Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA707605
`ESTTA Tracking number:
`11/09/2015
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`92062336
`Defendant
`Gary Kompothecras
`Gary Kompothecras
`PO BOX 25368
`Sarasota, FL 34277
`UNITED STATES
`Answer
`Jamie N. Pitts
`jamienpitts@jnplawfirm.com, greg.zitani@westcolaw.com
`/Jamie N. Pitts/
`11/09/2015
`Answer and Affirmative Defenses (filed).pdf(157380 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`
`ESTTA707605
`ESTTA Tracking number:
`11/09/2015
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`92062336
`Defendant
`Gary Kompothecras
`Gary Kompothecras
`PO BOX 25368
`Sarasota, FL 34277
`UNITED STATES
`Answer
`Jamie N. Pitts
`jamienpitts@jnplawfirm.com, greg.zitani@westcolaw.com
`/Jamie N. Pitts/
`11/09/2015
`Answer and Affirmative Defenses (filed).pdf(157380 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`In the Matter of Registration No. 3971311
`Mark: 1-800-CALL-GARY FOR AUTO INSURANCE
`Issued: May 31, 2011
`
`
`Gary's Insurance Agency, LLC,
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`
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` Petitioner,
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`v.
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`Gary Kompothecras,
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` Cancellation No. 92062336
`
`
`
`
`
`
`
` Respondent.
`
`
`ANSWER AND AFFIRMATIVE DEFENSES OF
`RESPONDENT GARY KOMPOTHECRAS
`
`Respondent, Gary Kompothecras (hereinafter “Respondent”), by its attorneys, hereby
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`
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`answers and responds to the allegations set forth in the Consolidated Petition dated September
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`28, 2015 for Cancellation (hereinafter “the Petition”) of Respondent’s 1-800-CALL-GARY FOR
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`AUTO INSURANCE mark and Design (hereinafter the “Mark”) filed by Petitioner Gary's
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`Insurance Agency, LLC (hereinafter “Petitioner”).
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`
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`For the convenience of the Board, the language of each allegation in the Petition to
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`Cancel is repeated below and is followed by Respondent’s answer to the corresponding
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`numbered paragraph.
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`1.
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`Petitioner Gary's Insurance Agency, LLC ("Petitioner"), a limited liability company duly
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`organized and existing under the laws of the State of New Jersey and having a principal place of
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`business at 610-618 West St. Georges Avenue, Linden, New Jersey 07036, believes that it will
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`
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`1
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`
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`be damaged by Registration No. 3,971,311 for the mark 1-800-CALL-GARY and Design (the
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`“1-800-CALL-GARY Registration”) and hereby petitions, in accordance with 37 C.F.R.
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`§2.111(b), to cancel said registration.
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`ANSWER TO PARAGRAPH 1: Respondent denies Registration No. 3,971,311 for the mark
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`1-800-CALL-GARY and Design will damage Petitioner. Respondent is without knowledge or
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`information sufficient to form a belief as to the truth of the remainder of allegations contained in
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`paragraph 1 of the Petition for Cancellation. Since Respondent can neither admit nor deny the
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`paragraph as written, Respondent must deny.
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`2.
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`To the best of Petitioner's knowledge, the name and address of the current Respondent of
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`the 1-800-CALL-GARY Registration is Gary Kompothecras ("Respondent"), an individual with
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`an address of P.O. Box 25368, Sarasota, Florida 34277.
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`ANSWER TO PARAGRAPH 2: Admitted.
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`3.
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`On October 13, 2009, Respondent filed an intent-to-use application, Serial No.
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`77/847662 to register the mark 1-800-CALL-GARY FOR AUTO INSURANCE and Design ("1-
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`800-CALL-GARY FOR AUTO INSURANCE Mark") for use in "[i]nsurance services, namely,
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`underwriting vehicle insurance" in International Class 036 ("Respondent's Application").
`
`ANSWER TO PARAGRAPH 3: Admitted.
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`4.
`
`On April 29, 2011, the United States Patent and Trademark Office ("USPTO") issued a
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`notice of acceptance of Respondent's application.
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`ANSWER TO PARAGRAPH 4: Admitted.
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`5.
`
`The 1-800-CALL-GARY FOR AUTO INSURANCE Mark registered on May 31, 2011,
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`under Registration No. 3,971,311.
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`ANSWER TO PARAGRAPH 5: Admitted.
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`2
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`6.
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`Upon information and belief, Respondent did not use the 1-800-CALL-GARY FOR
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`AUTO INSURANCE Mark in commerce prior to its 1-800-CALL-GARY Registration.
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`ANSWER TO PARAGRAPH 6: Denied.
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`7.
`
`Petitioner has applied for the following U.S. trademark registrations in the USPTO (the
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`"GARY'S AUTO INSURANCE Marks"):
`
`a.
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`b.
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`c.
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`GARY’S Serial No. 86478678
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`GARY’S INSURANCE Serial No. 86478773
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`GARY’S AUTO INSURANCE Serial No. 86478662
`
`ANSWER TO PARAGRAPH 7: Respondent is without knowledge or information sufficient to
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`form a belief as to the truth of the allegations contained in paragraph 7 of the Petition for
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`Cancellation. Since Respondent can neither admit nor deny the paragraph as written, Respondent
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`must deny.
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`8.
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`Since at least as early as April 1, 2002, Petitioner has been, and is now, using the
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`GARY’S AUTO INSURANCE Marks in connection with the sale of automobile insurance.
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`ANSWER TO PARAGRAPH 8: Respondent is without knowledge or information sufficient to
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`form a belief as to the truth of the allegations contained in paragraph 8 of the Petition for
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`Cancellation. Since Respondent can neither admit nor deny the paragraph as written, Respondent
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`must deny.
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`9.
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`Petitioner's use of the GARY'S AUTO INSURANCE Marks has been valid and
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`continuous since its date of first use.
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`ANSWER TO PARAGRAPH 9: Respondent is without knowledge or information sufficient to
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`form a belief as to the truth of the allegations contained in paragraph 9 of the Petition for
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`3
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`
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`Cancellation. Since Respondent can neither admit nor deny the paragraph as written, Respondent
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`must deny.
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`10.
`
`Petitioner's use of its GARY'S AUTO INSURANCE Marks pre-date the Respondent's
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`first use of, and application for registration of, the 1-800-CALL-GARY Mark, and establishes
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`the priority of Petitioner's GARY'S AUTO INSURANCE Marks.
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`ANSWER TO PARAGRAPH 10: Denied.
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`11.
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`Attached hereto as Exhibit “A” is a screen shot from the Internet Archive Wayback
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`Machine, located at URL www.archive.org showing the home page from Petitioner’s Website at
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`URL: www.garysautoinsurance.com, dating back to April 8, 2009, for use of the at least one of
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`GARY'S AUTO INSURANCE Marks.
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`ANSWER TO PARAGRAPH 11: Denied. Not one of Petitioner’s alleged marks appear on the
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`webpage at Exhibit “A.”
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`12.
`
`Petitioner has continued to use the GARY'S AUTO INSURANCE Marks to the present.
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`ANSWER TO PARAGRAPH 12: Denied.
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`13.
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`This is evidence of use of the mark by Petitioner which pre-dates Respondent’s alleged
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`first use of April 13, 2010.
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`ANSWER TO PARAGRAPH 13: Denied.
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`14. Petitioner's GARY'S AUTO INSURANCE Marks are symbolic of extensive goodwill
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`established by Petitioner, has acquired a high degree of recognition through continued use and
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`expenditures of time, effort and money in advertising and promotion, and serves as a unique
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`identifier of the services offered by Petitioner.
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`ANSWER TO PARAGRAPH 14: Denied.
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`4
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`
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`15.
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`Respondent's 1-800-CALL-GARY FOR AUTO INSURANCE Mark is similar to at least
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`one Petitioner's marks GARY'S AUTO INSURANCE Marks in that both marks incorporate the
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`"auto insurance" element with the name "Gary".
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`ANSWER TO PARAGRAPH 15: Denied.
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`16.
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`The services which bare Respondent's and Petitioner's marks are in the field of insurance
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`services.
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`ANSWER TO PARAGRAPH 16: Respondent is without knowledge or information sufficient
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`to form a belief as to the truth of the allegations contained in paragraph 16 of the Petition for
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`Cancellation. Since Respondent can neither admit nor deny the paragraph as written, Respondent
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`must deny.
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`17.
`
`Upon information and belief, Respondent's services with which it uses the 1-800-CALL-
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`GARY FOR AUTO INSURANCE Mark, as claimed in Respondent's Application, and the
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`services with which Petitioner uses its GARY'S AUTO INSURANCE Marks are offered
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`for sale and are sold through the same or similar channels of trade and consumers.
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`ANSWER TO PARAGRAPH 17: Respondent is without knowledge or information sufficient
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`to form a belief as to the truth of the allegations contained in paragraph 17 of the Petition for
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`Cancellation. Since Respondent can neither admit nor deny the paragraph as written, Respondent
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`must deny.
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`COUNT ONE
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`(ABANDONMENT)
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`18.
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`Petitioner hereby incorporates by reference and realleges each and every allegation set
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`forth in preceding paragraphs as if fully set forth at length herein.
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`
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`5
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`
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`ANSWER TO PARAGRAPH 18: Respondent incorporates by reference its responses to the
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`corresponding allegations of the Petition for Cancellation.
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`19.
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`Upon information and belief, Respondent is currently not using the 1-800- CALL-GARY
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`FOR AUTO INSURANCE Mark for the services for which the certificate of registration was
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`granted: “Insurance services, namely, underwriting vehicle insurance”, and has not used the
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`mark for such services for more than three consecutive years with no intent to reuse the mark.
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`ANSWER TO PARAGRAPH 19: Denied.
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`20.
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`Upon information and belief, Respondent has intentionally abandoned use of the 1-800-
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`CALL-GARY FOR AUTO INSURANCE Mark.
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`ANSWER TO PARAGRAPH 20: Denied.
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`COUNT TWO
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`(PRIORITY AND LIKELIHOOD OF CONFUSION)
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`21.
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`Petitioner hereby incorporates by reference and realleges each and every allegation set
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`forth in preceding paragraphs as if fully set forth at length herein.
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`ANSWER TO PARAGRAPH 21: Respondent incorporates by reference its responses to the
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`corresponding allegations of the Petition for Cancellation.
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`22.
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`All of the GARY'S AUTO INSURANCE Marks were used in commerce prior to the first
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`use in commerce of the 1-800-CALL-GARY FOR AUTO INSURANCE Mark, and Petitioner
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`has continuously used its GARY'S AUTO INSURANCE Marks in commerce thereafter.
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`ANSWER TO PARAGRAPH 22: Denied.
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`23.
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`All of the GARY'S AUTO INSURANCE Marks are senior in priority to the 1-800-
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`CALL-GARY FOR AUTO INSURANCE Mark.
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`ANSWER TO PARAGRAPH 23: Denied.
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`6
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`
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`24.
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` In view of the similarity of the respective marks of at least one of Petitioner’s
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`applications, and similar channels of trade and similar services offered by the respective parties,
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`Respondent's 1-800-CALL GARY FOR AUTO INSURANCE Mark and resemblance to at least
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`one of Petitioner's GARY'S AUTO INSURANCE Marks, previously used in the United States,
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`and not abandoned, as to be likely to cause confusion, or to cause mistake, or to deceive as to
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`source by suggesting that Respondent's goods are associated with or approved, endorsed,
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`affiliated, authorized or sponsored by Petitioner.
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`ANSWER TO PARAGRAPH 24: Denied.
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`
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`
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`FACTS AND AFFIRMATIVE DEFENSES
`
`In addition to the answers provided above Respondent hereby asserts the following facts
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`and affirmative defenses:
`
` 1.
`
`In 1996 Dr. Gary Kompothecras, (“Respondent") opened one of the first multi-
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`disciplinary medical clinics with the purpose of helping people injured in automobile accidents.
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`Respondent coupled providing care to patients injured in auto and other accidents with 1-800
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`ASK GARY, a patient and medical referral service in the early 2000’s.
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`2.
`
`Respondent is the founder and owner of several related companies who use the Mark at
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`issue, which include the following: AGIC, Inc., Palm Insure, Inc., Ask Gary Holdings, Inc.
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`Physicians Group, LLC 1st Health, Ask Gary, and WS Marketing, Inc. In addition to its insurance
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`business, Respondent also founded and owns 1-800-ASK-GARY (“ASK GARY”), which is one
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`of the more heavily advertised and utilized referral services throughout Florida, Minnesota, and
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`Kentucky.
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`
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`7
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`2.
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`Respondent has developed and used numerous trademarks in connection with its
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`insurance services, counseling, referral, and other services related to personal injuries resulting
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`from auto accidents, including in particular the 1-800-CALL GARY FOR AUTO INSURANCE,
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`1-800-ASK-GARY, and ASK GARY marks (collectively the “Marks”). In addition to the
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`registration of the Mark at issue in this case, Respondent has obtained two prior incontestable
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`federal registrations for very similar marks, including the following (the "Registrations"):
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`Word Mark
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`1-800-ASK-GARY
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`Goods and Services
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`IC 042. G & S: Telephone hot line counseling, namely offering advice
`regarding auto accidents, including personal injuries resulting from auto
`accidents. FIRST USE: 20030100. FIRST USE IN COMMERCE: 20030100
`
`Mark Drawing Code
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`(4) STANDARD CHARACTER MARK
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`Filing Date
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`March 9, 2005
`
`Original / Current Basis
`
`1A / 1A
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`Published for Opposition December 6, 2005
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`Registration Number
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`3063452
`
`Registration Date
`
`
`February 28, 2006
`
`Word Mark
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`ASK GARY
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`Goods and Services
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`IC 035. G & S: Promoting the goods and services of legal and healthcare
`service providers in connection with auto accidents, including personal
`injuries resulting from auto accidents, by providing referrals to legal and
`medical providers. FIRST USE: 20030100. FIRST USE IN COMMERCE:
`20030100
`
`Mark Drawing Code
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`(4) STANDARD CHARACTER MARK
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`Serial Number
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`Filing Date
`
`78595002
`
`March 25, 2005
`
`Original / Current Basis
`
`1A / 1A
`
`Published for Opposition October 24, 2006
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`Registration Number
`Registration Date
`
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`3195747
`January 9, 2007
`
`
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`8
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`3.
`
`Respondent has spent 10-15 million annually in advertising the 1-800-CALL GARY
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`FOR AUTO INSURANCE, 1-800-ASK-GARY, and ASK GARY family of marks (hereinafter
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`“Respondent’s Family of Marks”) in various media since the early 2000’s.
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`4.
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`Starting at least as early as 2007, the Respondent has advertised Mark by listing the
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`associated phone number 1-800-CALL GARY (1-800-225-5427) in various cities throughout the
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`state of Florida, Minnesota, and Kentucky in the Verizon Yellow Pages, Superpages.com,
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`EveryCarListed.com, Super pages Direct and other print and on-line telephone directories.
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`Expenditures for advertising the Mark in this specific medium alone total over $300,000
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`annually.
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`5.
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`Respondent also advertises the Mark on television, Facebook and other social media
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`sites, billboards, the sides of buildings, the tops of cars, and just about any other medium
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`imaginable. Respondent’s toll-free “ASK” number and catchy slogan blanket buses, billboards,
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`and Yellow Pages in at least three states.
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`6.
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`Dating back almost eight years ago, on January 27, 2008, Respondent purchased the
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`domain name http://www.1800callgary.com and launched a website to promote its insurance
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`business online. Respondent has advertised the Mark and the insurance services offered in
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`connection therewith using this domain name and website since its inception in January of 2008
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`up to present date.
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`7.
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`Due to Respondent’s lengthy and extensive marketing and use of the Marks over the past
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`12 years, Respondent has developed substantial recognition and goodwill in Respondent’s
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`Family of Marks.
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`FIRST AFFIRMATIVE DEFENSE
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`FAMILY OF MARKS
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`
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`9
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`8.
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`The family feature in Respondent’s Family of Marks is inherently distinctive and all of
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`the Marks are used in such a way as to create the public perception of the common feature as an
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`indication of Respondent being the single source.
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`SECOND AFFIRMATIVE DEFENSE
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`PRIORITY AND ABSENCE OF LIKELIHOOD OF CONFUSION
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`9.
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`Registrant owns valid prior rights in the Mark, and on information and belief, such rights
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`pre-date any use or application by Petitioner. Registrant’s registered and common-law rights in
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`its Mark, on information and belief, pre-date use of any similar mark by Petitioner. Having made
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`continuous use of and established goodwill in the same predating Petitioner’s first use,
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`Respondent is the senior user of the Mark.
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`10.
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`There is no likelihood of confusion, mistake or deception of the purchasing public
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`because Respondent’s Mark and the alleged marks of Petitioner are not confusingly similar.
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`When considered in their entireties, Respondent’s mark is distinctly different from Petitioner’s
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`marks in concept, sound and appearance.
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`11.
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`Alternatively, the only similarity between the marks not otherwise disclaimed is “Gary”.
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`There are a considerable number of trademarks used and registered in the United States by third
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`parties in connection with providing insurance services, which include the word “Gary” as part
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`thereof. The proliferation of such third party usage, application and registration, serves to narrow
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`the scope of protection to which Petitioner’s alleged marks are entitled and forecloses
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`Petitioner’s right to bar Registrant’s use and/or registration of its Mark and Design.
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`12.
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`Further, Petitioner only markets services to individuals within the state of New Jersey.
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`Respondent markets in the states of Florida, Minnesota, and Kentucky. Due to the conditions and
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`activities surrounding the marketing of Petitioner and Respondent’s services are such that they
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`10
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`
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`would not be encountered by the same persons and the dissimilarity of the marks, there is no
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`likelihood that purchasers would be confused as to the source of the services and/or goods.
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`THIRD AFFIRMATIVE DEFENSE
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`NO ABANDONMENT
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`13.
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`The Mark has been used in connection with the same services recited in the registration
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`continuously either by Respondent or companies controlled by Respondent since the Statement
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`of Use was filed for the Mark.
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`14.
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`As Respondent has exercised control over the nature and quality of the services on or in
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`rendered under the Mark is used with respect to any and all related-company use of the Mark, the
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`related company’s use of the Mark inures to the benefit of Respondent.
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`15.
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`Any non-use by Respondent is excusable due to several pending litigations and state
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`administrative actions involving the business which operates under the Mark at issue.
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`16.
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`The fact that Respondent has spent millions litigating its rights in connection with the
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`Mark and has actively defended its right to conduct its business in various proceedings
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`throughout the time in which the Mark has been registered rebuts any possible inference of
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`abandonment or intent not to use the Mark.
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`FOURTH AFFIRMATIVE DEFENSE
`
`LACHES, ACQUIESCENCE AND/OR ESTOPPEL
`
`17.
`
`Respondent has been using and developing consumer recognition and goodwill in
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`Respondent’s Family of Marks since at least 2003. Respondent’s use has been open, notorious
`
`and known to Petitioner, at least constructively since the subject Mark’s registration date of May
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`31, 2011. During this time Petitioner failed to take any action to assert the claims on which it
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`bases this Cancellation, Respondent has relied on Petitioner’s inaction to its detriment.
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`
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`11
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`
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`Petitioner’s claims are consequently barred by the doctrines of laches, acquiescence and/or
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`estoppel.
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`18.
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`In the present case, Respondent filed the application for the subject Mark October 13,
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`2009, the Mark was published for opposition on August 17, 2010; issuance of respondent's
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`registration on the Principal Register occurred on May 31, 2011; and the petition for cancellation
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`was not filed until September 28, 2015. As this comprises four years and 4 months since the
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`registration date of Respondent’s Mark at issue, the delay by Petitioner in this case is significant,
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`undue, and will result in material prejudice to Respondent.
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`19.
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`During the period of Petitioner’s delay there has been a substantial change in the
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`economic position of Respondent. Adding weight to the evidence of prejudice to Respondent is
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`the economical prejudice stemming from Respondent’s significant financial investment in and
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`development of the Mark, and the continued commercial use and economic promotion of the
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`Mark over this prolonged period of delay.
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`20.
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`Prejudice to Respondent is further compounded by the vast amounts of time, effort, and
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`financial resources that have been invested over the past five years in an effort to expand the
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`business operating under the Mark. During this time Respondent has spent hundreds of
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`thousands of dollars in advertising the Mark annually, millions have been spent annually on the
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`brand as a whole. Additionally, Respondent has also spent in several million dollars litigating
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`cases involving the Mark and related businesses.
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`21.
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`Thus, Petitioner’s undue delay, coupled with the extent of Respondent’s detriment
`
`attributable to Petitioner’s inaction, should compel a finding of laches, acquiescence and/or
`
`estoppel in this case.
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`FIFTH AFFIRMATIVE DEFENSE
`
`
`
`12
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`
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`
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`GENERICNESS AND DESCRIPTIVENESS
`
`22.
`
`Petitioner is asserting rights unregistered marks which are generic, or, in the alternative,
`
`merely descriptive of the goods and/or services offered under Petitioner’s marks, without
`
`acquired distinctiveness. Petitioner’s alleged marks are therefore inherently unprotectable.
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`SIXTH AFFIRMATIVE DEFENSE
`
`23.
`
`Respondent will assert any other affirmative defenses or compulsory or permissive
`
`counterclaims that may be developed throughout discovery and testimony periods in this
`
`proceeding.
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`
`
`WHEREFORE, Respondent respectfully requests that judgment be entered in favor of
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`Respondent and the Petition for Cancellation be dismissed in its entirety with prejudice.
`
`Respondent hereby appoints Jamie N. Pitts, a member of the Bar of the State of Florida,
`
`
`
`and Gregory A. Zitani a member of the Bar of the State of Florida and California at the firms
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`listed below to act as attorneys in the matter of the cancellation identified above, to prosecute
`
`said cancellation, to transact all business in the Patent and Trademark Office, and in the United
`
`States courts connected with the cancellation, to sign its name to all papers which are hereinafter
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`to be filed in connection therewith, and to receive all communications relating to the same.
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`
`
`Respectfully submitted this day the 9 November 2015.
`
` By: /
`Jamie N. Pitts, Esq.
`The Law Office Of Jamie N. Pitts, Esq.
`887 West Marietta Street NW, Suite M105
`Atlanta, GA 30318
`Phone: (941) 893-7751
`
`_
`
`
`
`13
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`
`
`E-mail: jamienpitts@jnplawfirm.com
`
`By: Gregory A. Zitani
`Gregory A. Zitani, Esq.
`West Coast Law, LLC
`4046 Sawyer Rd Ste D
`Sarasota, FL 34233
`Phone: (941) 552-0373
`E-mail: greg.zitani@westcolaw.com
`
`Attorneys for Registrant
`Gary Kompothecras
`
`
`
`
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`
`
`14
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`CERTIFICATE OF SERVICE
`
`
`I hereby certify that a true and complete copy of the foregoing Answer and Affirmative
`
`
`
`Defenses has been served on RICHARD L RAVIN by mailing said copy on Monday, November
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`9th, 2015, via First Class Mail, postage prepaid to:
`
`15
`
`RICHARD L RAVIN
`
`HARTMAN & WINNICKI PC
`
`74 PASSAIC STREET
`
`RIDGEWOOD, NJ 07450
`
`UNITED STATES
`
`rick@ravin.com
`
`
`
`
`
`By:
` Jamie N. Pitts, Esq.
`
`
`
`
`
`Date: November 9th, 2015
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