Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA1033961
`02/06/2020
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`ESTTA Tracking number:
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`Filing date:
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
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`92067777
`
`Party
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`Correspondence
`Address
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`Plaintiff
`Akasa (Europe) Limited
`
`STEVEN M RABIN
`RABIN & BERDO PC
`1101 14TH STREET NW, SUITE 500
`WASHINGTON, DC 20005
`UNITED STATES
`firm@rabinberdo.com, salprin@rabinberdo.com, hzhang@rabinberdo.com
`202-371-8976
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`Submission
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`Filer's Name
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`Filer's email
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`Signature
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`Date
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`Attachments
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`Plaintiff's Notice of Reliance
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`M. Scott Alprin
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`salprin@rabinberdo.com, firm@rabinberdo.com
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`/M. Scott Alprin/
`
`02/06/2020
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`Akasa Europe v. Akaso Tech - Testimony - Pet. - Ex. C - NOR 1 - Ex. C to C1
`(P's Interrogs.).pdf(729477 bytes )
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`

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`Exhibit C
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEAMARK TRIAL AND APPEAL BOARD
`
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`Cancellation No.: 92067777
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`Registration No. 4389656 (petitioned)
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`Mark: AKASO
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`Akasa (Europe) Limited,
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`Petitioner,
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`v.
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`Akaso Tech LLC,
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`Respondent.
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`PETITIONER’S FIRST NOTICE OF RELIANCE
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`Petitioner Akasa (Europe) Limited (“Petitioner”), by its undersigned attorneys and
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`pursuant to Rules 2.120, 2.122, and 2.123 of the Trademark Rules of Practice, hereby gives
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`notice to Respondent Akaso Tech LLC (“Respondent”) and the Board that it intends to rely at
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`trial on the following material evidence, generally relevant to the issues raised by the pleadings
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`herein, and specifically relevant to the question of whether the petitioned registered mark would
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`be likely to cause confusion with Petitioner’s mark, whether the petitioned registration should be
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`cancelled due to nonuse at the time of filing of the application, and whether the mark in the
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`petitioned registration has been abandoned:
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`Petitioner’s Interrogatories / Respondent’s Responses
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`(These documents are relevant for the reasons stated in the first paragraph hereabove)
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`1. Pursuant to 37 C.F.R. Section 2.122, a copy of Petitioner’s Revised First Set of
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`Interrogatories, as sent by Petitioner on March 22, 2019. See Exhibit C1.
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`2. Pursuant to 37 C.F.R. Section 2.122, a copy of Respondent’s Objections And Responses
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`To Petitioner’s Revised First Set Of Interrogatories (Nos. 1-24), as sent by Respondent
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`on April 17, 2019. See Exhibit C2. [Under Seal]
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`1 
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`3. Pursuant to 37 C.F.R. Section 2.122, a copy of Petitioner’s Second Set of Interrogatories,
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`as sent by Petitioner on June 27, 2019. See Exhibit C3.
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`4. Pursuant to 37 C.F.R. Section 2.122, a copy of Respondent’s Objections And Responses
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`To Petitioner’s Second Set Of Interrogatories (Nos. 25-34), w as sent by Respondent on
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`April 17, 2019. See Exhibit C4. [Under Seal]
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`Petitioner’s Requests for Admission / Respondent’s Responses
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`(These documents are relevant for the reasons stated in the first paragraph hereabove, and for
`authenticating documents produced by Respondent)
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`5. Pursuant to 37 C.F.R. Section 2.122, a copy of Petitioner’s First Set Of Requests For
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`Admission, as sent by Petitioner on January 20, 2019. See Exhibit C5.
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`6. Pursuant to 37 C.F.R. Section 2.122, a copy Respondent’s Objections And Responses To
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`Petitioner’s First Set Of Requests For Admission (Nos. 1-62), as sent by Respondent on
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`March 21, 2019. See Exhibit C6. [Under Seal]
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`Petitioner’s Requests for Documents / Respondent’s Responses and Documents
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`(These documents are relevant for the reasons stated in the first paragraph hereabove)
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`7. Pursuant to 37 C.F.R. Section 2.122, a copy of Petitioner’s First Request For Production
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`Of Documents And Things, as sent by Petitioner on January 20, 2019. See Exhibit C7.
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`8. Pursuant to 37 C.F.R. Section 2.122, a copy of Respondent’s First Request For
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`Production Of Documents And Things, as sent by Respondent on March 21, 2019. See
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`Exhibit C8.
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`2 
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`9. Pursuant to 37 C.F.R. Section 2.122, a copy of documents produced by Respondent, as
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`sent by Mr. Allen Xue on May 31, 2019 (and as authenticated through Respondent’s
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`Respondent’s Objections And Responses To Petitioner’s First Set Of Requests For
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`Admission (Nos. 1-62). See Exhibit C8-1 ~ C8-5. [Under Seal]
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`Date: February 5, 2020
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`Respectfully submitted,
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`AKASA (EUROPE) LIMITED
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`__/M. Scott Alprin/____________________
`
`Steven M. Rabin
`Hui Zhang
`M. Scott Alprin
`Attorneys for Petitioner
`RABIN & BERDO, P.C.
`Suite 500, 1101 14th Street, NW
`Washington, D.C. 20005
`Tel: (202) 371-8976
`Fax: (202) 408-0924
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and complete copy of the PETITIONER’S FIRST NOTICE
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`OF RELIANCE has been served on counsel for Respondent, Trina Longo, by e-mail, on
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`February 5, 2020, at the following e-mail addresses:
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`tlongo@nkllaw.com
`docket@nkllaw.com
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` 
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`/M. Scott Alprin/______
`M. Scott Alprin
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`3 
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`

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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`----------------------------------------------------- )
`)
`)
`
`AKASA (EUROPE) LIMITED,
` )
`Petitioner,
`)
`
`)
`Cancellation No. 92067777
`)
`)
` )
`AKASO TECH LLC,
`
` )
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`
`
`
`
`
`)
`Respondent.
`)
`)
`----------------------------------------------------- )
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`
`
`
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`
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`Petitioned Registration No.: 4389656
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`Mark: akaso
`
`
`Exhibit C1
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`
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`v.
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`PETITIONER’S REVISED FIRST SET OF INTERROGATORIES
`
`
`Pursuant to Rule 33 of the Federal Rules of Civil Procedure and Rule 2.120 of the
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`Trademark Rules of Practice (37 C.F.R. § 2.120), Petitioner, Akasa (Europe) Limited
`(hereinafter, “Petitioner”) serves its Revised First Set of Interrogatories upon Respondent,
`Akaso Tech, LLC (hereinafter, “Respondent”), to be answered fully in writing under oath.
`A copy of the answer shall be served upon Petitioner’s counsel within ten (10) days after
`the service hereof. To the extent permitted by Rule 26(e) of the Federal Rules of Civil
`Procedure, these interrogatories are to be deemed continuing and the answers hereto are
`to be supplemented promptly upon Respondent’s acquisition of further or additional
`information. The Board’s standard protective order is applicable, and objections based on
`confidentiality are generally inappropriate.
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`If Respondent does not agree to serve responses to these interrogatories within ten
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`(10) days of service, that is, by April 1, 2019, Petitioner respectfully requests that the
`parties request guidance from the interlocutory attorney in this matter to determine an
`appropriate date for service.
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`DEFINITIONS AND INSTRUCTIONS
`
`
`All interrogatories are to be answered on the basis of Respondent’s knowledge or
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`information and belief, including that of its officers, employees, directors, or agents
`having such knowledge. If any answer is given on information and belief, such fact
`should be stated in the answer.
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`1
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`If any information called for in any interrogatory is being withheld on the grounds
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`that it is subject to the attorney-client privilege or any other privilege, Respondent is
`hereby directed to state with respect to such interrogatory that the information is being
`withheld and state the alleged ground of the privilege.
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`
`
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`The following definitions are applicable herein:
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`1. The terms “Respondent” and “you” or “yours” mean and refer to the Respondent,
`Akaso Tech, LLC, its subsidiaries and any merged or acquired subsidiaries; its
`predecessors, or controlled, controlling, or affiliated companies; and Respondent’s
`past and present officers, employees, agents, representatives, and attorneys, all to the
`fullest extent the context permits.
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`2. The term “Petitioner” means and refers to the Petitioner, Akasa (Europe) Limited,
`and includes the Petitioner herein, its predecessors in business, and their officers,
`directors, agents, employees, and attorneys, both present and past.
`
`3. The terms “Respondent’s Mark,” and similar terms (such as “its trademarks” in the
`proper context) means and refers to Respondent’s alleged trademark for “AKASO”
`and any and all marks including the term “AKASO,” in any form, regardless of
`color and stylization.
`
`4. The term “Respondent’s Registration” and similar terms means and refers to U.S.
`Reg. No. 4389656; the term “Respondent’s Application” and similar terms means
`and refers to U.S. Ser. No. 87796108; the term “Respondent’s mark” means and
`refers to Respondent’s alleged “AKASO” mark.
`
`5. The term “Respondent’s Goods” and similar terms means and refers to all of the
`goods listed in Respondent’s Registration (“Tablet computer”) and Application
`(“Computers; Tablet computers; Notebook computers; Computer peripheral
`devices; Computer memory devices; Covers for tablet computers; Downloadable
`computer software for editing images, voice, videos; Photo printer; Pedometers;
`Time recording apparatus; Face recognition security devices; Electronic
`identification device for animals; Photocopiers; Wireless electronic scales; Light-
`emitting electronic pointers; Smartphones; Covers for smartphones; Smartwatches;
`Wearable activity trackers; Radio receivers; Video monitoring apparatus; Video
`baby monitors; Camcorders; Portable media players; Set-top boxes; Photographic
`projectors; Mini beam projectors; Audio speakers; Wireless speakers; Audio
`equipment for vehicles, namely, stereos, speakers, amplifiers, equalizers, crossovers
`and speaker housings; Radios; Virtual reality headsets; Earphones and
`headphones; Microphones; Electronic book readers; Car video recorders;
`Cameras; Lens filters; Stands for photographic apparatus; Cases especially made
`for photographic apparatus and instruments; Directional compasses; Temperature
`indicators; Telescopes; USB cables; Switches, electric; Electrical plugs and sockets;
`Remote controls for radios, televisions, stereos; Protective helmets for sports;
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`2
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`Goggles for sports; Snow goggles; Swim goggles; Burglar alarms; Electric door
`bells; Digital door locks; Eyeglasses; Sunglasses; Rechargeable batteries; Chargers
`for electric batteries; Diver's masks”), and any other goods that may have been used
`under Respondent’s Mark in the United States.
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`6. The term “Petitioner’s Mark,” and similar terms means and refers to the “AKASA”
`mark, as applied for in Application Ser. No. 87424540.
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`7. The term “Petitioner’s Application,” and similar terms means and refers to the
`application set forth in Par. 6 immediately above.
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`8. The term “Petitioner’s Goods,” and similar terms means and refers to all of the
`goods listed in Petitioner’s Application (“Computer hardware; Computer
`peripherals”), and any other goods that may have been used under Petitioner’s mark
`in the United States.
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`9. The terms “commerce” and “U.S. commerce” shall have the meaning ascribed to the
`term “commerce” as set forth in the Lanham Act, 15 U.S.C. Sec. 1127 and related
`federal case law.
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`10. The term “use,” “uses,” or “used” shall mean, unless specifically stated otherwise,
`use in connection with U.S. commerce as defined above.
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`11. The term “person” refers to both natural persons and to corporate or other business
`entities, partnerships, groups, associations, governmental entities, or other
`organizations.
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`12. The term “document” is used herein in its customary broad sense as defined in
`FRCP 34(a)(1), and includes, without being limited to, the original and all copies
`(carbon, photocopy, photographic, microfilm, or otherwise) of any advertising or
`promotional material (including, without limitation, art work, copies of drafts
`thereof, proofs, tear sheets, scripts, storyboards, etc.), brochures, business cards,
`travel tickets, lodging confirmations, lists of customers, lists of customer inquiries,
`rate schedules, letters, correspondence, customer or other complaints, books,
`journals, ledgers, working papers, invoices, contracts, purchase orders, estimates,
`reports, memoranda, interoffice communications, records, studies, appraisals, papers,
`charts, recordings of or memoranda of any conversation (by telephone or otherwise),
`meeting or conference, or any other writing however produced or reproduced; all
`other handwritten, typed, printed, or otherwise visually or aurally reproduced
`materials, whether copies or originals, including, but not limited to, letters, cables,
`wires, memoranda, and interoffice communications; reports, notes, minutes, and
`recordings; drawings, blueprints, sketches, charts, photographs, microfilm records,
`data compilations, and movies; copyrights, copyright registration applications,
`patents, trademarks, patent applications, trademark applications, assignments,
`contracts, agreements, licenses, and other official documents and legal instruments;
`published material of any kind; annual reports, reports to shareholders and minutes
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`3
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`or reports of meetings of directors or executive boards or committees; advertising or
`promotional literature and press releases; engineering notebooks and data; and
`ledgers, bills, orders, books, records, and files that are in the possession, custody or
`control of Respondent or any of its officers, agents, or employees and/or
`Respondent’s attorneys. The term “document” or “documents” also includes all
`copies that are not identical with the original.
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`13. The term “identify” as used herein means:
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`(a) in the case of a natural person, to state for each person his or her: (i) full name; (ii)
`present residence address and telephone number; (iii) present business address and
`telephone number; (iv) present position, business affiliation, and job description;
`and (v) if any of the information set forth in (i)~(iv) is unknown, so state and set
`forth the corresponding last known such information;
`(b) in the case of a corporation or other business entity, to state for each corporation or
`business entity: (i) its full name; (ii) its legal form (i.e., corporation, partnership,
`etc.) and state of incorporation or legal formation; (iii) its address and principal
`place of business; (iv) the identity of officers or other persons having knowledge of
`the matter with respect to which the corporation or entity is named; and (v) the
`connection to Respondent’s response; and
`(c) in the case of a document, to state for each document: (i) the identity of the
`person(s) originating and preparing it and the sender; (ii) its general type (e.g.,
`letter, memo, report, invoice, etc.), title, identifying number and the general nature
`of its subject matter; (iii) the identify of the addressees and distributes, if any; (iv)
`its date of preparation; (v) its date and manner of transmission, distribution and
`publication, if any; (vi) the location of each copy (including title, index number and
`location of the file in which it is kept or from which it was removed) and the
`identity of the present custodian of persons responsible for its filing or other
`disposition; and (vii) the identity of persons who can authenticate or identify it.
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`14. As used herein, “and” as well as “or” shall be construed either disjunctively or
`conjunctively as necessary in order to bring within the scope of the request all
`documents and things which might otherwise be construed to be outside its scope.
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`15. As used herein, the singular shall always include the plural and the present tense
`shall always include the past tense.
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`16. The term “thing” as used herein refers to any tangible object other than a document,
`and includes objects of every kind and nature such as, but not limited to, prototypes,
`models, specimens, computer disks and tapes, videotapes and audiotapes.
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`INTERROGATORIES
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`Interrogatory No. 1:
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`Identify each officer of Respondent.
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`Interrogatory No. 2:
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`Identify each predecessor, parent, subsidiary, and affiliated company of
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`Respondent.
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`Interrogatory No. 3:
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`Identify and describe all goods or services in connection with which Respondent
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`has used Respondent’s Mark in the United States, and for each such usage provide the
`date of first use in commerce, if applicable, and last use in commerce, if applicable.
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`Interrogatory No. 4:
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` Describe the circumstances, methods and reasoning surrounding Respondent’s
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`selection of Respondent’s trademarks, including the specific individual who thought of
`the name AKASO.
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`Interrogatory No. 5:
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`State whether any searches or investigations were conducted by Respondent or
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`any person on its behalf (including its attorneys) to determine whether Respondent’s
`trademarks were available for use and registration in the United States and, if so, identify
`each such search or investigation.
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`Interrogatory No. 6:
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`State Respondent’s annual expenditures (including predecessor(s)-in-interest)
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`since the year 2010 for advertising and promoting Respondent’s Goods under its
`trademarks in the United States.
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`Interrogatory No. 7:
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`Identify a representative sample of all labels, hangtags, wrappers, containers,
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`advertisements, pamphlets, catalogs, and brochures which contain or bear Respondent’s
`Mark as used in the United States.
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`Interrogatory No. 8:
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`Identify each person employed by Respondent and each outside agent or agency
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`retained by Respondent who has been or now is responsible for (a) marketing, advertising
`and promotion, and (b) bookkeeping and accounting with respect to any goods or services
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`offered for sale or sold under Respondent’s Mark, or any variations thereof, in the United
`States.
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`Interrogatory No. 9:
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`Identify types of media through which Respondent has advertised or promoted its
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`goods or services under Respondent’s Mark, including websites designed to sell products.
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`Interrogatory No. 10:
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`For each of Respondent’s Goods, set forth the approximate dollar amount of
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`Respondent’s annual sales in U.S. commerce of such goods or services since the year
`2010.
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`Interrogatory No. 11:
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`State whether Respondent or any person acting for or on behalf of Respondent has
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`received any communication, oral or in writing, from any person, inside or outside of the
`United States, which suggests, implies, or infers that, due to reasons related to
`Respondent’s Mark or Petitioner’s Mark, Respondent may be connected or associated
`with Petitioner or any other corporation, or which comprises any inquiry as to whether
`there is or may be or which evidences any such connection or association.
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`Interrogatory No. 12:
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`Identify the trade channels through which Respondent has sold and now is
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`offering and selling goods under Respondent’s Mark.
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`Interrogatory No. 13:
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`Identify the witnesses Respondent intends to call to testify on its behalf in
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`connection with this proceeding and state the facts or subject matter concerning which
`they are each expected to testify.
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`Interrogatory No. 14:
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`Identify the documents upon which Respondent intends to rely in connection with
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`this proceeding.
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`Interrogatory No. 15:
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`Respondent’s specimen of use for Respondent’s Registration (Reg. No. 4389656), which
`was filed on June 13, 2013 and depicts Respondent’s “tablet computer” bearing the
`“AKASO” mark as follows,
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`6
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`appears to show the printed wording on the product slightly misaligned. Please indicate
`if Respondent can produce an actual product being the same make and model as the
`product shown in the specimen of use that could be examined by Petitioner. If not, please
`indicate if Respondent can produce any additional pictures of the product being the same
`make and model as the product shown in the specimen of use that could be examined by
`Petitioner.
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`Interrogatory No. 16:
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`Respondent’s specimen of use for Respondent’s Registration, which was filed on June 13,
`2013 and depicts Respondent’s “tablet computer” bearing the “AKASO” mark as follows,
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`7
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`also displays a website printed on the product, namely, www.tabletexpress.com. Please
`describe the past and current affiliation between Respondent and this website.
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`Interrogatory No. 17:
`
`On the LinkedIn page for TabletExpress, at
`https://www.linkedin.com/company/tabletexpress/, the following is stated:
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`
`TabletExpress is a U.S.-based manufacturer and distributor. Our goal is to
`provide high-quality products at affordable prices. Dragon Touch®,
`AKASO®,KingPad® and Tabsuit® are our sub brands, which already
`have a very good reputation.
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`Please indicate if “AKASO” is a sub brand of TabletExpress. If not, please provide an
`explanation for the inaccuracy set forth on the TabletExpress LinkedIn page.
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`Interrogatory No. 18:
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`Paragraphs 8 and 9 in the Petition for Cancellation filed in this matter on January 22,
`2018 state the following:
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`8.
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`Upon information and belief, Respondent’s website, at
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`http://www.tabletexpress.com/, indicates that “tablet computers” are not marketed
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`under the “akaso” mark. The following image from the website shows the four product
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`categories under the “akaso” mark in a dropdown menu, namely, action cameras, security
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`cameras, projectors, and TV boxes, as follows:
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`8
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`9.
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`Upon information and belief, Respondent’s “tablet computers” are marketed and
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`sold under the name “Dragon Touch,” as shown on Respondent’s website, as follows:
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`It is noted that Respondent responded to Paragraph 9 of the Petition in its Answer as
`follows: “Paragraph 9 is admitted to the extent that it currently markets and sells tablet
`computers under the mark ‘Dragon Touch.’” Does this mean that Respondent is no
`longer marketing and selling tablet computers under the “AKASO” mark? Please clarify,
`including an indication of the date on which the last sale of tablet computers under the
`“AKASO” mark occurred. If Respondent is no longer marketing and selling tablet
`computers under the “AKASO” mark, please indicate if Respondent has any intention of
`resuming use in commerce of the “AKASO” mark in connection with tablet computers.
`If so, please indicate the steps that have been taken to resume use in commerce of the
`“AKASO” mark, if any, and the expected timeline for re-commencing use in commerce.
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`Interrogatory No. 19:
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`It appears that www.tabletexpress.com now redirects to
`https://www.dragontouch.com/. Please describe the past and current relationship
`between Respondent and the company operating as Dragon Touch at
`https://www.dragontouch.com/.
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`9
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`Interrogatory No. 20:
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`At https://www.akaso.net/, Respondent’s products are listed as follows:
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`Please indicate if this list of products is accurate.
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`Interrogatory No. 21:
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`The date of first use in commerce of Respondent’s Mark as set forth in both
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`Respondent’s Registration and Respondent’s Application is May 9, 2013. Please advise
`if Respondent intends to rely on this date as its date of first use in commerce of its mark.
`If not, please indicate the actual date of first use in commerce upon which Respondent
`intends to rely in this matter. It is noted that the application for Respondent’s
`Registration was filed on November 5, 2012, and Petitioner understands that Respondent
`will likely assert this date as the date on which its constructive rights for its mark
`commenced in the United States.
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`Interrogatory No. 22:
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`If any of the answers to Request for Admissions Nos. 1 and 5 through 61 are
`denied, please indicate the date of first use in commerce for the subject good(s) of each
`Request, and identify any documentation evidencing use in commerce of the subject
`good(s) of each Request.
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`If the answers to Request for Admissions No. 1 is denied, please indicate the date
`of first use in commerce for the subject good of the Request, and identify any
`documentation evidencing use in commerce of the subject good of the Request.
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`Interrogatory No. 23:
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`Identify each person who participated in the preparation of Respondent’s
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`responses to the foregoing interrogatories or furnished any information in response
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`thereto, and for each specify the interrogatory response for which each such person
`provided information or participated in the preparation of.
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`Interrogatory No. 24:
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`Identify all documents relating to the subject matter of the foregoing
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`interrogatories and the preparation of Respondent’s responses thereto.
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`Date: March 22, 2019
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`Respectfully submitted,
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`AKASA (EUROPE) LIMITED
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`__/M. Scott Alprin/____________________
`Steven M. Rabin
`Hui Zhang
`M. Scott Alprin
`Attorneys for Petitioner
`RABIN & BERDO, P.C.
`Suite 500, 1101 14th Street, NW
`Washington, D.C. 20005
`Tel: (202) 371-8976
`Fax: (202) 408-0924
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and complete copy of the foregoing Petitioner’s Revised First
`Set of Interrogatories has been served on counsel for Respondent, Allen Xue, by e-mail,
`on March 22, 2019, at the following e-mail addresses:
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`allen.xue@nkllaw.com
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`__/M. Scott Alprin/______________
`M. Scott Alprin
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`11
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