Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA1047425
`
`Filing date:
`
`04/06/2020
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`92072279
`
`Party
`
`Correspondence
`Address
`
`Defendant
`Luoyang Hangyuan E-commerce Co., Ltd.
`
`FRANCIS H KOH
`KOH LAW FIRM LLC
`4800 HAMPDEN LANE SUITE 200
`BETHESDA, MD 20814
`UNITED STATES
`fkohmail@gmail.com, ecptm@scienbizip.com, TMProce@scienbizip.com
`301-881-3600
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Attachments
`
`Opposition/Response to Motion
`
`Francis H. Koh
`
`fkohmail@gmail.com, ecptm@scienbizip.com, TMProce@scienbizip.com
`
`/Francis Koh/
`
`04/06/2020
`
`Opposition to Motion for Summary Judgment - Haircube-.pdf(1538729 bytes )
`Verification.pdf(930515 bytes )
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Cancellation Proceeding
`No. 92072279
`
`)
`
`))
`
`))
`
`)
`)
`
`))
`
`))
`
`)
`
`In the Matter of Reg. No.: 5780133 and 5774901
`Mark: HAIRCUBE
`
`Nir Ron
`
`Petitioner,
`
`v.
`
`Luoyang Hangyuan E-commerce Co., Ltd.
`
`Registrant.
`
`REGISTRANT’S OPPOSITION TO PETITIONER’S MOTION FOR
`SUMMARY JUDGMENT
`
`Registrant Luoyang Hangyuan E-commerce Co., Ltd. (“Registrant”), by and through
`
`undersigned counsel, hereby files this Opposition to Petitioner’s Motion for Summary
`
`Judgment and states the following in support:
`
`Background And Facts
`
`(herein after referred to as “H3”)
`1. Petitioner previously had its mark
`registered under 4026264 on September 13, 2011, but more importantly, it was
`
`cancelled on April 20, 2018.
`
`1 / 15
`
`

`

`2. On June 11, 2019, the USPTO approved Registration of HAIRCUBE (hereinafter
`
`“HAIRCUBE” or “haircube” or “Haircube”)
`
`in standard character
`
`form with
`
`Registration No. 5774901 in international class 005 with an alleged first use in
`
`commerce as of September 01, 2018 for Aerosol dispensers for medical use sold filled
`
`with hair growth stimulants; Analgesics; Anti-inflammatories; Cytostatics for medical
`
`purposes; Hair growth stimulants; Human growth hormone; Medical plasters;
`
`Medicated hair care preparations; Medicated hair serums; Medicated skin soap;
`
`Medicinal herbs; Medicinal oils; Medicinal preparations for stimulating hair growth;
`
`Sterilizing preparations; Sticking plasters for medical use; Dietetic foods adapted for
`
`medical purposes; Medicated balms for treatment of hair; Medicated lotions for hair;
`
`Medicated serums for treatment of hair Medicinal hair growth preparations.
`
`3. On June 18, 2019, Registrant registered the mark HAIRCUBE in standard character
`
`form with Registration No. 5780133 in international class 003 with an alleged first
`
`use in commerce as of September 01, 2018 for Colognes, perfumes and cosmetics;
`
`Cosmetic hand creams; Cosmetic oils; Cosmetic preparations for body care; Cosmetic
`
`suntan lotions; Cosmetics; Face creams for cosmetic use; Facial masks; Lip stains;
`
`Lipstick; Make-up removing lotions; Nail paint; Nail polish remover pens;
`
`Pre-moistened cosmetic wipes; Cleansing creams; Cosmetic creams for skin care;
`
`Cosmetic preparations for protecting the skin from the sun's rays; Cosmetic
`
`preparations for removing gel nails, acrylic nails, and nail polish; Cosmetic products
`
`in the form of aerosols for skincare; Cosmetics for children.
`
`4. The USPTO approved for registration Haircube 5780133 (class 3) and 5774901
`
`2 / 15
`
`

`

`(class 5) after the required notice period after publication for anyone to file an
`
`opposition to its registration. Further, the USPTO was fully aware of the petitioner’s
`
`cancelled mark
`
`4026264 at the time.
`
`5. Petitioner failed to file any opposition to the registration of HAIRCUBE 5780133
`
`(class 3) and 5774901 (class 5) during this notice period, and Registrant’s stated
`
`marks were duly registered.
`
`6. Petitioner’s mark was cancelled during this period and presumably Petitioner was not
`
`conducting any business, and therefore did not file any opposition, and more
`
`importantly, failed to provide the required statement of use to the USPTO.
`
`7. On May 28, 2019, the Petitioner attempted to re-register and arguably, revive his
`
`earlier forfeited H3 mark, which led to the Examiner citing Registrant’s Haircube
`
`5780133 (class 3) and 5774901 (class 5).
`
`8. Now, in a fit of desperation, Petitioner seeks to cancel Registrant’s proper marks.
`
`9. On March 6, 2020, Petitioner filed its Motion for Summary Judgment lacking any
`
`evidence that it did not forfeit rights to the mark while asserting there is no material facts
`
`in dispute.
`
`Standard of Review
`
`Summary Judgment Standard
`
`3 / 15
`
`

`

`10. It is the Movant’s burden to demonstrate the absence of any genuine dispute of
`
`material fact and that it is entitled to judgment as a matter of law. Anderson v. Liberty
`
`Lobby, Inc., 477 U.S. 242, 256-57 (1986).
`
`11. A material fact is a fact that could matter to (have legal impact on) the outcome of the
`
`case. Anderson at 248. If met, non-movant must proffer countering evidence to show
`
`there is a genuine dispute for trial. Octocom Systems Inc. v. Houston Computer
`
`Services Inc., 918 F.2d 937, 16 USPQ2d 1783, 1786 (Fed. Cir. 1990). Non-movant is
`
`given benefit of doubt. Lloyd's Food Products Inc. v. Eli's Inc., 987 F.2d 766, 25
`
`USPQ2d 2027, 2029 (Fed. Cir. 1993)
`
`Domain Name Use
`
`12. When a mark appears in the computer browser area as part of the URL, Internet
`
`address, or domain name of the website that houses the web page, consumers
`
`generally do not recognize this as trademark use.
`
`13. Instead, this use merely identifies the Internet location of the website where business
`
`is conducted and goods or services are offered. See, e.g., In re Roberts, 87 USPQ2d
`
`1474, 1479-80 (TTAB 2008) (concluding that the mark IRESTMYCASE, which
`
`appeared as part of a website address, www.irestmycase.com, on applicant’s
`
`specimens, merely served as a contact address to reach the applicant and failed to
`
`function as a service mark for applicant’s services); In re Supply Guys, Inc., 86
`
`USPQ2d 1488, 1493 (TTAB 2008) ( “[A]pplicant’s use of the term LEADING EDGE
`
`4 / 15
`
`

`

`TONERS as part of the internet address, www.leadingedgetoners.com, . . . identifies
`
`the website where applicant conducts its retail sales services.
`
`Arguments
`
`Priority
`
`PETITIONER’S PRIORITY CLAIM IS IN DISPUTE BECAUSE PETITIONER’S
`
`MARK WAS CANCELLED DUE TO FAILURE TO PROVIDE THE NECESSARY
`
`DOCUMENTATIONS INCLUDING STATEMENT OF USE
`
`14. Petitioner admits its mark H3 was cancelled for failure to provide the necessary
`
`documentation, which includes any statement of use and the necessary fees.
`
`15. The undisputed docket chronology shows after Petitioner’s H3 mark was cancelled on
`
`April 20, 2018, Registrant filed its application for haircube on November 8, 2018,
`
`citing first use date of September 1st, 2018.
`
`16. Aside from bald assertions, Petitioner provides no verifiable evidence that it did not
`
`forfeit any claim to H3 during the period after April 20, 2018 or earlier.
`
`17. Additionally, Petitioner
`
`improperly asserts that his ownership of
`
`the domain
`
`www.haircube.com confers him trademark rights.
`
`18. To the contrary, ownership the domain does not by itself confer priority or ownership
`
`of rights in the mark. See id. And any priority Petitioner may have had was
`
`5 / 15
`
`

`

`lost/forfeited.1
`
`19. Thus, Registrant disputes Petitioner’s priority claim and alleges due to Petitioner’s
`
`mark cancellation, Registrant is the proper and duly entitled user of the mark.
`
`No Likelihood of Confusion
`
`Argument
`
`against Likelihood
`
`of Confusion
`
`between
`
`"HAIRCUBE"
`
`and
`
`"
`
`"
`
`Comparison of the Marks
`
`20. First, just a visual examination of Petitioner’s and Registrant’s Mark show they are
`
`not similar in appearance, sound, connotation, and commercial
`
`impression and
`
`arguably no reasonable person or consumer would confuse the two.
`
`21. The registered mark is "HAIRCUBE" in standard character.
`
`See below, and
`
`Registrant’s Exhibit 1 Showing Specimen with Haircube mark, showing difference to
`
`Petitioner’s.
`
`1 Registrant argues it is actually prior to Petitioner without waiving its right to claim
`that H3 and Haircube are distinct and not confusing,
`6 / 15
`
`

`

`22. Meanwhile wording while the applied-for mark is "
`
`" in stylized
`
`wording. Specifically, the applied-for mark consists of the wording "H3", with the
`
`"H" in white outlined in red, and with the "3" appearing in red with white at the right
`
`edge of the "3" making it look three-dimensional.
`
`23. The "H3" appears above the wording "HAIR CUBED" in white; one horizontal line in
`
`white underneath "H3" and one horizontal line in white below the 'HAIR CUBED";
`
`all with a black background, which makes the appearance and sound of these two
`
`marks totally different.
`
`24. Examining Petitioner’s Website, www.haircube.com,
`
`further shows the glaring
`
`difference.
`
`See Registrant’s Exhibit 2 Showing Snapshot of Petitioner’s website.
`
`Also, as addressed earlier, simply claiming a domain name does not confer rights to
`
`the mark. See id.
`
`25. The registration mark "HAIRCUBE", is the literal translation of Chinese characters
`
`“发” and “立方”, which refers to the combination of “HAIR” and “CUBE” in English.
`
`However, applied-for mark is "
`
`", in which H3 refers to tritium, an
`
`7 / 15
`
`

`

`isotope of hydrogen with a mass that is three times that of the usual isotope.
`
`26. Additionally, the applied-for mark is with a disclaimer that “No claim is made to the
`
`exclusive right
`
`to use ‘HAIR’ apart from the mark as shown”. Therefore,
`
`the
`
`connotations and commercial impression of these two marks are heading in contrary
`
`direction.
`
`Comparison of the Good
`
`27. First, Registrant submits that the relatedness of the goods between Registrant's goods
`
`in Class 3, Class 5, and Petitioner's goods in Class 3 is not existent.
`
`28. Registrant’s goods are in international class 003 for Colognes, perfumes and
`
`cosmetics; Cosmetic hand creams; Cosmetic oils; Cosmetic preparations for body
`
`care; Cosmetic suntan lotions; Cosmetics; Face creams for cosmetic use; Facial masks;
`
`Lip stains; Lipstick; Make-up removing lotions; Nail paint; Nail polish remover pens;
`
`Pre-moistened cosmetic wipes; Cleansing creams; Cosmetic creams for skin care;
`
`Cosmetic preparations for protecting the skin from the sun's rays; Cosmetic
`
`preparations for removing gel nails, acrylic nails, and nail polish; Cosmetic products
`
`in the form of aerosols for skincare; Cosmetics for children and in international class
`
`005 for Aerosol dispensers for medical use sold filled with hair growth stimulants;
`
`Analgesics; Anti-inflammatories; Cytostatics for medical purposes; Hair growth
`
`stimulants; Human growth hormone; Medical plasters; Medicated hair care
`
`preparations; Medicated hair serums; Medicated skin soap; Medicinal herbs;
`
`Medicinal oils; Medicinal preparations for stimulating hair growth; Sterilizing
`8 / 15
`
`

`

`preparations; Sticking plasters for medical use; Dietetic foods adapted for medical
`
`purposes; Medicated balms for
`
`treatment of hair; Medicated lotions for hair;
`
`Medicated serums for treatment of hair Medicinal hair growth preparations.
`
`29. However, Petitioner’s goods are in international class 003 for Cosmetic hair filling
`
`sprays and fibers for covering bald and thinning spots on the scalp; Hair thickener
`
`spray; Cosmetic hair dressing preparations; Cosmetic hair
`
`regrowth inhibiting
`
`preparations; Cosmetic preparations for the hair and scalp; Non-medicated exfoliating
`
`preparations for hair; Hair care creams; Hair care kits comprising non-medicated hair
`
`care preparations, namely, shampoos, hair loss capsules, gels, conditioners, hair spray,
`
`and shine spray; Hair care lotions; Hair care preparations; Hair cleaning preparations;
`
`Hair coloring preparations; Hair conditioners; Hair creams; Hair pomades; Hair
`
`products, namely,
`
`thickening control creams; Hair rinses; Hair shampoo; Hair
`
`shampoos and conditioners; Hair spray; Hair spray and hair gels; Hair styling
`
`preparations; Hair tonic; Hair tonics; Non-medicated lotions for hair; Hair mousse;
`
`Non-medicated hair restoration lotions; Non-medicated hair treatment preparations
`
`for cosmetic purposes; Non-medicated preparations all for the care of skin, hair and
`
`scalp.
`
`30. Although Registrant’s goods and Petitioner’s goods are cosmetics products involved
`
`in class 3, these two goods are different in nature and can lead to entirely distinct
`
`chemical or physical reactions.
`
`31. Specially, Registrant’s goods are for skin care while Petitioner’s goods are for hair
`
`care. Skin refers to the natural outer layer of a person’s or animal’s body while hair is
`
`9 / 15
`
`

`

`the mass of things line fine threads that grows on the head.
`
`32. Additionally, Registrant’s goods in class 5 are medical hair care products that relates
`
`to medicine while Petitioner’s goods in class 3 are non-medical hair care products.
`
`Therefore, Registrant’s goods in class 3, class 5 is not related to Petitioner’s goods in
`
`class 3.
`
`33. The mark HAIRCUBE was originally created by Registrant. Registrant manufactures,
`
`markets, and distributes its goods in class 3 and class 5 in the China, U.S. and other
`
`English-Speaking countries under the well-known, globally recognized trademark
`
`"HAIRCUBE" in standard wording.
`
`34. Registrant’s
`
`products
`
`are
`
`sold
`
`on
`
`https://haircube.net
`
`and
`
`https://www.amazon.com/dp/B07SHM4TPH?ref=myi_title_dp，and have acquired a
`
`high degree of distinctiveness and recognition in the marketplace. Please see Exhibit
`
`3.
`
`35. The marks, "HAIRCUBE" and "
`
`" presently co-exist in the online
`
`environment without any known instances of confusion.
`
`36. On information and belief, Registrant does have basis for claiming rights and
`
`reserving a right in the mark "HAIRCUBE" in connection with the goods as listed in
`
`its trademark registrations because a reasonable person examining the two marks
`
`would not reach the conclusion that Registrant’s mark HAIRCUBE is similar to
`
`petitioner’s mark
`
`, and it is not likely a consumer would be confused,
`
`10 / 15
`
`

`

`mistaken, or deceived as to the source of the goods of the Registrant and Petitioner.
`
`37. Hence, there is a factual dispute whether Petitioner’s mark or Registrant’s Standard
`
`character mark are similar enough to confuse consumers.
`
`Summary
`
`38. Because there are material facts in disputes whether Petitioner forfeited its rights to
`
`H3 and whether the marks are even similar enough to confuse consumers,
`
`the
`
`Petitioner’s Motion for Summary Judgment must be denied.
`
`WHEREFORE,
`
`for
`
`the
`
`foregoing reasons, Registrant
`
`respectfully requests
`
`Petitioner’s Motion for Summary Judgment be denied.
`
`Dated: April 06, 2020
`
`Respectfully submitted,
`
`By: /Francis H. Koh/
`Francis H. Koh
`Koh Law Firm, LLC.
`4800 Hampden Lane, St. 200
`Bethesda, Maryland, 20814
`United States
`fkohmail@gmail.com
`TMProce@scienbizip.com
`ecptm@scienbizip.com
`Attorneys for Respondent
`Luoyang Hangyuan E-commerce Co., Ltd.
`
`11 / 15
`
`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and complete copy of the foregoing Registrant’s
`Opposition to Petitioner’s Motion for Summary Judgement has been served on
`Petitioner’s Attorneys by forwarding said copy on April 06, 2020, via email to:
`
`ADRIANO PACIFICI
`INTELLECTUAL PROPERTY CONSULTING LLC
`334 CARONDELET ST STE B
`NEW ORLEANS, LA 70130
`UNITED STATES
`Phone: 504-323-6600
`apacifici@iplawconsulting.com
`trademarks@iplawconsulting.com
`Attorneys for Nir Ron
`
`By: /Francis H. Koh/
`Francis Koh
`
`12 / 15
`
`

`

`EXHIBIT 1
`
`EXHIBIT 1
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`EXHIBIT 2
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`EXHIBIT 2
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`14 / 15
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`15/15
`15 / 15
`
`

`

`2020/4/7
`
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`Beauty & Personal Care Hair Care Hair Loss Products Hair Regrowth Treatments
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`Hair Growth For Men Women Hairline Mask Hair Loss 30 Pack Mask Scalp Care with Patent Pure Natural Plant
`Ginger Juice Essence HM30H
`by HAIRCUBE
`
`
`
` 6 ratings
`
`Price: $19.99 ($0.67 / Count) FREE Shipping on orders over $25.00 shipped by Amazon or get Fast, Free Shipping with Amazon Prime & FREE Returns
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`Get $10 o(cid:381) instantly: Pay $9.99 upon approval for the Amazon Prime Store Card.
`
`(cid:752)MASK FOR HAIRLINE GROWTH(cid:753)- This hair growth mask (with patent NO.29686379) is specially designed for hairline receding, according to shape of people’s hairline area.
`Relieve hair loss caused by excessive oil and hair follicle blockage. E(cid:381)ective soothing and deep hydration.
`(cid:752)SAFE & NATURAL ESSENCE(cid:753)- Ginger gently stimulates hair follicles. Other herbal ingredients sterilize scalp, relieve scalp fatigue and help to improve hair follicle
`environment. Relieve secretion of oil, clean up cosmetics residue and nourish scalp of hairline area.
`(cid:752)BIO-FIBER MASK(cid:753)- Fermented in natural coconut, being the smallest organic fiber in nature. Skin-like function, super soft and elastic. Penetrate oxygen and isolate
`bacteria. Strong water absorption, oil discharge and decontamination performance. No (cid:383)uorescent substances existing.
`(cid:752)INDIVIDUAL PACKAGE(cid:753)- Small and light with thoughtful individual wrap, the hairline regrowth mask sheet is not only hygienic to use, but also convenient to carry
`wherever you go. Nice gift idea for friends, spouse and parents.
`(cid:752)100% SATISFACTION(cid:753)- Pack of 30 (once daily, 10-15 minutes). Suitable for all hair types of male and female. Please remove the supporting net cloth on one side before
`applying the sheet. It is normal if the hairline area has a slightly cold or hot feeling during wearing. Please avoid contacting eyes.
`
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`LARITELLE
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`2020/4/7
`
`Amazon.com : Hair Growth For Men Women Hairline Mask Hair Loss 30 Pack Mask Scalp Care with Patent Pure Natural Plant Ginger Juice Essence HM30H : Beauty
`
`Product Description
`
`Ginger Extract
`
`Gently Stimulate Hair Follicle
`Promote Blood Circulation
`Relieve Secretion Of Oil
`
`HM05H
`
`HM20H
`
`HM30H
`
`HM05M
`
`HM20M
`
`HM30M
`
`EFFICACY
`
`Nourishing
`
`Nourishing
`
`Nourishing
`
`Strengthened
`
`Strengthened
`
`Strengthened
`
`KEY INGREDIENT
`
`Ginger Extract
`
`Ginger Extract
`
`Ginger Extract
`
`Minoxidil
`
`Minoxidil
`
`Minoxidil
`
`PIECES
`
`INDIVIDUAL PACKAGE
`
`5
`
`✓
`
`20
`
`✓
`
`30
`
`✓
`
`5
`
`✓
`
`20
`
`✓
`
`30
`
`✓
`
`COLOR
`
`Colorless
`
`Colorless
`
`Colorless
`
`Light Yellow
`
`Light Yellow
`
`Light Yellow
`
`Product details
`Shipping Weight: 3.5 ounces (View shipping rates and policies)
`ASIN: B07SHM4TPH
`Customer Reviews:
`6 customer ratings
`Amazon Best Sellers Rank: #250,400 in Beauty & Personal Care (See Top 100 in Beauty & Personal Care)
`#879 in Hair Regrowth Treatments
`
`Would you like to tell us about a lower price?
`
`https://www.amazon.com/dp/B07SHM4TPH?ref=myi_title_dp
`
`2/5
`
`

`

`Amazon.com : Hair Growth For Men Women Hairline Mask Hair Loss 30 Pack Mask Scalp Care with Patent Pure Natural Plant Ginger Juice Essence HM30H : Beauty
`
`2020/4/7
`
`Videos
`
`Videos for this product
`
`0:53
`Haircube Hairline Mask Scalp Care
`
`Amazon Seller
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`
`Important information
`
`Directions
`1. Clean the hairline with water and dry it; 2. Take out the middle layer of the mask and stick it on the hairline; 3. Gently massage with your fingertips to spread the liquid evenly; 4. Remove the mask after 10-15 minutes, no need to rinse. It is recommended to use once daily.
`
`Customer Questions & Answers
`See questions and answers
`
`Ad feedback
`
`Customer reviews
`4.8 out of 5
`
`6 customer ratings
`
`Top Reviews
`
`Jacob n.
`
`https://www.amazon.com/dp/B07SHM4TPH?ref=myi_title_dp
`
`3/5
`
`Top Reviews
`
`

`

`2020/4/7
`5 star
`4 star
`3 star
`2 star
`1 star
`
` 78%
` 22%
` 0%
` 0%
` 0%
`
`How does Amazon calculate star ratings?
`
`Amazon.com : Hair Growth For Men Women Hairline Mask Hair Loss 30 Pack Mask Scalp Care with Patent Pure Natural Plant Ginger Juice Essence HM30H : Beauty
` Thank you
`Reviewed in the United States on February 6, 2020
`Verifi ed Purchase
`
`Hello thank you for the item
`
`Helpful
`
`Comment
`
`Report abuse
`
`Uday
`
` Hairline packs
`Reviewed in the United States on December 24, 2019
`Verifi ed Purchase Early Reviewer Rewards (What's this?)
`
`It seems to be working , will post final review when I complete 30 day
`
`Helpful
`
`Comment
`
`Report abuse
`
`james
`
` Works ok.
`Reviewed in the United States on January 8, 2020
`Verifi ed Purchase
`
`Ad feedback
`
`My forehead is pretty wide. So the strip didn't fit completely across my hairline. Had to use two strips at once. I saw
`ok results
`
`One person found this helpful
`
`Helpful
`
`Comment
`
`Report abuse
`
`G. Logsdon
`
` Helps with thinning hair....
`Reviewed in the United States on December 21, 2019
`Verifi ed Purchase Early Reviewer Rewards (What's this?)
`
`Help my hair grow in areas that was thinning and falling out...,
`Be sure to use every day....
`
`Helpful
`
`Comment
`
`Report abuse
`
`See all reviews from the United States
`
`Disclaimer: While we work to ensure that product information is correct, on occasion manufacturers may alter their ingredient lists. Actual product packaging and materials may contain more and/or different information than that shown on our Web site. We recommend that you do not solely rely on the information presented and that
`you always read labels, warnings, and directions before using or consuming a product. For additional information about a product, please contact the manufacturer. Content on this site is for reference purposes and is not intended to substitute for advice given by a physician, pharmacist, or other licensed health-care professional. You
`should not use this information as self-diagnosis or for treating a health problem or disease. Contact your health-care provider immediately if you suspect that you have a medical problem. Information and statements regarding dietary supplements have not been evaluated by the Food and Drug Administration and are not intended to
`diagnose, treat, cure, or prevent any disease or health condition. Amazon.com assumes no liability for inaccuracies or misstatements about products.
`
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`
`4/5
`
`

`

`2020/4/7
`
`Amazon.com : Hair Growth For Men Women Hairline Mask Hair Loss 30 Pack Mask Scalp Care with Patent Pure Natural Plant Ginger Juice Essence HM30H : Beauty
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`5/5
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`

`

`VERIFICATION/AFFIDAVIT OF REGISTRANT
`
`I,
`
`[Ail/h Ymnm
`
`, am Principal of Luoyang Hangyuan
`
`E-commerce Co.,Ltd., declare:
`
`The registrant in the above-captioned matter, hereby attest, subject to the penalties of
`
`perjury that the averments and allegations of fact made in the foregoing Opposition to
`
`Petitioner’s Motion for Summary Judgment are true and correct to the best of my
`
`knowledge.
`
`Dated:
`
`0
`
`0
`
`)W-0
`
`Lil/l, YMO‘W
`
`12/15
`
`