Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
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`ESTTA Tracking number:
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`ESTTA1069793
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`Filing date:
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`07/22/2020
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
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`92074717
`
`Party
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`Correspondence
`Address
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`Defendant
`Lanying WU
`
`LANYING WU
`RM 301 JINRONG BLDG JINWAN GARDEN
`NO 1 JINWAN RD XINWAN HUMEN TOWN
`DONGGUAN GUANGDONG, 523899
`CHINA
`Primary Email: USTKAPP@outlook.com
`212-858-9978
`
`Submission
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`Filer's Name
`
`Filer's email
`
`Signature
`
`Date
`
`Answer
`
`Jonathan G. Morton
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`jmlawchina@gmail.com, jmlawaotumanip@gmail.com
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`/Jonathan G. Morton/
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`07/22/2020
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`Attachments
`
`Answer FEEKE.pdf(190189 bytes )
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`

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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`
`
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`CHAOFENG LIU,
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`Petitioner,
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`v.
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`LANYING WU,
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`Respondent.
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`
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`
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`Cancellation No. 92074717
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`Registration No. 6096267
`Mark: FEEKE
`Registration Date: July 07, 2020
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`RESPONDENT’S ANSWER TO THE PETITION FOR CANCELLATION
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`Lanying Wu, (“Respondent”) is a Chinese individual with an address of Rm. 301,
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`Jinrong Bldg., Jinwan Garden, No.1 Jinwan Rd., Xinwan, Humen Town, Dongguan,
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`Guangdong, China 523899, by and through its undersigned counsel, Jonathan G. Morton,
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`answers Chaofeng Liu’s (“Petitioner”) Petition for Cancellation as follows:
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`1. Answering Paragraph 1 of the Petition for Cancellation, Respondent does not have
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the same.
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`2. Answering Paragraph 2 of the Petition for Cancellation, Respondent does not have
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the same.
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`3. Answering Paragraph 3 of the Petition for Cancellation, Respondent does not have
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the same.
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`4. Answering Paragraph 4 of the Petition for Cancellation, Respondent does not have
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`1
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the same, except Applicant admits the existence of U.S.
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`Serial Numbers: 87096628; 88841280; 88876037; 88876041; 88879013; 88890222;
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`88890235; 88890241; 88890250; 88890254; 88890262; 88890272; 88890293; and
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`88890285.
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`5. Answering Paragraph 5 of the Petition for Cancellation, Respondent does not have
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the same.
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`6. Answering Paragraph 6 of the Petition for Cancellation, Respondent admits the
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`allegations contained therein.
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`7. Answering Paragraph 7 of the Petition for Cancellation, Respondent admits the
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`allegations contained therein.
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`8. Answering Paragraph 8 of the Petition for Cancellation, Respondent admits the
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`allegations contained therein.
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`9. Answering Paragraph 9 of the Petition for Cancellation, Respondent does not have
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the same.
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`10. Answering Paragraph 10 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`11. Answering Paragraph 11 of the Petition for Cancellation, Respondent repeats,
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`reiterates and re-alleges every admission, allegation and denial in Paragraphs 1
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`through 10, inclusive, of this Answer with the same force and effect as if fully set
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`forth herein.
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`12. Answering Paragraph 12 of the Petition for Cancellation, Respondent does not have
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`2
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`sufficient knowledge or information to form a belief as to the allegations contained
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`therein and accordingly denies the same.
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`13. Answering Paragraph 13 of the Petition for Cancellation, Respondent admits that its
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`first use in commerce of Registrant’s Mark was May 24, 2019 and denies the
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`remaining allegations therein.
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`14. Answering Paragraph 14 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`15. Answering Paragraph 15 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`16. Answering Paragraph 16 of the Petition for Cancellation, Respondent repeats,
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`reiterates and re-alleges every admission, allegation and denial in Paragraphs 1
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`through 15, inclusive, of this Answer with the same force and effect as if fully set
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`forth herein.
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`17. Answering Paragraph 17 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`18. Answering Paragraph 18 of the Petition for Cancellation, Respondent admits the
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`allegations contained therein.
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`19. Answering Paragraph 19 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`20. Answering Paragraph 20 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`21. Answering Paragraph 21 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`22. Answering Paragraph 22 of the Petition for Cancellation Respondent denies the
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`3
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`

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`allegations contained therein.
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`23. Answering Paragraph 23 of the Petition for Cancellation, Respondent admits that he
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`sells his respective products through e-commerce websites, such as Amazon, and
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`denies the remaining allegations contained therein.
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`24. Answering Paragraph 24 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`25. Answering Paragraph 25 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`26. Answering Paragraph 26 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`27. Answering Paragraph 27 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`28. Answering Paragraph 28 of the Petition for Cancellation, Respondent repeats,
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`reiterates and re-alleges every admission, allegation and denial in Paragraphs 1
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`through 27, inclusive, of this Answer with the same force and effect as if fully set
`
`forth herein.
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`29. Answering Paragraph 29 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`30. Answering Paragraph 30 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`31. Answering Paragraph 31 of the Petition for Cancellation, Respondent admits the
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`allegations contained therein.
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`32. Answering Paragraph 32 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`4
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`

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`33. Answering Paragraph 33 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`34. Answering Paragraph 34 of the Petition for Cancellation, Respondent repeats,
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`reiterates and re-alleges every admission, allegation and denial in Paragraphs 1
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`through 33, inclusive, of this Answer with the same force and effect as if fully set
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`forth herein.
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`35. Answering Paragraph 35 of the Petition for Cancellation, Respondent admits the
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`allegations contained therein.
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`36. Answering Paragraph 36 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`37. Answering Paragraph 37 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`38. Answering Paragraph 38 of the Petition for Cancellation, Respondent admits the
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`allegations contained therein.
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`39. Answering Paragraph 39 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`40. Answering Paragraph 40 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`41. Answering Paragraph 41 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`42. Answering Paragraph 42 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`43. Answering Paragraph 43 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`5
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`

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`44. Answering Paragraph 44 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`45. Answering Paragraph 45 of the Petition for Cancellation, Respondent repeats,
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`reiterates and re-alleges every admission, allegation and denial in Paragraphs 1
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`through 44, inclusive, of this Answer with the same force and effect as if fully set
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`forth herein.
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`46. Answering Paragraph 46 of the Petition for Cancellation, Respondent admits the
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`allegations contained therein.
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`47. Answering Paragraph 47 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`48. Answering Paragraph 48 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`49. Answering Paragraph 49 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`50. Answering Paragraph 50 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`51. Answering Paragraph 51 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`52. Answering Paragraph 52 of the Petition for Cancellation, Respondent denies the
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`allegations contained therein.
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`
`
`
`
`6
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`

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`AFFIRMATIVE DEFENSES
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`Respondent reserves the right to rely on such other and further defenses as may be
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`supported by facts to be determined through comprehensive discovery and to amend its Answer
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`accordingly to assert such defenses.
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`WHEREFORE, Respondent respectfully requests that the Trademark Trial and
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`Appeal Board dismiss the Petition for Cancellation, dated July 14, 2020, with prejudice and
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`permit Registration No. 6096267 to remain registered and in full force.
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`Dated: July 22, 2020
`
`
`
`
`
`By:
`Jonathan G. Morton, Esq.
`Attorney for Respondent
`1395 Brickell Drive
`Suite 900
`Miami, Florida 33131
`Tel: (305) 764-9179
` jmlawchina@gmail.com
`
`7
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and complete copy of the foregoing ANSWER TO THE
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`PETITION FOR CANCELLATION, dated July 22, 2020, has been served on Petitioner’s
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`Attorney of Record by e-mail at the following addresses:
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`Adriano Pacifici, Esq.:
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`apacifici@iplawconsulting.com
`creid@iplawconsulting.com
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`
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`Dated: July 22, 2020
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`By:
`Jonathan G. Morton, Esq.
`
`
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`8
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