Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
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`ESTTA Tracking number:
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`ESTTA1196077
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`Filing date:
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`03/11/2022
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding no.
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`92078700
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`Party
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`Correspondence
`address
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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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`Defendant
`Jam City, Inc.
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`JAM CITY, INC.
`3562 EASTHAM DRIVE
`CULVER CITY, CA 90232
`UNITED STATES
`Primary email: tmclients@cooley.com
`No phone number provided
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`Answer
`
`Andrea Anderson
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`AAnderson@hollandhart.com, TKHawkes@hollandhart.com, dock-
`et@hollandhart.com, ceradoci@hollandhart.com
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`/Andrea Anderson/
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`03/11/2022
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`Attachments
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`Answer to Petition for Cancellation.pdf(124783 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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`Petitioner,
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`HASBRO, INC.,
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`v.
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`JAM CITY, INC.,
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`
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`Respondent.
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`Cancellation No.: 92078700
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`Mark: WORLD WAR DOH
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`Registration No.: 6037670
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`ANSWER TO PETITION FOR CANCELLATION
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`Respondent Jam City, Inc. (“Respondent”), by and through its counsel, responds as
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`follows to the Petition for Cancellation:
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`[Unnumbered Paragraph]. Respondent denies that Petitioner will be damaged by
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`continued registration of the mark shown in Registration No. 6,037,670 (the “Registration”).
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`Respondent admits it is the owner of the Registration and a Delaware corporation having a
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`principal place of business at 3562 Eastham Drive, Culver City, California 90232. Respondent is
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`without information or knowledge sufficient to form a belief as to the truth of the remaining
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`allegations of the unnumbered paragraph and therefore denies them.
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`1.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 1 and therefore denies them.
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`2.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 2 and therefore denies them.
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`3.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 3 and therefore denies them.
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`4.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 4 and therefore denies them.
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`5.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 5 and therefore denies them.
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`6.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 6 and therefore denies them.
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`7.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 7 and therefore denies them.
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`8.
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`Respondent states that while the USPTO records for the registration numbers
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`identified in Paragraph 8 and TSDR printouts at Exhibit A speak for themselves, Respondent lacks
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`sufficient knowledge and information to form a belief as to the truth of the contents of the records,
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`and therefore denies the allegations in Paragraph 8. Respondent further denies the allegations in
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`Paragraph 8 to the extent they are different from or claim more than what is set forth in these
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`USPTO records.
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`9.
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`Respondent states that while the USPTO records identified in Paragraph 9 speak
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`for themselves, Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the contents of the USPTO records, and therefore denies the allegations in Paragraph 9.
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`10.
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`Respondent states that while the USPTO records for the registration numbers
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`identified in Paragraph 10 speak for themselves, Respondent lacks sufficient knowledge and
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`information to form a belief as to the truth of the contents of the USPTO records, and therefore
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`denies the allegations in Paragraph 10.
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`11.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 11 and therefore denies them.
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`12.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 12 and therefore denies them.
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`

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`13.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 13 and therefore denies them.
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`14.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 14 and therefore denies them.
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`15.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 15 and therefore denies them.
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`16.
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`Respondent states that while Exhibit B appears to speak for itself, Respondent lacks
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`sufficient knowledge and information to form a belief as to the contents in Exhibit B and to the
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`truth of the allegations contained in Paragraph 16 and therefore denies them.
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`17.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 17 and therefore denies them.
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`18.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 18 and therefore denies them.
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`19.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 19 and therefore denies them.
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`20.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 20 and therefore denies them.
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`21.
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`Respondent admits the allegations in Paragraph 21.
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`22.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 22 and therefore denies them.
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`23.
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`To the extent the allegations contained in Paragraph 23 constitute legal conclusions,
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`no response is required, and to the extent a response is required, Respondent denies the allegations.
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`24.
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`Respondent admits the allegations contained in Paragraph 24.
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`

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`25.
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`To the extent the allegations contained in Paragraph 25 constitute legal conclusions,
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`no response is required, and to the extent a response is required, Respondent denies the allegations.
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`26.
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`Respondent admits it uses the graphic pictured in Paragraph 26 and that the mark
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`includes the term “DOH” but denies the remaining allegations of the first sentence of Paragraph
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`26. Respondent admits that the pages attached as Exhibit C appear to be printouts taken from
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`www.worldwardoh.com.
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`27.
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`Respondent admits its game that uses the Challenged Mark features characters but
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`denies the remaining allegation in the first sentence of Paragraph 27. Respondent admits that the
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`pages attached as Exhibit C appear to be printouts taken from www.worldwardoh.com.
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`28.
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`Respondent admits its game features “doh” and the World War Doh Instagram page
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`has referenced “doh” but denies the remaining allegation in the first sentence of Paragraph 28.
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`Respondent admits that the pages attached as Exhibit D appear to be printouts of posts on the
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`World War Doh Instagram page.
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`29.
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`Respondent denies the allegations in Paragraph 29.
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`30.
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`Respondent admits Exhibit E appears to be a printout of a post on the World War
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`Doh Facebook page but denies Exhibit E reflects that Respondent adopted, registered, and uses
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`the WORLD WAR DOH mark in bad faith.
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`31.
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`Respondent denies the allegations in Paragraph 31.
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`32.
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`Respondent lacks sufficient knowledge and information with respect to Petitioner’s
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`goods and services to form a belief as to the truth of the allegations contained in Paragraph 32 and
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`therefore denies them.
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`

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`33.
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`Respondent lacks sufficient knowledge and information with respect to the
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`channels of trade Petitioner’s goods and services are offered through to form a belief as to the truth
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`of the allegations contained in Paragraph 33 and therefore denies them.
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`34.
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`To the extent the allegations contained in Paragraph 34 constitute legal conclusions,
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`no response is required, and to the extent a response is required, Respondent denies the allegations.
`
`COUNT I
`Likelihood of Confusion
`15 U.S.C. § 1052(d)
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`35.
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`Respondent incorporates by reference the preceding paragraphs of this Answer.
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`36.
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`Respondent denies the allegations in Paragraph 36.
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`COUNT II
`Likelihood of Dilution
`15 U.S.C. § 1025(c)
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`37.
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`Respondent incorporates by reference the preceding paragraphs of this Answer.
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`38.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 38 and therefore denies them
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`39.
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`Respondent lacks sufficient knowledge and information to form a belief as to the
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`truth of the allegations contained in Paragraph 39 and therefore denies them
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`40.
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`Respondent denies the allegations in Paragraph 40.
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`WHEREFORE, Respondent respectfully requests that the Board dismiss this proceeding
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`with prejudice.
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`Dated: March 11, 2022
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`Respectfully submitted,
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`/s/Andrea Anderson
`Andrea Anderson
`Tara K. Hawkes
`HOLLAND & HART LLP
`P.O. Box 8749
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`Denver, Colorado 80201
`Phone: (303) 473-2861
`AAnderson@hollandhart.com
`TKHawkes@hollandhart.com
`docket@hollandhart.com
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`ATTORNEYS FOR RESPONDENT
`JAM CITY, INC.
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`I hereby certify that a true and correct copy of the foregoing Answer to Petition for
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`CERTIFICATE OF SERVICE
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`Cancellation was served on March 11, 2022, via email on counsel for Petitioner at the following
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`address of record:
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`Catherine M.C. Farrelly
`Frankfurt Kurnit Klein & Selz PC
`28 Liberty Street
`New York, NY 10005
`pto@fkks.com
`alaroui@fkks.com
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`/s/ Craig Radoci
`Craig Radoci
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`18323413_v1
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