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Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA734491
`
`Filing date:
`
`03/18/2016
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`92063123
`
`Party
`
`Correspondence
`Address
`
`Submission
`
`Filer's Name
`
`Filer's e-mail
`
`Signature
`
`Date
`
`Attachments
`
`Defendant
`Triple B Construction Inc.
`
`TRIPLE B CONSTRUCTION INC
`208 C SOUTHWEST PARKWAY EAST
`COLLEGE STATION, TX 77840
`UNITED STATES
`
`Answer
`
`Bryan T. Hanna
`
`bryan.hanna@westwebblaw.com
`
`/Bryan T. Hanna/
`
`03/18/2016
`
`Defendant's Answer to Petition for Cancellation.pdf(219530 bytes )
`Ltr Answer.pdf(77191 bytes )
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`TRADEMARK TRIAL AND APPEAL BOARD
`
`
`CANCELLATION NO. 92063123
`REGISTRATION NO. 3238468
`
`Mark: HANDI HOOK
`
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`
`
`VARTAN KHAZADIAN,
`
`
`
` Plaintiff,
`
`
`vs.
`
`TRIPLE B CONSTRUCTION INC.,
`
`
`
` Defendant.
`
`
`
`DEFENDANT’S ORIGINAL ANSWER
`
`
`
`
`
`
`
`TO THE HONORABLE JUDGE OF SAID COURT:
`
`TRIPLE B CONSTRUCTION, INC. hereby responds to the Petition for Cancellation for
`
`Trademark Registration #3238468 (the “Petition”) with the following numbered paragraphs
`
`which correspond to the paragraph numbers in the Petition.
`
`1.
`
`Triple B Construction Inc. denies that Plaintiff is entitled to the relief sought in
`
`the Petition. Triple B Construction Inc. admits that it is the owner of the trademark for “Handi
`
`Hook.” Triple B Construction Inc. is without sufficient information to form a belief as to the
`
`truth of the allegations contained in the remainder of Paragraph 1 and therefore denies the
`
`allegations contained therein.
`
`2.
`
`Triple B Construction Inc. admits it provided a specimen to the Commissioner of
`
`Trademarks on March 16, 2013. Triple B Construction Inc. admits that the registration of its
`
`trademark was continued. Triple B Construction Inc. is without sufficient information to form a
`
`belief as to the truth of the allegations contained in the remainder of Paragraph 2 and therefore
`
`denies the allegations contained therein.
`
`DEFENDANT’S ORIGINAL ANSWER
`
`PAGE 1
`
`

`
`3.
`
`Triple B Construction Inc. is without sufficient information to form a belief as to
`
`the truth of the allegations contained in the remainder of Paragraph 3 and therefore denies the
`
`allegations contained therein.
`
`4.
`
`Triple B Construction Inc. is without sufficient information to form a belief as to
`
`the truth of the allegations contained in the remainder of Paragraph 4 and therefore denies the
`
`allegations contained therein.
`
`5.
`
`Triple B Construction Inc. is without sufficient information to form a belief as to
`
`the truth of the allegations contained in the remainder of Paragraph 5 and therefore denies the
`
`allegations contained therein.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Defendant Triple B Construction, Inc. respectfully requests that
`
`Plaintiff’s Petition for Cancellation of Trademark Registration #3238468 be dismissed and award
`
`such other relief, at law or in equity, as may be necessary and appropriate and to which Triple B
`
`Construction, Inc. has shown itself to be justly entitled.
`
`Respectfully submitted,
`
`WEST, WEBB, ALLBRITTON & GENTRY, P.C.
`
`
`
`By: _/Bryan T. Hanna/____________
`
`Bryan T. Hanna
`Texas State Bar No. 24069873
`Email: bryan.hanna@westwebblaw.com
`1515 Emerald Plaza
`College Station, Texas 77845
`Telephone ~ 979.694.7000
`Facsimile ~ 979.694.8000
`
`ATTORNEYS FOR DEFENDANT
`
`
`
`
`
`DEFENDANT’S ORIGINAL ANSWER
`
`PAGE 2
`
`

`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and complete copy of the foregoing Defendant’s Original
`Answer has been served on Vartan Khazadian by mailing said copy on March 18, 2016, via First
`Class Mail, postage prepaid and certified mail, return receipt requested to:
`
`Vartan Khazadian
`P.O. Box 135
`Bethel, CT 06801
`
`Via First Class Mail and CM/RRR
`
`
`
`
`
`/Bryan T. Hanna/
`
`
`
`
`
`
`
`
`DEFENDANT’S ORIGINAL ANSWER
`
`PAGE 3
`
`

`
`WEST, WEBB, ALLBRITTON & GENTRY
`A PROFESSIONAL CORPORATION
`
`A TTORNEYS:
`
`STEVEN N. ALLBRITTON +
`ROY D. BRANTLEY * +
`DONALD DELGADO
`TERRANCE D. DILL, JR. +
`PATRICK W. FOGARTY
`MICHAEL H. GENTRY "" +
`BRYAN T. HANNA ****
`JENNIFER D. JASPER +
`AARON B. MICHELSOHN
`BAILI B. RHODES
`JOHN "JAY" RUDINGER, JR.
`WELDON RUSSELL ""‘
`JOHN C. WEBB, JR. +
`GAINES WEST +
`
`OF COUNSEL:
`
`COURTNEY S. CAIN
`
`‘BOARD CERTIFIED
`PERSONAL INJURY TRIAL LAW
`TEXAS BOARD OF LEGAL SPECIALIZATION
`
`"BOARD CERTIFIED
`COMMERCIAL REAL ESTATE LAW
`TEXAS BOARD OF LEGAL SPECIALIZATION
`
`— Established in 1982 —
`
`March 18, 2016
`
`PRINCIPAL OFFICE
`1515 EMERALD PLAZA
`COLLEGE STATION, TEXAS 77845-1515
`TELEPHONE: (979) 694-7000
`FACSIMILE: (979)694-8000
`1106 WEST AVENUE
`AUSTIN. TEXAS 78701-2020
`TELEPHONE:
`(512) 501-3617
`
`WEB SITE: hltp://www.westwebb|aw.com
`
`Writer's e-mail: bryan.hanna@weslwebb|aw.com
`
`+ Parlner
`
`“’ BOARD CERTIFIED
`ESTATE PLANNING AND PROBATE LAW
`TEXAS BOARD OF LEGAL SPECIALIZATION
`
`"""" REGISTERED PATENT ATTORNEY
`U.S. PATENT & TRADEMARK OFFICE
`
`Via Regular First Class Mail, Postage Prepaid and
`Via CMIRRR# 7015 0640 0002 6212 5025
`
`Vartan Khazadian
`P.O. Box 135
`
`Bethel, CT 06801
`
`Re:
`
`Defendant’s Answer to Cancellation Petition
`
`Enclosed please find the Defendant's Answer to the Petition for Cancellation of
`Registration No. 3238468 (Cancellation No. 92063123) filed with the USPTO Trademark Trial
`and Appeal Board.
`
`Sincerely,
`
`'
`
`9
`
`Bryan T. Hanna
`
`Enclosure
`
`27787:Ltr Answer

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