Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA737641
`
`Filing date:
`
`04/04/2016
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Petition for Cancellation
`
`Notice is hereby given that the following party requests to cancel indicated registration.
`
`Petitioner Information
`
`Name
`
`Entity
`
`Address
`
`Attorney informa-
`tion
`
`Touchnet Information Systems, Inc.
`
`Corporation
`
`Citizenship
`
`Kansas
`
`15520 College Boulevard
`Lenexa, KS 66219
`UNITED STATES
`
`I. Edward Marquette
`Kutak Rock LLP
`2300 Main Street Suite 800
`Kansas City, MO 64108
`UNITED STATES
`trademarks@kutakrock.com Phone:(816) 960-0090
`
`Registration Subject to Cancellation
`
`Registration No
`
`4502329
`
`Registration date
`
`03/25/2014
`
`Registrant
`
`Hazim Ansari
`191 West Second Street
`Santa Ana, CA 92701
`UNITED STATES
`
`Goods/Services Subject to Cancellation
`
`Class 009. First Use: 2013/09/01 First Use In Commerce: 2013/09/01
`All goods and services in the class are cancelled, namely: Computer software for identifying, via
`searching a third party patent database or a patent database contained within the computer software,
`and evaluating, viaanalysis of patents within a database, intellectual property related to at least one
`field; computer software for providing a web platform for, via searching athird party patent database
`or a patentdatabase contained within the computer software, and evaluating, via analysis of patents
`within a database, intellectual property; computer software for allowing users to access, evaluate,
`and synthesize information and generate reports related to intellectual property assets; Computer
`software for creating searchabledatabases of information and data; Computer software platforms for
`allowing users to access, evaluate, and synthesize information and generate reports related to intel-
`lectual property; Computer software that provides information from various databases and presents it
`in an easy-to-understand user interface; Computer software that provides intellectual property inform-
`ation, and more specifically, patents, from various databases and presents it in an easy-
`to-understand user interface; Computer software that providesweb-based access to applications and
`services through a web operating system orportal interface
`
`Class 035. First Use: 2013/09/01 First Use In Commerce: 2013/09/01
`All goods and services in the class are cancelled, namely: Business advice and information; Business
`advisory services in the field of newproduct research and development; Business consultation and
`management regarding marketing activities and launching of new products; Business consultation in
`the field of new product research and development; Business research services in the field of intellec-
`tual property analysis; Business services, namely, structuring, optimizing and change management
`consulting related to corporate in-house intellectual property departments and intellectual property
`
`

`
`asset management programs; Collection and compilation of information into computer databases in
`the field of intellectual property; Collection and systematization of information into computer data-
`bases; Computer-assisted business information and research services; Providing business informa-
`tion via awebsite; Providing information in the fields of business innovation process, business man-
`agement and business opportunities
`
`Class 042. First Use: 2013/09/01 First Use In Commerce: 2013/09/01
`All goods and services in the class are cancelled, namely: Providing a members-only website featur-
`ing technology which provides members with the ability to quickly and efficiently evaluate intellectual
`property; Providing a secure electronic online system featuring technology which allows for efficient
`evaluation of intellectual property; Providing a secured-access, members only website featuring tech-
`nology that gives members the ability to identify and evaluate intellectual property; Providing a web-
`site that features technology that enables the secure exchange of information by users; Providing an
`interactive website featuring technology that allowsusers to access, evaluate, and synthesize inform-
`ation and generate reports for use in consulting with research and development; Research and devel-
`opment and consultation related thereto in the field of intellectual property
`
`Class 045. First Use: 2013/09/01 First Use In Commerce: 2013/09/01
`All goods and services in the class are cancelled, namely: Legal document preparation and research-
`services for attorneys; Legal research;Legal services; Legal services, namely,intellectual property
`consulting services in the field of invention, identification, strategy, analytics, and invention; Licensing
`of intellectual property; Licensing of software for management of intellectual property; Patent licens-
`ing; Providing a web site that features information on the development of international law, regula-
`tions, legal policies, and legal practices in a manner that promotes global governance by all types of
`organizations; Providing an online interactive database featuring legal information
`
`Grounds for Cancellation
`
`Fraud on the USPTO
`
`Other
`
`Trademark Act section 14;In re Bose Corp., 580
`F.3d 1240, 91 USPQ2D 1938 (Fed. Cir. 2009)
`
`Overly broad description/failure to use the mark
`to the full extent of the description recited in the
`goods and services (Aries Systems Corporation
`v. World Book, Inc., 26 USPQ2d 1926 WL
`222336 (TTAB 1993)
`
`Attachments
`
`Petition to Cancel.pdf(3258805 bytes )
`
`Certificate of Service
`
`The undersigned hereby certifies that a copy of this paper has been served upon all parties, at their address
`record by First Class Mail on this date.
`
`Signature
`
`/I. Edward Marquette/
`
`Name
`
`Date
`
`I. Edward Marquette
`
`04/04/2016
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the Matter of Registration No. 4,502,329
`
`Registered: March 25, 2014
`Mark: RECON
`
`) ) )
`
`) )
`
`) Cancellation No.
`)
`
`) )
`
`)
`
`TOUCHNET INFORMATION SYSTEMS, INC.
`
`Petitioner,
`
`v.
`
`HAZIM ANSARI
`
`Respondent.
`
`TouchNet Information Systems, Inc. (“Petitioner”), a corporation organized and
`existing under the laws of Kansas with a principal place of business at 15520 College
`Boulevard, Lenexa, Kansas 66219 believes that it has been and will continue to be
`
`damaged by U.S. Trademark Registration No. 4,502,329 for the mark RECON
`(the “RECON Registration”), and hereby petitions for cancellation of the same. In the
`
`alternative, Petitioner hereby petitions for partial cancellation of the RECON Registration
`
`and/or modification of the description of the goods and/or services listed in the RECON
`
`Registration.
`
`As grounds for cancellation, Petitioner alleges as follows:
`
`1.
`Petitioner is an innovator and acknowledged leader in campus commerce and
`provides a variety of technology—based goods and services associated therewith, including
`related financial transactions involving debit cards, credit cards, and like electronic
`payment facilities, including both computer programs that reside on clients’ servers and
`computer programs that are not downloadable, but instead, reside on Petitioner’s servers,
`
`offering the functionality of such programs as a service.
`
`2.
`
`Petitioner has invested time, effort, and money marketing and preparing to market
`
`goods and services using the trademark RECON 1 (the “RECON 1 Mark”).
`
`3.
`
`Petitioner has used the RECON 1 Mark in interstate commerce in the United
`
`States continuously since November 13, 2014 in connection with payment processing
`cost data reporting reconciliation and simplification to its numerous clients, primarily
`bursar’s offices in colleges and universities.
`
`4842-0398-3917.2
`
`

`
`4.
`
`Attached hereto as Exhibit 1 are copies of trade show advertising materials
`
`showing Petitioner's use of the RECON 1 Mark in connection with Petitioner’s services
`
`associated with payment processing cost reporting reconciliation and simplification.
`
`5.
`
`Petitioner filed a trademark application for the RECON 1 Mark on
`
`November 26, 2014 (Ser. No. 86/466,041).
`
`6.
`
`The USPTO issued a non-final office action dated March 20, 2015. The non-final
`
`office action rejected Petitioner’s application based on an alleged likelihood of confusion
`
`with the RECON Registration.
`
`Petitioner responded to the non-final office action on September 21, 2015, arguing
`7.
`against the rejection based on the utter dissimilarity of the products and services and the
`
`complete separation of the respective customers/clients and trade charmels.
`
`8.
`
`Despite Petitioner’s compelling arguments, the USPTO issued a final office action
`
`dated October 10, 2015. The final office action maintained the likelihood of confusion
`
`rejection.
`
`Upon information and belief, Hazim Ansari (“Respondent”), an individual with
`9.
`an address at 191 West Second Street Santa Ana, California 92701, is the current owner
`
`of the RECON Registration, based on the publicly available records of the United States
`
`Patent and Trademark Office (the “USPTO”).
`
`FAILURE TO SUBMIT EVIDENCE OF USE
`
`10.
`
`An application for the RECON Registration was filed on June 1, 2012
`
`(the “RECON Application”).
`
`The USPTO issued a Notice of Allowance for the RECON Application on
`11.
`April 23, 2013.
`
`12.
`
`Respondent submitted a purported specimen of use (attached as Exhibit 2) and
`
`Statement of Use (attached as Exhibit 3) on October 18, 2013, the purported specimen
`being characterized as a “WebPage.”
`
`13.
`
`The purported specimen does not, in fact, show use in commerce of RECON. At
`
`best, the purported specimen displays “RECONIP,” and there is good reason to believe
`
`that the purported specimen does not, in fact, demonstrate any exposure to the public at
`
`all (See paragraph 15).
`
`14.
`
`The RECON Registration should be cancelled because Respondent has failed to
`
`provide evidence of use of RECON as a mark in commerce, as required by the Lanham
`Act.
`
`4842-0398-3917.2
`
`

`
`FAILURE TO MAKE A BONA FIDE USE OF THE MARK IN COMMERCE
`
`Upon information and belief, the screens depicted in the screenshots provided in
`15.
`the specimen for the RECON Registration are not currently available to the public and, in
`all likelihood, have never been available to the public.
`'
`
`16.
`
`In the Statement of Use, Petitioner states that the specimen includes various
`
`screenshots of various screens of a website “reconip.com.” NONE of the screenshots,
`
`however, includes an address bar or other designation indicating that they were actually
`taken from a website or that they were ever available through a website to which the
`public was ever exposed or had access.
`
`17.
`
`It is the impression on the mind of the consumer that is crucial to trademark law
`
`in the United States, and if the public is not exposed to a trademark, no impression is
`possible. A valid specimen, therefore, must demonstrate that it was, somehow, exposed
`to the public.
`
`Attached hereto as Exhibit 4 is a screenshot of the publicly accessible website
`18.
`“reconip.com” as it existed on January 25, 2016. The various screens submitted as
`
`specimens to establish use in commerce of the RECON Registration by Respondent
`APPEAR NOWHERE on this publically accessible website. Instead, there is merely a
`single screen indicating that the website will be available at a future time, i.e., “Coming
`Soon.”
`
`19.
`
`Attached hereto as Exhibit 5 is a screenshot of a website “web.archive.org”
`
`indicating that the website “reconip.com” has not been archived as of January 28, 2016.
`
`20.
`
`There is, therefore, no publicly accessible evidence that reconip.com has ever
`
`carried a message to the public other than “Coming Soon.”
`
`The RECON Registration should be cancelled because Respondent has failed to
`21.
`make a bona fide use of the mark RECON in commerce.
`
`FRAUD
`
`22.
`
`Attached hereto as Exhibit 6 is a copy of a print-out from a website
`
`“whois.icarm.org” indicating that the domain name “reconip.com” was created on June 1,
`
`2012 and that an individual named Sona Dalal is the Registrant for such domain name.
`
`23.
`
`Attached hereto as Exhibit 7 is a copy of a print-out from a website
`
`“aihitdata.com” indicating that Respondent, Hazim Ansari, is CEO of an alleged
`
`company named “RECONIP” and that Sona Dalal is COO of that same alleged company.
`
`4842-03 98-39 1 7.2
`
`

`
`Upon information and belief, Respondent is currently aware that the various
`24.
`screens allegedly depicted by the screenshots provided in the specimen are not, and have
`
`never been, available on the said website for public viewing.
`
`Upon information and belief, Respondent was aware at the time the specimen and
`25.
`the statement of use were filed for the RECON Registration that the screenshots were not
`
`actually taken from the publically accessible “reconip.com” website, calling into question
`
`the verity of the assertions made in the statement of use.
`
`Upon information and belief, Respondent was aware at the time the specimen and
`26.
`the statement of use were filed for the RECON Registration that the various screens
`allegedly depicted by the screenshots provided in the specimen were not available on the
`
`“reconip.com” website.
`
`27.
`
`The RECON Registration should be cancelled because it was obtained
`
`fraudulently.
`
`OVERLY BROAD DESCRIPTION OF GOODS
`
`28.
`
`The RECON Registration is registered in International Class 9.
`
`29.
`
`The descriptions of goods listed in the RECON Registration under International
`
`Class 9 are: Computer software for identifying, via searching a third party patent database
`
`or a patent database contained within the computer software, and evaluating, via analysis
`
`of patents within a database, intellectual property related to at least one field; computer
`software for providing a web platform for, via searching a third party patent database or a
`
`patent database contained within the computer software, and evaluating, via analysis of
`patents within a database, intellectual property; computer software for allowing users to
`access, evaluate, and synthesize information and generate reports related to intellectual
`property assets; Computer software for creating searchable databases of information and
`data; Computer software platforms for allowing users to access, evaluate, and synthesize
`information and generate reports related to intellectual property; Computer software that
`
`provides information from various databases and presents it in an easy-to-understand user
`interface; Computer software that provides intellectual property information, and more
`specifically, patents, from various databases and presents it in an easy-to-understand user
`interface; Computer software that provides web-based access to applications and services
`
`through a web operating system or portal interface.
`
`Of the eight descriptions of goods listed in the RECON Registration under
`30.
`International Class 9, five are properly-focused and relate to intellectual property (“IP”)
`research, analysis, and reporting and three are broadly-focused, covering virtually every
`data processing computer program on the planet.
`
`4842-0398-3917.2
`
`

`
`31.
`
`In the final Office Action, in support of maintaining the likelihood of confusion
`
`rejection, the Examining Attorney specifically referenced the three broadly-focused
`
`descriptions of goods listed in the RECON Registration under International Class 9 as
`
`potentially causing confusion with Petitioner’s use of the RECON 1 Mark. The broadly-
`focused descriptions are:
`
`Computer software for creating searchable databases of information and data;
`
`Computer software that provides information from various databases and presents
`
`it in an easy-to-understand user interface; and
`
`Computer software that provides web—based access to applications and services
`
`through a web operating system or portal interface.
`
`32.
`
`Assuming, arguendo, that the purported specimen submitted by Respondent
`
`shows ANY USE of the mark RECON with any goods associated with International
`
`Class 9 (and a Webpage that does not also qualify as a point of sale display or does not
`
`show a photograph of the goods displaying the mark will not qualify as a proper
`
`specimen for goods), such use is narrowly-focused, pertaining to investigation, analysis,
`
`and reporting on IP.
`
`33.
`
`The outrageously broad three descriptions (referenced above) should never have
`
`been allowed by the examining attorney.
`
`34.
`
`The RECON Registration should be cancelled, in whole or in part, at least
`
`because Respondent is not using the mark to the extent suggested by the three broadly-
`
`focused descriptions. Respondent may not be using, and probably has never used, the
`
`RECON Registration at all or with respect to any goods, but if it has, that use is limited
`
`solely to research and analysis of and reporting on IP, not for the outrageously broad
`
`descriptions cited by the examining attorney in this case and referenced in paragraph 31
`hereof.
`
`35.
`
`Additionally or alternatively, the RECON Registration should be partially
`
`canceled or modified to limit the descriptions so as more accurately to describe the goods
`
`provided by Respondent.
`
`OVERLY BROAD DESCRIPTION OF SERVICES
`
`The RECON Registration is registered in International Class 42 — in addition to
`36.
`Class 9.
`
`37.
`
`The descriptions of services listed in the RECON Registration under International
`
`Class 42 are: Providing a members-only website featuring technology which provides
`
`members with the ability to quickly and efficiently evaluate intellectual property;
`
`4842-0398-3917.2
`
`5
`
`

`
`Providing a secure electronic online system featuring technology which allows for
`efficient evaluation of intellectual property; Providing a secured-access, members only
`website featuring technology that gives members the ability to identify and evaluate
`intellectual property; Providing a website that features technology that enables the secure
`exchange of information by users; Providing an interactive website featuring technology
`that allows users to access, evaluate, and synthesize information and generate reports for
`
`use in consulting with research and development; Research and development and
`consultation related thereto in the field of intellectual property.
`
`38.
`
`Of the six descriptions of services listed in the RECON Registration under
`
`International Class 42, four are narrowly-focused to Intellectual Property (“IP”) and two
`
`are unfocused, applying to almost anything dealing with Web-based data processing.
`
`39.
`
`In the final Office Action, in support of maintaining the likelihood of confusion
`
`rejection, the Examining Attorney specifically referenced the two overly broad
`descriptions of services listed in the RECON Registration under International Class 42 as
`potentially causing confusion with Petitioner’s use of the RECON 1 Mark. The unfocused
`
`descriptions are:
`
`Providing a website that features technology that enables the secure exchange of
`
`information by users; and
`
`Providing an interactive website featuring technology that allows users to access,
`
`evaluate, and synthesize information and generate reports for use in consulting
`
`with research and development.
`
`40.
`
`Assuming, arguendo, that the specimen shows use of the mark RECON with
`
`services associated with International Class 42, such use is narrowly-focused to
`
`identification, analysis, and reporting on IP.
`
`41.
`
`The RECON Registration should be cancelled, in whole or in part, at least
`
`because Respondent is not using the mark to the extent suggested by the two unfocused
`
`descriptions.
`
`42.
`
`Additionally or alternatively, the RECON Registration should be partially
`
`canceled or modified to limit the descriptions so as more accurately to describe the
`
`services provided by Respondent.
`
`4842-0398-3917.2
`
`

`
`WHEREFORE, Petitioner requests that U.S. Registration No. 4,502,329 for the
`
`mark RECON be cancelled. Alternatively, Petitioner requests partial cancelation
`
`of U.S. Registration No. 4,502,329 and/or modification of the description of the
`
`goods and/or services listed in U.S. Registration No. 4,502,329.
`
`Petitioner authorizes the Board to charge any fees that may be required, or credit
`
`any overpayment, to Deposit Account No. 50-4104.
`
`Respectfully submitted,
`
`KUTAK ROCK LLP
`
`By: /1. Edward Marguettei
`
`1. Edward Marquette
`2300 Main St. Suite 800
`
`Kansas City, Missouri 64108
`
`Telephone: (816) 960-0090
`
`Facsimile:
`
`(816) 960-0041
`
`Emaill 2 Ed.Marquette@kutakrock.com
`Emai12: Trademarks@kutakrock.com
`
`Attorneys for Petitioner
`
`TouchNet Information Systems, Inc.
`
`4842-0398-3917.2
`
`

`
`EXHIBIT 1
`
`TRADE SHOW ADVERTISING MATERIALS
`
`4842-0398-3917.2
`
`

`
`.4
`
`0 Heartland \/
`
`
`Heartland
`Transaction Services
`
`TouchNet"
`
`
`Tailored to TouchNet
`
`Heartland Payment Systems and TouchNet have joined forces to provide colleges and universities with the
`most com_prehensive campus commerce products and services available today. With the ever increasing
`challenge of managing payment card security and transaction costs, TouchNet + Heartland demystify and
`protect your payment processing through a fair and transparent pricing model and advanced security
`technology. Now, when you combine Heartland payment systems and TouchNet U.Commerce technology,
`you'll discover Heartland Transaction Services, the most powerful transaction processing solution designed
`specifically for higher education.
`
`Simple Addition. Exponential Results. '
`
`Only when you choose Heartland payment processing for your -TouchNet U.Commerce platform can you get
`these unprecedented payment processing advantages:
`
`+ "
`RECON 1"‘ gives you access to payment transaction information like you've never seen before—information collected
`from your campus ERP systems, Heartland payment processing, and U.Commerce transactions. You can view trends
`or drill down to individual transactions in orderto manage merchant fees and streamline reconciliation.
`l-inaily, an
`
`answer to the nightmarish problems of reconciling payment transactions.
`
`
`
`+ Heartland Secure
`Heartland Secure?“ is a comprehensive card data security program
`that combines three modern technologies—EMV, data encryption,
`and tokenization—to give merchants the best protection
`against card-present data fraud and point-of—sale (P05)
`intrusions. And it comes with a warranty, too!
`
`+ Merchant Bill of Rights
`As the author of the Merchant Bill of Rights,
`Heartland guarantees fair and transparent pricing
`for all card payments. You get full disclosure of
`how much you're paying for each transaction and
`confidence that you're dealing with an open and
`honest business partner.
`
`_
`+ All Devices. All in.
`When we say you can hack payments processed down to the POS
`transaction level, we mean it. Even if an approved, stand-alone point-of—sale
`device does not connect directly to TouchNet U.Commerce, its transactions
`are available from Heartland for your review in RECON 1 and its
`deployment on campus can be monitored through the
`Device Manager. Heartland has a long list of
`approved POS devices.
`
`U.C®mmerce%
`EVl.‘l ywhcrc Money I'‘./7ov:2:.. "
`
`

`
`’\
`TouchNet“
`
`' Heartland V
`
`_
`Heartland
`Transaction Services
`
`"‘
`
`Reconciliation Made Easy
`
`is a To'uchNet U.Commerce component for payment reconciliation and data reconnaissance.
`RECON 1
`it's the 1 place to go to pull together data from your campus ERP systems, TouchNet U.Commerce
`applications, and Heartland payment processing systems to help you run your business better and
`make tough chores like reconciliation easier.
`
`
`
`+ Data Reconnaissance
`
`Review campus-wide payments _— all devices and all pay points
`>
`Track v_olumes by merchant or merchant ID
`D
`> Monitor transaction interchange rates, and ACH returns, and more
`
`+ Batch Analysis
`
`I Match TouchNet batches with settlement data for cards & ACH
`
`I
`I
`
`v
`Analyze fees assessed at the batch level
`Post fees to your Finance System GIL with a click of a button
`
`+ Transaction Fees
`
`I
`I
`I»
`
`Know which cards you've.processed and their fees
`Know why a card is unexpectedly processed at a higher rate
`Link transaction fees to specific campus merchants
`
`+ Business Automation .
`
`Streamline the process of transmitting ACH files to your bank
`>
`D Automate returned ACH payment handling
`D Automatically mark payment transactions as settled
`
`'Jl8 ToumNeL logo aritf U Commerce are registered tnademans and RECON 1 and Everywhere Money Moves are rmcamm-la: or TouchNet.
`-u 2014 TouchNet :.-ilmmatlon Systems Inc Al' rights mserved. Tun'fll‘lel
`lnformauon Sysuanra Inc The Heanlaid logo and Haaniand Sanum me I:r-ail.-emarlc: ol Heal Lland Payment 5\':L8mS. inc Other business nsnms herein may be "ECtlgnlIBU as trademarks by their m.-.-pecuve
`
`‘.V‘.'V\‘.' [0llEill'(’l.COlll
`
`

`
`EXHIBIT 2
`
`RECON REGISTRATION SPECIMEN
`
`4842-03 98-39 1 7 .2
`
`

`
`
`
`

`
`
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`urlyon In mu dnvoionmenz nroccns
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`ma Recunw Synum d-"nun rumvunr nunnu mm
`lunuomnmal quusrions ma: mgnngru the key nannies.
`which. hum : nchmcal cundunmz. uniqualy
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`nfiminnrly uuoevnooa by your Rad) rum Ind
`ch-Ilonyng aesngnmounu mnuu can be reamry
`ilenxilnod and niymgmaa lo yam exueuxivc mam
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`Elrly .11 ms CI|':9l.M1 Anun w an mxellocxusl
`progeny ntamvy mm ouorveng a. My": when he
`mwesenme numerous hlgn techno -ugy mmpenan '-n
`the negcriuion of mmueczuul pmuarry licens-ng and
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`noulol.-us. rrucwrmgcl co-development um
`co-oxnla-ulian veni
`Ins, and genera) management a!
`mu Iecuu property atsals. Mr. An on began his
`mu'.|ecrun picnerly can is on u socxlu : Crmusa
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`cnc.-n'~:u- Eng-nesting rmm surshnl umvavauy.
`
`Hanm Ansml
`Huim Ansui serves II CEO 01 ROCOMF. Noun -8 J
`nmnul in me oflsnora -manecxunl ploperty Industry
`and: wccesniul entmnmncur As a count axwmzy.
`Huirn Ms v.-rimn and nroncuuou autumn for an-la:
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`founding mu launching several srmup cumnan-is In
`2002. Mv.AnsAn' handed Pnnn1Me:r:x.naw Novel ‘P
`(wwmnovaliucoml based in nalni. Indie mm: was on of
`me firs: in use this high qua!-ry. cnnuéfictwe law!
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`murmurs :0 Italy cnmnameu proucuvury muruge pulem
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`culllbolnlinns In runner mchnoloy aovelnpment
`Sona Dalral
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`
`son: DIM‘ currcnuy an 3 CO0 nf Recon N7. Smce
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`Pawnxmemx.now Novnl I9 and has uxnnsive
`expanance in the film; Ind umsccution of pnum
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`manager. mm in In-Inansible hr maria:-ng buwnn
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`Blue In ‘ndtl.
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`mm nus nceivea numemus rumors (av Mr arnuernlc
`work. mcuuaxng Iecngninan u n Nu-.mnu6 scnnncc
`Fouuaanon Sahqlu sue ms uumnruo seven’ paper: in
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`cnlilmnm sun in
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`100%
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`50%
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`50%
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`{D 0%
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`Tutat 88 of Parents: 15
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`Totals of Patenzs: 27
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`Total 3 of Patents: 0
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`- fatal 2 ca! Fatents. 0
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`u.-nien. (rem A xaenmul vunduemz. uniquuly
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`Iangulu. so (hit a altenz Iundtcnnu no be can dc‘-y and
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`chnllengmgdes gn-mun: cssuel can he yuuily
`men:-6:6 Ind n-yllaghtod u: your axacmzve mum
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`Hazim Ansmi
`Huzii-ii Minn SGNES u csoci Recs:-ixv. Ha .'m is a
`piimee: inzrie nflshan :hl3”QC1LlI|9fDDE|1yIHU|lSl'y
`one a zueceulul eviuenrvneur. A: a patent nwrney.
`Hazim hn written and nrosvcutoc purems for a urine
`nrige afcompen-es. from umeiging companzen to lug:
`cornotauons maxim has also been instrumental in
`(minding mi-1 launching several zrimun camxzlnies. in
`2002. Mr.Ans|1i founded 9
`nrlilnr x. now Novel IP
`:iiimw.navurip.cimi). used I Delhi new and inn am of
`
`
`mo firs! to use unis nigh qual izy. can-effective lax»:
`base to deiivtr mum services. such as ma9D\'05
`in-vkuxs xv nelg cnmpuniaii 9H1I6liVI7y muuge pamu
`inir ngamanr risk and xsuireing mull .- -nsuxuriarial
`coI'.lboraxinns In forum recrinniugy flevaroomem.
`Sona Dalai
`Son: Dnlolcunmzly none: 5: C00 ofliaconlfi since
`3003. Ml. Dale‘ nu served us Dinner Nopuulons u
`Pu¢ntMe2:n<. new Nave‘. I9 and an extensive
`experience in the lining ma pinneution oi putarit
`nimlolxus me me smngic mnnogomerix of -mm Iecnm
`nroaerty usual} to: a mac VIPIOI] :7! clients. A: then:
`moinuger. she is resnansible for =n:evhc-ng between
`ciimn Ind Imnloyiiec. imiisxlng csienrii in iaon:'ig=i-ig
`unique innaumaris. ma ensuring me eemaiueriess
`and o