Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA986033
`
`Filing date:
`
`07/08/2019
`
`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 has filed a petition to cancel the registration indicated below.
`
`Petitioner Information
`
`Name
`
`Entity
`
`Address
`
`Correspondence
`information
`
`Salt Life, LLC
`
`Limited Liability Company
`
`Citizenship
`
`Georgia
`
`322 South Main Street
`Greenville, SC 29601
`UNITED STATES
`
`Jason A Pittman / Tim F. Williams
`Dority & Manning, P.A.
`75 Beattie Place, Suite 1100
`Greenville, SC 29601
`UNITED STATES
`jpittman@dority-manning.com, timw@dority-manning.com, litdocket-
`ing@dority-manning.com
`8642711592
`
`Registration Subject to Cancellation
`
`Registration No.
`
`5242512
`
`Registration date
`
`07/11/2017
`
`Registrant
`
`Salt Water Life Inc.
`7 Maple Street
`Mendon, MA 01756
`UNITED STATES
`
`Goods/Services Subject to Cancellation
`
`Class 025. First Use: 2017/04/17 First Use In Commerce: 2017/04/17
`All goods and services in the class are subject to cancellation, namely: Headwear, namely, caps and
`hats
`
`Grounds for Cancellation
`
`Priority and likelihood of confusion
`
`Trademark Act Sections 14(1) and 2(d)
`
`Dilution by blurring
`
`Dilution by tarnishment
`
`Trademark Act Sections 14(1) and 43(c)
`
`Trademark Act Sections 14(1) and 43(c)
`
`Marks Cited by Petitioner as Basis for Cancellation
`
`U.S. Registration
`No.
`
`3762960
`
`Application Date
`
`08/06/2009
`
`Registration Date
`
`03/23/2010
`
`Foreign Priority
`
`NONE
`
`

`

`Word Mark
`
`Design Mark
`
`SALT LIFE
`
`Date
`
`Description of
`Mark
`
`Goods/Services
`
`The mark consists of the words "SALT LIFE".
`
`Class 016. First use: First Use: 2003/10/00 First Use In Commerce: 2003/10/00
`Stickers
`Class 025. First use: First Use: 2003/10/00 First Use In Commerce: 2003/10/00
`Caps; Shirts; Surf wear
`
`U.S. Registration
`No.
`
`2959429
`
`Registration Date
`
`06/07/2005
`
`Application Date
`
`09/04/2003
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`SALT LIFE
`
`NONE
`
`Class 025. First use: First Use: 2003/10/02 First Use In Commerce: 2003/10/02
`Clothing and apparel, namely, caps, shirts, T-shirts, [ underwear, socks, pants,
`sweaters, jackets, shoes, sandals, ] bathing suits, Bermuda shorts, walking
`shorts, [ wet suits, ] swim trunks, caps with visors, visors, fleece pullovers, sweat
`shirts, surf wear, [ briefs, boxer briefs, panties, wind resistant jackets ]
`
`U.S. Registration
`No.
`
`4627064
`
`Registration Date
`
`10/28/2014
`
`Word Mark
`
`Design Mark
`
`SALT LIFE
`
`Application Date
`
`03/22/2013
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 025. First use: First Use: 2003/10/02 First Use In Commerce: 2003/10/02
`Clothing, namely, hats, caps, shirts, T-shirts, shorts, swim trunks, visors, fleece
`pullovers, sweat shirts, surf wear,jackets, pants, bandanas, sun sleeves,
`
`

`

`dresses and footwear
`
`U.S. Registration
`No.
`
`4562190
`
`Registration Date
`
`07/08/2014
`
`Word Mark
`
`Design Mark
`
`SALT LIFE
`
`Application Date
`
`10/09/2012
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`The mark consists of the words "Salt Life" in stylized form with crossed fishing
`poles between the "Salt" and "Life" and with a skull positioned above the
`crossed fishing poles.
`
`Class 025. First use: First Use: 2007/01/05 First Use In Commerce: 2007/01/05
`Clothing, namely, shirts, sweat shirts and caps
`
`U.S. Registration
`No.
`
`4324994
`
`Registration Date
`
`04/23/2013
`
`Word Mark
`
`Design Mark
`
`SALT LIFE
`
`Application Date
`
`06/07/2011
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 025. First use: First Use: 2013/02/13 First Use In Commerce: 2013/02/13
`Clothing and apparel, namely, jackets, pants [, shoes, and sandals ]
`
`

`

`U.S. Registration
`No.
`
`4335287
`
`Registration Date
`
`05/14/2013
`
`Word Mark
`
`Design Mark
`
`SALT LIFE
`
`Application Date
`
`12/10/2010
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`The mark consists of the stylized words"Salt Life" with the crest of a wave ap-
`pearing below the words.
`
`Class 025. First use: First Use: 2013/03/11 First Use In Commerce: 2013/03/11
`Women's clothing, namely, caps, shirts,T-shirts, [ pants, shoes, sandals, flip-
`flops, beach shoes, walking shorts, caps with visors, ] sweat shirts [ and
`surfwear ]
`
`U.S. Registration
`No.
`
`5091373
`
`Registration Date
`
`11/29/2016
`
`Word Mark
`
`Design Mark
`
`SALT LIFE
`
`Application Date
`
`10/16/2012
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`The mark consists of the words "Salt Life" in stylized form.
`
`Class 025. First use: First Use: 2003/10/00 First Use In Commerce: 2003/10/00
`Clothing and apparel, namely, jackets, pants, shoes, sandals, bathing suits,
`shorts and sweat shirts; sun protective clothing, namely, bandanas
`
`U.S. Registration
`No.
`
`4852462
`
`Application Date
`
`10/20/2014
`
`Registration Date
`
`11/10/2015
`
`Foreign Priority
`
`NONE
`
`

`

`Word Mark
`
`Design Mark
`
`LIVE THE SALT LIFE
`
`Date
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 025. First use: First Use: 2011/01/01 First Use In Commerce: 2011/01/01
`Men's, women's clothing and apparel, namely, caps, shirts, T-shirts, Pants,
`Bathing Suits, Bermuda Shorts, Shorts, SwimTrunks, Hats, Caps with visors,
`Fleece Pullovers, Sweat Shirts, Surf Wear; Athletic apparel, namely, shirts, hats,
`caps
`
`U.S. Registration
`No.
`
`4471719
`
`Registration Date
`
`01/21/2014
`
`Word Mark
`
`Design Mark
`
`LIVE THE SALT LIFE
`
`Application Date
`
`06/21/2012
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 035. First use: First Use: 2010/11/01 First Use In Commerce: 2010/11/01
`Online retail store services and retailstore services featuring clothing, jewelry,
`sports and outdoor living related merchandise
`Class 038. First use: First Use: 2010/11/01 First Use In Commerce: 2010/11/01
`Social media services, namely, the provision of interactive forums in which users
`may exchange information, recordings,videos, and photographs about outdoor-
`related activities
`
`U.S. Registration
`No.
`
`4905379
`
`Registration Date
`
`02/23/2016
`
`Word Mark
`
`LIVE THE SALT LIFE
`
`Application Date
`
`06/21/2012
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 028. First use: First Use: 2011/01/01 First Use In Commerce: 2011/01/01
`sportsman's fishing bags; waterproof bags especially adapted for sports equip-
`ment; fishing equipment, namely, insulatedfish storage bags
`
`U.S. Registration
`No.
`
`4905378
`
`Registration Date
`
`02/23/2016
`
`Word Mark
`
`Design Mark
`
`LIVE THE SALT LIFE
`
`Application Date
`
`06/21/2012
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 020. First use: First Use: 2011/01/01 First Use In Commerce: 2011/01/01
`Beach chairs
`
`U.S. Registration
`No.
`
`4905376
`
`Registration Date
`
`02/23/2016
`
`Word Mark
`
`LIVE THE SALT LIFE
`
`Application Date
`
`06/20/2012
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 024. First use: First Use: 2011/01/01 First Use In Commerce: 2011/01/01
`Banners and flags of textile; Beach towels; Cloth banners; Towels
`
`U.S. Registration
`No.
`
`4902144
`
`Registration Date
`
`02/16/2016
`
`Word Mark
`
`Design Mark
`
`LIVE THE SALT LIFE
`
`Application Date
`
`06/20/2012
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 021. First use: First Use: 2011/01/01 First Use In Commerce: 2011/01/01
`Insulating sleeves holders for beveragecups, cans, and bottles; portable coolers;
`cups, mugs and drinking glasses
`
`U.S. Registration
`No.
`
`4895967
`
`Registration Date
`
`02/02/2016
`
`Application Date
`
`06/20/2012
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`LIVE THE SALT LIFE
`
`NONE
`
`Class 018. First use: First Use: 2011/01/01 First Use In Commerce: 2011/01/01
`All-purpose carrying bags; backpacks; beach bags; beach umbrellas; dog
`leashes;luggage; bags for sports, namely, waterproof bags
`
`

`

`Attachments
`
`77798829#TMSN.png( bytes )
`85883591#TMSN.png( bytes )
`85749357#TMSN.png( bytes )
`85339855#TMSN.png( bytes )
`85195561#TMSN.png( bytes )
`85754930#TMSN.png( bytes )
`86428849#TMSN.png( bytes )
`85658203#TMSN.png( bytes )
`85658035#TMSN.png( bytes )
`85657572#TMSN.png( bytes )
`85656434#TMSN.png( bytes )
`85656310#TMSN.png( bytes )
`85656277#TMSN.png( bytes )
`Petition for Cancellation 7-8-19.pdf(217904 bytes )
`
`Signature
`
`Name
`
`Date
`
`/jason a pittman/
`
`Jason A Pittman
`
`07/08/2019
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of trademark U.S. Registration No.: 5,242,512
`
`Salt Life, LLC,
`
`Cancellation No.: ______________________
`
`
`
`
`
`
`
`Petitioner,
`
`v.
`
`Salt Water Life, Inc.,
`
`Registrant.
`
`
`
`
`
`Mark: SALT WATER LIFE
`
`
`
`
`
`
`
`PETITION FOR CANCELLATION
`
`
`
`
`Salt Life, LLC (“Petitioner” or “Salt Life”), a limited liability company organized under
`
`the laws of Georgia having a place of business at 322 South Main Street, Greenville, SC, 29601,
`
`believes it will be damaged by the continued registration of U.S. Trademark Registration No.
`
`5,242,512 for the alleged mark SALT WATER LIFE (referred to herein sometimes as the
`
`“Registrant’s Mark” or “Registrant’s designation”) for “headwear, namely, caps and hats” in
`
`International Class 025, registered by Salt Water Life, Inc. (“Registrant”), on July 11, 2017.
`
`Therefore, Salt Life hereby petitions to cancel the registration of the same pursuant to § 14 of the
`
`Lanham Act (15 U.S.C. § 1064).
`
`
`
`As grounds in support of its Petition for Cancellation, Petitioner asserts as follows:
`
`1.
`
`Upon information and belief, Salt Water Life, Inc., is the owner of U.S.
`
`Registration No. 5,242,512 (“the ‘512 Registration”), registered on July 11, 2017, for the alleged
`
`mark SALT WATER LIFE for “headwear, namely, caps and hats” in International Class 025.
`
`
`
`Page 1 of 9
`
`

`

`2.
`
`Upon information and belief, the application resulting in the ‘512 Registration,
`
`U.S. Application Serial No. 86972945 (“the ‘945 Application”), was filed on an intent-to-use
`
`basis on or about April 12, 2016.
`
`3.
`
`Upon information and belief, Registrant filed a Statement of Use relevant to the
`
`‘945 Application, alleging both a first use anywhere and a first use in commerce of April 17,
`
`2017 for its alleged mark SALT WATER LIFE on or with “Headwear, namely, caps and hats.”
`
`4.
`
`Since long prior to the April 12, 2016 filing date of the ‘945 Application, or any
`
`date of first use alleged therein or any other alleged date of first use in commerce of the SALT
`
`WATER LIFE designation by Registrant, Petitioner and/or its predecessors in interest have used,
`
`advertised, and promoted the marks SALT LIFE and LIVE THE SALT LIFE as trademarks
`
`(referred to collectively herein as the “SALT LIFE marks”), service marks, and/or have
`
`analogous usage in a trademark or service mark sense or alternatively in a trade name sense, or
`
`use analogous to trademark, service mark or trade name usage, in commerce and/or in interstate
`
`commerce, in connection with numerous goods and/or services, including products related to the
`
`field of clothing, caps, hats and apparel and in connection with other products and/or services.
`
`5.
`
`Salt Life or its predecessors have continuously used, advertised, and promoted the
`
`mark SALT LIFE in connection with various products related to the field of clothing and apparel
`
`and in connection with other products and services since at least as early as October 2003.
`
`6.
`
`Salt Life is the owner of all rights, title, and interest in trademarks that include the
`
`formative words SALT LIFE and LIVE THE SALT LIFE. Petitioner owns extensive common
`
`law rights to its SALT LIFE marks by virtue of the aforementioned use of the marks in
`
`
`
`Page 2 of 9
`
`

`

`commerce. Petitioner also owns United States trademark registrations on the principal register
`
`for its SALT LIFE marks, including at least the following United States trademark registrations.
`
`Trademark
`
`U.S.
`Trademark
`Reg. No.
`3,762,960 August 6,
`2009
`
`SALT LIFE
`
`2,959,429
`
`
`
`September 4,
`2003
`
`International Class &
`Goods/Services
`
`Filing Date Date of First
`Use in
`Commerce
`October 2003 Class 16: Stickers
`Class 25: Caps,
`shirts, surf wear.
`October 2003 Class 25: Clothing
`and apparel, namely,
`caps, shirts, T-shirts,
`bathing suits,
`Bermuda shorts,
`walking shorts, swim
`trunks, caps with
`visors, visors, fleece
`pullovers, sweat
`shirts, surf wear.
`October 2003 Class 25: Clothing,
`namely, hats, caps,
`shirts, T-shirts,
`shorts, swim trunks,
`visors, fleece
`pullovers, sweat
`shirts, surf wear,
`jackets, pants,
`bandanas, sun
`sleeves, dresses and
`footwear.
`January 2007 Class 25: Clothing,
`namely, shirts, sweat
`shirts and caps.
`
`SALT LIFE
`
`4,627,064 March 22,
`2013
`
`4,562,190 October 9,
`2012
`
`SALT LIFE
`
`4,324,994
`
`June 7, 2011
`
`
`
`February
`2013
`
`Class 25: Clothing
`and Apparel, Namely,
`Jackets, Pants, Shoes,
`and Sandals
`
`
`
`Page 3 of 9
`
`

`

`4,335,287 December 10,
`2010
`
`5,091,373 October 16,
`2012
`
`
`
`
`
`LIVE THE SALT LIFE
`
`4,852,462 October 20,
`2014
`
`March 2013 Class 25: Women’s
`Clothing, Namely,
`Caps Shirts T-Shirts,
`Pants, Shoes,
`Sandals, Flip Flops,
`Beach Shoes Walking
`Shorts, Caps with
`Visors, Sweat Shirts
`and Surf Wear
`October 2003 Class 25: Clothing
`and apparel, namely,
`jackets, pants, shoes,
`sandals, bathing suits,
`shorts and sweat
`shirts; sun protective
`clothing, namely
`bandanas
`January 2011 Class 25: For:
`Men’s, Women’s
`Clothing and
`Apparel, Namely,
`Caps, Shirts, T-
`Shirts, Pants, Bathing
`Suits, Bermuda
`Shorts, Shorts, Swim
`Trunks, Hats, Caps
`with Visors, Fleece
`Pullovers, Sweat
`Shirts, Surf Wear;
`Athletic Apparel,
`Namely, Shirts, Hats,
`Caps
`Class 35: For: online
`retail store services
`and retail store
`services featuring
`clothing, jewelry,
`sports and outdoor
`living related
`merchandise; and
`Class 38: For: social
`media services,
`namely, the provision
`of interactive forums
`
`LIVE THE SALT LIFE
`
`4,471,719
`
`June 21, 2012 November
`2010
`
`
`
`Page 4 of 9
`
`

`

`LIVE THE SALT LIFE
`
`4,905,379
`
`June 21, 2012
`
`LIVE THE SALT LIFE
`
`4,905,378
`
`June 21, 2012
`
`LIVE THE SALT LIFE
`
`4,905,376
`
`June 20, 2012
`
`LIVE THE SALT LIFE
`
`4,902,144
`
`June 20, 2012
`
`LIVE THE SALT LIFE
`
`4,895,967
`
`June 20, 2012
`
`in which users may
`exchange
`information,
`recordings, videos,
`and photographs
`about outdoor-related
`activities
`January 2011 Class 28: For:
`sportsman's fishing
`bags; waterproof bags
`especially adapted for
`sports equipment;
`fishing equipment,
`namely, insulated fish
`storage bags
`January 2011 Class 20: For: beach
`chairs
`January 2011 Class 24: For:
`Banners and flags of
`textile; Beach towels;
`Cloth banners;
`Towels
`January 2011 Class 21: For:
`Insulating sleeves
`holders for beverage
`cups, cans, and
`bottles; portable
`coolers; cups, mugs
`and drinking glasses
`January 2011 Class 18: For: all-
`purpose carrying
`bags; backpacks;
`beach bags; beach
`umbrellas; dog
`leashes; luggage;
`bags for sports,
`namely, waterproof
`bags
`
`
`
`7.
`
`The registrations referenced above are valid and subsisting, in full force and
`
`effect, and constitute prima facie and/or conclusive evidence of Petitioner’s exclusive right to
`
`use the marks in commerce in connection with the goods specified in the registrations.
`
`
`
`Page 5 of 9
`
`

`

`8.
`
`Petitioner has priority of use in all respects for its SALT LIFE marks relative to
`
`Registrant’s SALT WATER LIFE designation as used in conjunction with all relevant goods
`
`and services, including those identified in the ‘512 Registration, because Petitioner’s use of its
`
`SALT LIFE and LIVE THE SALT LIFE marks long precedes the filing date of the ‘945
`
`Application and Registrant’s April 17, 2017 date of alleged first use.
`
`9.
`
`Petitioner’s SALT LIFE marks are inherently distinctive and have acquired
`
`distinctiveness through the long, continuous, and exclusive use of the SALT LIFE marks so that
`
`consumers associate the SALT LIFE marks with a single source. The trademark and service
`
`mark SALT LIFE has been used nationally to promote goods to the consuming public and such
`
`use has occurred since as early as 2003.
`
`10.
`
`Salt Life’s use of the SALT LIFE name and the SALT LIFE marks, in word,
`
`stylized and logo form has been substantially exclusive for more than a decade.
`
`11.
`
`Salt Life has generated millions of dollars of revenue through the sale of millions
`
`of products bearing the SALT LIFE marks, including approximately one million t-shirts bearing
`
`the SALT LIFE trademark, to consumers across the United States and internationally.
`
`12.
`
`Salt Life has invested millions of dollars to market the SALT LIFE trademarks
`
`through print and internet advertising channels and the use of brand ambassadors throughout the
`
`United States.
`
`13.
`
`Through its advertising, including its brand ambassadors, the SALT LIFE marks
`
`have permeated the market and are known and recognized.
`
`14.
`
`As a result of Salt Life’s regular, extensive, and well-publicized use, as well as
`
`the above-mentioned advertising, marketing, promotion, and sales, the SALT LIFE name and the
`
`
`
`Page 6 of 9
`
`

`

`SALT LIFE marks, in word, stylized and logo form have become famous and are associated
`
`exclusively with Salt Life and its high quality goods. Indeed, the SALT LIFE name and mark, in
`
`word, stylized and logo form have become famous within the meaning of 15 U.S.C. § 1125(c)
`
`prior to any use of the SALT WATER LIFE designation by Registrant and the filing date of the
`
`‘945 Application.
`
`15.
`
`Petitioner and its predecessors have made substantial investment in advertising,
`
`marketing, and promoting Petitioner’s goods under Petitioner’s SALT LIFE marks. Petitioner
`
`and its predecessors have extensively used, advertised, promoted, and offered Petitioner’s goods
`
`bearing Petitioner’s SALT LIFE marks to the public through various channels of trade in
`
`commerce. Accordingly, Petitioner’s customers and the public in general have come to know
`
`and recognize Petitioner’s SALT LIFE marks to associate the same with Petitioner and/or the
`
`goods sold by Petitioner.
`
`16.
`
`The SALT LIFE marks are symbolic of the extensive goodwill and consumer
`
`recognition that Petitioner has established through substantial expenditures of time, effort and
`
`other resources in the advertising and promotion of the goods Petitioner sells and offers for sale
`
`under the SALT LIFE marks.
`
`17.
`
`As a result of Petitioner’s regular, extensive, and well-publicized use, as well as
`
`the above-mentioned advertising, marketing, promotion, and sales, Petitioner’s SALT LIFE
`
`marks have become famous and are associated exclusively with Petitioner and its high quality
`
`goods. Indeed, Petitioner’s SALT LIFE marks became famous within the meaning of 15 U.S.C.
`
`§ 1125(c) prior to the April 12, 2016 filing date of the ‘945 Application and/or any alleged first
`
`use of the designation SALT WATER LIFE by Registrant.
`
`
`
`Page 7 of 9
`
`

`

`18.
`
`Registrant’s SALT WATER LIFE designation is confusingly similar in sound,
`
`appearance, connotation, and overall commercial impression to Petitioner’s SALT LIFE marks.
`
`19.
`
`Because Registrant’s SALT WATER LIFE designation is for the same or similar
`
`goods and services offered by Petitioner, the channels of trade through which Registrant’s
`
`products, and Petitioner’s products and services are the same or overlap. Such similarities are
`
`likely to cause confusion, mistake or to deceive consumers and lead consumers to believe
`
`Registrant’s goods and services as designated are goods and services of Petitioner, or in some
`
`way backed by, sponsored by, franchised by, approved by, associated with, or otherwise
`
`connected with the good name and reputation of Petitioner, to the damage and injury of the
`
`public, and to the damage and injury of Petitioner and its goodwill in its SALT LIFE marks.
`
`20.
`
`Registrant’s SALT WATER LIFE designation so resembles Petitioner’s SALT
`
`LIFE marks that registration and use of the SALT WATER LIFE designation by Registrant is
`
`likely to cause confusion, mistake or to deceive consumers and lead consumers to believe
`
`Registrant’s goods and services as designated are goods and services of Petitioner, or in some
`
`way backed by, sponsored by, franchised by, approved by, associated with, or otherwise
`
`connected with the good name and reputation of Petitioner, to the damage and injury of the
`
`public, and to the damage and injury of Petitioner and its goodwill in its SALT LIFE marks.
`
`21.
`
`Registrant’s SALT WATER LIFE designation so resembles Petitioner’s SALT
`
`LIFE marks that use of the SALT WATER LIFE designation will cause dilution of the
`
`distinctive qualities of Petitioner’s SALT LIFE marks by blurring Petitioner’s SALT LIFE marks
`
`from association with a single source, namely Petitioner. Such dilution will cause or is likely to
`
`cause damage and injury to Petitioner and its goodwill in its SALT LIFE marks.
`
`
`
`Page 8 of 9
`
`

`

`
`
`WHEREFORE, Petitioner believes it will be damaged by continued registration of the
`
`SALT WATER LIFE mark and prays that the present Petition for Cancellation be granted in
`
`favor of Petitioner and that U.S. Registration No. 5,242,512 be cancelled.
`
`Respectfully submitted,
`
`Date: July 8, 2019
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /
`
`
`
`
`DORITY & MANNING, P.A.
`
` / Jason A. Pittman
`Jason A. Pittman
`jpittman@dority-manning.com
`Tim F. Williams
`tim@dority-manning.com
`DORITY & MANNING, P.A.
`Attorneys at Law
`75 Beattie Place, Suite 1100
`Greenville, SC 29601
`Phone: 864-271-1592
`Fax: 864-335-0127
`
`Attorney for Petitioner
`Salt Life, LLC
`
`Page 9 of 9
`
`

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.

We are unable to display this document.

PTO Denying Access

Refresh this Document
Go to the Docket