a representative of the
`
`15
`
`22
`
`20 Chaldean American Chamber of Commerce.
`21 Q. Now, has any other organizationin America in any way,
`shape or form rivaled the ChaldeanAmerican Chamberof
`23 Commerce and what it is doing?
`24 A. No, not to my understanding.
`25 Q. And this respondent, this organization in San Diego,
`
`Min-U-Script®
`
`Bienenstock Court Reporting & Video
`
`(5) Pages 17 - 20
`
`Ph: 248.644.8888
`
`Toll Free:
`
`888.644.8080
`
`

`
`Chaldean American Chamber of Commerce vs.
`
`Kalasho
`
`Page 21
`
`Martin Manna
`
`November 16, 2015
`
`Page 23
`
`1
`
`have they done anything like this?
`
`2 A. Not that I'm aware of.
`3 Q. And I'm trying to determine how important is that name
`4
`and reputation, first of all, does the Chaldean
`5 American Chamber of Commerce have a reputation?
`
`6 A. Of course it does.
`
`7 Q.
`
`Is the reputation only internationally, these foreign
`
`8
`countries overseas?
`9 A. No, it's also here locally and on a national level.
`10
`This is why there's so much danger in anybody else
`11
`trying to duplicate the name "Chaldean American
`
`12 Chamber of Commerce."
`13 Q. But what about if there's, you know, like, well, you
`14
`know, a San Diego or East San Diego, does that really
`
`15 matter?
`
`16 A. Well sure it does.
`I think if you look historically
`in the context of other groups similar, or they may be
`17
`18
`ethnic in nature. I give you one example, the
`19 Hispanic community. There's a Hispanic Chamber of
`20 Commerce and there was a similar dispute and the
`21
`challenges are people recognize the name Chamber of
`22 Commerce and Hispanic as the core leading group here
`
`23
`
`24
`
`in southeast Detroit.
`
`The resolution was there should be a
`
`25 Hispanic business alliance but not necessarily a
`
`1
`
`ask you, does the Chaldean American Chamber of
`2 Commerce have a national reputation?
`
`3 A. Yes.
`
`6
`
`7
`
`4 Q. What is that reputation?
`5 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.
`8 Q. The United States government?
`9 A. For the United States government.
`10 Q. Why do you say that?
`11 A. We have a great relationship with the current
`administration, previous administration, the U.S.
`State Department, several senators, several members of
`14 Congress, other government agencies.
`15 Q. And you'll be able to back this up later in more
`specific detail about the national reputation of the
`
`12
`
`13
`
`16
`
`17 Chaldean American Chamber of Commerce?
`
`18 A. Yes.
`
`Is that reputation a good one?
`19 Q.
`It's a great one.
`20 A.
`21 Q. And how important is the name of the Chaldean American
`22 Chamber of Commerce in terms of dealing with the
`23 United States government?
`24 A.
`It's extremely important. This is the organization
`that they look upon, again, for resources and the
`
`25
`
`Page 22
`
`Page 24
`
`1 Hispanic Chamber of Commerce. This Hispanic Chamber
`
`2
`
`of Commerce like the National Women's Business
`
`3 Association wants to —creates chapters throughout
`4
`the country, so there's one representing body that is
`5
`affiliated with the core organizer, the host
`organization, the one that founded the name and has
`6
`7
`been continuously using that name for several years.
`8 Q. And the San Diego people never did such a thing. They
`9
`never approached you about —
`10 A. They did not approach us. Asa matter of fact, when
`11 we brought up the issue, not only did they not
`12
`approach us, they caused a ton of confusion because
`although it might be San Diego East County, the San
`13
`14 Diego East County portion of their name really was
`15
`never visible, and when they initially launched, the
`16
`reason we were so concerned immediately is most of
`
`their materials on their website was material that was
`17
`just plagiarized from our website.
`18
`The photos that they used for their events
`19
`20 were actually the photos from our events, and there's
`21 many other instances in which they were using our
`
`22 material.
`23 Q. We'll get back to that later.
`24
`You briefly identified the international
`25
`relationship, which we'll go into later, but let me
`
`1
`
`2
`
`3
`
`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
`
`4
`
`the Middle East.
`5 Q. You talking about the United States government looks
`
`6
`
`to the Chaldean American Chamber of Commerce?
`
`7 A. Absolutely.
`8 Q. For assistance?
`
`13
`
`9 A. Yes.
`10 Q. Now, in terms of the state, does the Chaldean American
`11 Chamber of Commerce have a reputation in the state of
`12 Michigan and does it have any reputation outside of
`the state of Michigan?
`14 A. Yes, for both.
`15 Q. Could you explain.
`16 A. 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
`19 of his committees, but also with the state House and
`the state Senate and many other departments within the
`state of Michigan.
`21
`22 Q. Are there any other states in which the Chaldean
`
`17
`
`18
`
`20
`
`23 American Chamber of Commerce has dealt besides
`
`24 Washington, D.C.?
`25 A. We have dealt with our states such as California,
`
`Min-U-Scriptc
`
`Bienenstock Court Reporting & Video
`
`(6) Pages 21 - 24
`
`Ph: 248.644.8888
`
`Toll Free:
`
`888.644.8080
`
`

`
`Chaldean American Chamber o f Commerce vs.
`
`Kalasho
`
`Page 25
`
`1
`2
`3
`4
`
`Illinois, and other states in which there may have
`been issues 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.
`5
`6 Q. Now, Mr. Manna, what I'm going to do, I'm going to
`7
`hand you the Petitioner's Exhibit Number 1.
`
`8
`
`9
`
`10
`
`11
`
`MARKED FOR IDENTIFICATION
`
`EXHIBIT 1
`
`9:19 a.m.
`
`BY MR. ACHO:
`
`12 Q. Now, you have before you, and I move for its
`13
`admission. I know it's not required, but all the
`14
`exhibits that I present I move for their admission.
`
`15
`16
`
`17
`
`Exhibit Number 1 is Petitioner's outline of
`trial testimony by deposition of Martin Manna, do you
`
`see that, sir?
`
`18 A. Yes, sir.
`19 Q. What I'm going to do, I'm going to direct your
`20
`attention to page number three. Now, Mr. Manna, what
`21
`I'm going to do, I am going to be asking you a series
`22
`of questions that are going to follow this outline.
`23
`The reason I'm going to do that is to
`24
`assist the Trademark Trial and Appeal Board to follow
`25
`your testimony, as well as to assist you in order to
`
`Martin Manna
`November 16, 2015
`
`Page 27
`
`1
`
`Interlink helped establish the Chaldean
`2 News, which is a monthly publication, and also helped
`organize the Bank of Michigan, a community bank.
`3
`4 Q. So you have a deep background with the Chaldean
`community.
`6 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,
`all volunteer-based organization that was affiliated
`
`5
`
`7
`
`8
`
`9
`
`11
`
`10 with the Chaldean Catholic church focused on
`preserving the language, history and culture of the
`12 Chaldean people.
`13 Q. Are you Chaldean?
`
`14 A. Yes.
`
`17
`
`18
`
`15 Q. Now, what is a Chaldean?
`16 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 Iraq, Syria, parts of Turkey and Iran.
`19
`20 They're like the American Indians of Iraq.
`21 Q. AH right. And the sad story is, aren't like 90
`percent of Chaldeans, since the problems with the
`22
`23 Muslims, like 90 percent have been driven out of their
`country?
`25 A.
`In 2003 when the U.S. invaded Iraq there was
`
`24
`
`Page 26
`
`Page 28
`
`1
`
`2
`
`3
`
`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.
`
`1
`
`streamline this process. Do you understand?
`
`2 A.
`
`I do.
`
`3 Q. Okay. Now, I will be asking you questions with
`4
`regards to each topic, so let's begin with this. Can
`5
`you give us your employment history.
`
`6 A. Sure.
`
`7 Q. Please do.
`
`8 A. Yeah.
`I was one of about 15 members of the Chaldean
`9
`community that set out to help organize the Chaldean
`
`10 American Chamber of Commerce.
`
`11 Q. And what year was that?
`
`12 A. 2001.
`13 Q. The same organization that's the petitioner here, you
`14
`helped organize it in 2001.
`
`15 A. Correct.
`16 Q. And has it been in continuous use since you began the
`17
`organization?
`
`18 A.
`It's been exclusive and in continuous since 2001.
`19 Q. Now, what is your other history prior to the Chaldean
`
`2 0 American Chamber of Commerce?
`
`21 A. Prior to the Chaldean American Chamber of Commerce I
`
`22 worked at a financial firm and until 2001, and I also
`started an organization called InterLink Media.
`23
`24
`InterLink Media was focused on helping start up new
`businesses and also did some advertising.
`25
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`Since 2003, more than 80 churches in Iraq
`have been bombed, three quarters of our population has
`fled, and more recently because of the violence
`perpetuated against them by ISIS. The remaining
`villages in, Christian villages in northern Iraq are
`no longer inhabited by the members of our community;
`and for the first time in 1600 years, Mosul has not
`celebrated mass on Sunday because of ISIS.
`11
`12 Q. Did you know that I was born in Bagdad myself?
`
`10
`
`I did not.
`13 A.
`14 Q. And that I am Chaldean. Well, let me ask you this.
`15 We are going to introduce later a book on the
`16 Chaldeans, it will be an exhibit, but can you - we're
`also going to introduce a book on Chaldeans in
`18 Detroit, but let me ask you this.
`Can you give us an overview of the
`immigrationhistory of Chaldean Americans coming to
`
`19
`
`20
`
`17
`
`the United States.
`21
`22 A. Well, Chaldeans have been coming to the United States
`since the early 1900s and quite a large segment of our
`community was leaving Iraq for better economic and
`religious freedoms that were offered here in United
`
`23
`
`24
`
`25
`
`Min-U-Script*
`
`Bienenstock Court Reporting & Video
`
`(7) Pages 25
`
`28
`
`Ph: 248.644.8888
`
`Toll Free:
`
`888.644.8080
`
`

`
`Chaldean American Chamber of Commerce vs.
`
`Kalasho
`
`1
`
`States.
`
`Page 29
`
`The majority of our population came later,
`2
`3 mainly the 1960s, as the Baath party came into power.
`4 Q. That's the one, the Baath that was founded by Saddam
`
`5 Hussein or —
`
`6 A. Yes, correct, by Saddam Hussein, that is the Baath
`7
`party. As they came into power, a large percentage of
`8 Chaldeans chose to leave, my family being one of them.
`I was the youngest of eight. I was born in
`9
`10 Detroit but five of my brothers and sisters were born
`11
`in Iraq, and my dad like so many others left because
`he was fearful that he was going to be persecuted for
`12
`13
`not believing in the ideology of Saddam Hussein or the
`
`party.
`14
`15 Q. Well, where did the Chaldeans from Iraq, which is
`16 where they're from, how did they —where did they
`
`17
`
`locate?
`
`18 A. Well, originally they came like all the other
`19
`immigrants to Ellis Island and eventually most came to
`2 0 Detroit, and Detroit was chosen like many other
`21 immigrant groups before them because of the automotive
`
`industry.
`22
`23 Q. Well, did Chaldeans then just go into the automotive
`24
`industry and become autoworkers like so many others?
`25 A. Well, they wanted to because of the allure of $5 a day
`
`Martin Manna
`
`November 16, 2015
`
`Page 31
`
`1
`
`2
`
`3
`
`owned liquor stores; so here in Detroit that was the
`
`same thing, they owned the majority of the liquor
`
`stores.
`
`4
`
`But it was also during a time in which the
`riots, the civil unrest was taking place in Detroit.
`6 Q. When was this?
`
`5
`
`7 A. This was the late 1960s.
`
`8 Q. Around 1967?
`9 A. Correct, and the chain stores abandoned the cities so
`10 Chaldeans pooled their monies together and bought most
`11 of the chain stores in the city of Detroit forming a
`large group of independent grocers. That continues
`today as 75,85 supermarkets in the city of Detroit
`are owned by Chaldeans, along with 90 percent of the
`convenience and liquor stores.
`15
`16 Q. And has there been —how would you describe the
`growth of Chaldeansin the United States since the
`
`12
`
`13
`
`14
`
`17
`
`18
`
`1960s?
`
`19 A. Well, we'll start here in Detroit and just look at the
`evolution of the community. You have a population now
`
`20
`
`21
`
`22
`
`23
`
`that's some 150,000 and it's not just the party store
`ownership anymore. The community here owns some
`
`15,000 businesses.
`
`24 Q. 15,000?
`25 A. 15,000.
`
`Page 30
`
`Page 32
`
`from Henry Ford, but again, many of them didn't speak
`1
`2
`the language, so they really couldn't work in the auto
`industries, and so like many Chaldeans before them,
`3
`they became entrepreneurs.
`4
`5 Q. Well, Chaldeans in Iraq, they were mostly merchants,
`6 weren't they?
`7 A. Many were, but if we look at 2003, we were 10 percent
`8 of the population, but 40 percent of the intellect; so
`9 Chaldeans were most of them physicians, they were
`attorneys, they were professors, but you're right,
`10
`11 most —the vast majority were merchants.
`12 Q. So what happened when they came to the Detroitarea
`13
`and when they didn't work in the auto plants?
`14 A. Well, like other immigrant groups, they tend to do
`15 whatever they could to provide for their families, but
`16
`they pooled their monies together and became very
`hard-working members and contributors to the local
`17
`18
`economy and started opening up businesses.
`19
`Initially it was —
`20 Q. What kind of businesses?
`21 A.
`Initially it was stores; so if you look at the city of
`22 Detroit, 90 percent of the convenience and liquor
`23
`stores are owned by Chaldeans, and the reason being is
`24
`even in Iraq as Christians, you know, Islam forbade
`the sale and consumption of alcohol, so Christians
`25
`
`1 Q.
`2 A.
`
`In the metro Detroit area?
`In the state of Michigan, and they have really
`
`3
`
`4
`
`dominated certain industries. So we talked about
`convenience stores and liquor stores, but let's look
`
`5
`
`6
`
`at hotels.
`Greater than 50 percent, 5-0,50 percent of
`hotels in southeast Michigan now are owned by
`7
`8 Chaldeans. One of our members has 100 hotels not just
`in Michigan but also Indiana, Ohio and other parts of
`the country and is building ten more currently.
`10
`11 Q. Is he a memberof the Chaldean American Chamber of
`
`9
`
`12 Commerce?
`13 A. Yes, and has been for at least 10 years if not more.
`
`16
`
`17
`
`14 We also h