Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
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`ESTTA Tracking number:
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`ESTTA1240688
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`Filing date:
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`10/10/2022
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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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`92080451
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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
`THE DIVA LAWYERS SOCIAL CLUB INC
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`THE DIVA LAWYERS SOCIAL CLUB INC
`1158 26TH STREET, #783
`1158 26TH STREET, #783
`SANTA MONICA, CA 90403
`UNITED STATES
`Primary email: atyriasclark@gmail.com
`3104157112
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`Motion to Dismiss - Rule 12(b)
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`Atyria S Clark
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`atyriasclark@gmail.com, divalawyers@gmail.com
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`/Atyria S Clark/
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`10/10/2022
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`Attachments
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`Motion to Dismiss Petition to Cancel for Filing.pdf(241400 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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`Lonita K. Baker,
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`Petitioner,
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`Cancellation No.: 92080451
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`v.
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`THE DIVA LAWYERS SOCIAL CLUB, INC,
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`
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`Registrant.
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`________________________________________/
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`REGISTRANT’S MOTION TO DISMISS PETITION FOR
`CANCELLATION PURSUANT TO FED. R. CIV. P. 12(b)(1) and 12(b)(6)
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`Registrant, THE DIVA LAWYERS SOCIAL CLUB, INC (“Registrant”)
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`moves to dismiss with prejudice the above-captioned Petition for Cancellation
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`(“Petition”) filed by Petitioner, Lonita K. Baker (“Petitioner”) pursuant to Fed. R.
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`Civ. P. 12(b)(1) (“Rule 12(b)(1)), Fed. R. Civ. P. 12(b)(6) (“Rule 12(b)(6)”) and
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`Trademark Trial and Appeal Board (“TTAB” or the “Board”) Section 503.02 of the
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`Trademark Trial and Appeal Board’s Manual of Procedure (“Manual”) because, as
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`a matter of fact and law, Petitioner lacks standing for this Petition. The Petition also
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`fails to allege sufficient facts in support of its claims against Registrant for
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`abandonment due to claims that the Registrant never used the mark “DIVA
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`LAWYERS” (the “Mark”) in commerce.
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`
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`I.
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`ARGUMENT
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`Registrant is the owner of the Mark in Class 200, a collective membership
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`mark “indicating membership in a social club organization of female attorneys.”
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`1
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`

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`Registration No.: 5769971. This Mark was registered with the United States Patent
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`and Trademark Office on June 4, 2019 and has been used as early as January 13,
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`2014 and used by its members to indicate their membership in the social club as
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`early as May 1, 2018.
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`Petitioner, Lonita K. Baker (“Petitioner”) claims to be the owner of [an intent
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`to use] Application, Serial No. 87/939,686 for “Diva Attorney, Lonita K. Baker” for
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`“providing legal information, namely, legal information about civil rights, personal
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`injury, business law, and criminal law proffered to clients hired by an individual
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`attorney and not pertaining to membership of any social club organization,” in Class
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`45. See Petition for Cancellation, ¶ 3.
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`On April 23, 2021, Registrant filed its Notice of Opposition No. 91/268,921
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`against Petitioner’s application due to likelihood of confusion with the Mark “Diva
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`Lawyers.” Opposition, ¶ 6. Registrant also filed the Opposition on the basis that
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`Petitioner did not establish a bona fide intent to use her mark in commerce for the
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`identified goods and services and because her applied for mark indicates a false
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`suggestion of connection with the organization THE DIVA LAWYERS SOCIAL
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`CLUB. Opposition, ¶¶ 7-8.
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`In this present proceeding, Petitioner alleges, as a basis for her Petition for
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`Cancellation that the “DIVA LAWYERS” mark should be cancelled because “upon
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`information and belief, Respondent has never used the mark “DIVA LAWYERS”
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`in interstate commerce in connection with a collective mark indicating membership
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`in a social club organization of female attorneys.” Petition to Cancel, ¶ 5.
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`Petitioner then alleges false statements about documents provided to her in
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`the Opposition proceedings that she feels do not amount to the Registrant’s use in
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`interstate commerce of the Mark. Petition for Cancellation, ¶¶ 5-11. These
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`speculative and conclusory allegations do not amount to facts sufficient to support
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`Petitioner’s Petition.
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`2
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`Moreover, Petitioner has failed to provide any legitimate explanation as to
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`why or how the use of the Mark would personally damage her and therefore, lacks
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`standing to bring this Petition.
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`The Petition, as a matter of law, does not state any claim for cancellation of
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`the Mark but rather constitutes a series of frivolous and nonsensical allegations
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`meant to malign and harass the Registrant and was filed for an improper purpose.
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`Moreover, as evident from Petitioner’s allegations set forth in the Petition, she does
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`not own any registered trademark at all, she only alleges that she is the owner of an
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`application for a trademark (Petition to Cancel, ¶ 3), and thus cannot claim any actual
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`damage or harm from Registrant’s collective membership mark registration.
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`Petitioner cites no facts in support of any of her conclusory “grounds” for the
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`Petition. The Petition wholly fails to concisely and directly state the elements of each
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`claim for relief as it relates to a collective membership mark and as required by Fed.
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`R. Civ. P. 8(a) and (d), the TBMP and decisional authority, thereby failing to provide
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`Registrant with fair notice of the actual basis for Petitioner’s Petition.
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`As a result, Petitioner has neither standing nor grounds to cancel the Mark.
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`Therefore, the Petition should be dismissed in its entirety, with prejudice.
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`A. LEGAL STANDARD ON MOTION TO DISMISS
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`1. Motion to Dismiss Pursuant to Rule 12(b)(1)
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`A motion to dismiss brought pursuant to Federal Rule of Civil Procedure
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`12(b)(1) challenges the lack of subject matter jurisdiction, namely whether a party
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`has standing to bring forth a claim. See Fed. R. Civ. P. 12(b)(1); see also
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`Corporacion Habanos, S.A. and Empresa Cubana del Tobacco, d.b.a. Cubatabaco
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`v. Rodriguez, Cancellation No. 92052146, 2011 TTAB LEXIS 258, at *3 (T.T.A.B.
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`Aug. 1, 2011) (“In the context of cancellation proceedings before the Board, a claim
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`is plausible on its face when the petitioner pleads factual content that if proved,
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`would allow the Board to conclude, or draw a reasonable inference that, the
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`petitioner has standing and that a valid ground for cancellation exists.”). In order to
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`3
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`establish standing, a “petitioner must allege facts which, if ultimately proven, would
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`establish that petitioner has a ‘real interest,’ i.e., a ‘personal stake’ in the proceeding.
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`Doyle v. Al Johnson’s Swedish Restaurant & Butik, Inc., 101 U.S.P.Q.2d (BNA)
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`1780, 1782 (T.T.A.B. 2012) (internal citations omitted); see also Jewelers Vigilance
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`Committee, Inc. v. Ullenberg Corp., 2 U.S.P.Q.2d 2012, 2023 (Fed. Cir. 1987) (in
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`pleading stage of proceeding the plaintiff must plead facts sufficient to show a real
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`interest in the proceeding to establish standing.)
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`2. Motion to Dismiss Pursuant to Rule 12(b)(6)
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`Furthermore, under Rule 12(b)(6) of the Federal Rules of Civil Procedure and
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`Trademark Trial and Appeal Board Manual of Procedure (“TBMP”) § 503, a
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`registrant may move to dismiss a petition for cancellation for “failure to state a claim
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`upon which relief can be granted.” Id. To withstand such a motion, “a complaint
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`must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that
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`is plausible on its face.’” Corporation Habanos, S.A. v. Rodriguez, 99 U.S.P.Q.2d
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`1873, 1874 (T.T.A.B. 2011) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).
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`In the context of a cancellation proceeding before the Board, “a claim is plausible
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`on its face when the petitioner pleads factual content that if proved, would allow the
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`Board to conclude, or draw a reasonable inference that, the petitioner has standing
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`and that a valid ground for cancellation exists.” Id. (citation omitted); see also TBMP
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`§ 503.02; see also Kelly Services, Inc. v. Greene’s Temporaries, Inc., Cancellation
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`NO. 19,971, 1992 TTAB LEXIS 57, at *5 (T.T.A.B. Nov. 24, 1992) (citing Lipton
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`Industries, Inc. v. Ralston Purina Co., 213 U.S.P.Q. (BNA) 185 (C.C.P.A. 1982). In
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`particular, a party must plead “enough factual matter…..to suggest that [a claim is
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`plausible]” and “raise a right to relief above the speculative level.” Totes-Isotoner
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`Corp. v. United States, 594 F.3d 1346, 1354 (Fed. Cir. 2010).
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`Factual allegations must not only be well-pleaded, but they also must be more
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`than “[t]hreadbare recitals of the elements of a cause of action, supported by mere
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`4
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`conclusory statements.” Doyle v. Al Johnson’s Swedish Rest. & Butik, Inc., 101
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`U.S.P.Q.2d 1780, 1782 (T.T.A.B. 2012) (quoting Iqbal, 556 U.S. at 678).
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`Dismissal is appropriate where a pleading does not allege the facts necessary
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`to establish that a petitioner is entitled to relief. See Fed. R. Civ. P. 12(b)(6). Indeed,
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`where the defects in a petition are incurable and the nature of the allegations are
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`clearly frivolous, a petition should therefore be dismissed with prejudice. See United
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`Food & Commer. Worker Cent. Pa. v. Amgen, Inc., 400 Fed. Appx. 255 (9th Cir.
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`2010).
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`Federal Rules of Civil Procedure, Rule 8 requires “a short and plain statement
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`of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2).
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`Under the pleading standards established by Ashcroft v. Iqbal, 556 U.S. 662 (2009)
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`and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), Petitioner must do more
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`than merely state that the law has been violated—Petitioner must plead sufficient
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`facts to show that it has a plausible claim for relief.
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`First and foremost, at a basic level, Petitioner fails to establish the necessary
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`standing required to bring this Petition before the Board against Registrant.
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`Furthermore, Petitioner cannot reasonably allege that Registrant abandoned the
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`Mark due to alleged failure to use the Mark in interstate commerce simply by merely
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`outlining the elements for these types of claims and conflating facts to make her
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`misleading claims seemingly plausible. The specious allegations that Petitioner
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`alleges in her petition to cancel the Mark do not come anywhere close to meeting
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`this standard, and therefore this cancellation proceeding should be dismissed in its
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`entirety, with prejudice.
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`The Petition for Cancellation not only lacks standing, but is both factually and
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`legally deficient, and as such, warrants dismissal pursuant to Rule 12(b)(6) of the
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`Federal Rules of Civil Procedure.
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`5
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`STANDING
`LACKS
`B. PETITIONER
`CANCELLATION PROCEEDING.
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`TO
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`BRING
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`THIS
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`Petitioner has the burden of establishing that she has standing to bring this
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`cancellation proceeding, and she has not satisfied this burden. Petitioner lacks
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`standing to maintain the cancellation proceeding because her interest in cancelling
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`the DIVA LAWYERS mark is not reasonable nor does Petitioner have any real
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`interest in this proceeding. At the pleading state, Petitioner must “allege facts
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`sufficient to show a ‘real interest’ in the proceeding and a ‘reasonable basis’ for [her]
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`belief that [she] would suffer some kind of damage if the mark is registered.” TBMP
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`§ 309.03(b); see also Stewart v. Warner Bros. Entertainment Inc., Cancellation No.
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`92058387, 2015 TTAB LEXIS 327, at *5-6 (T.T.A.B. Feb. 5, 2015) (citing Ritchie
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`v. Simpson, 170 F.3d 1092, 1098 (Fed. Cir. 1999). To plead a “real interest,”
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`Petitioner must allege a “direct and personal stake” in the outcome of the proceeding.
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`Ritchie v. Simpson, 50 U.S.P.Q.2d 1023, 1026 (Fed. Cir. 1999). Furthermore, any
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`generalized reference to “common law rights” is insufficient to satisfy Petitioner’s
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`burden of pleading particularized facts as to how such person will personally suffer
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`damages as a result of the registration. See Nh Beach Pizza, LLC v. Cristy’s Pizza,
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`Inc., Cancellation No. 92058955, 2015 WL 7772759, at *3 (T.T.A.B. Nov. 20,
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`2015). Indeed, the standing requirement is intended to prevent a generalized action
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`by a “mere intermeddler.” Id. As such, the allegations in support of petitioner’s belief
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`of damage must have a “reasonable basis in fact.” Id. at 1027 (explaining that more
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`than a “subjective belief” is required) (citation omitted).
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`In her attempt to establish standing, Petitioner alleges that she is the owner of
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`an [intent-to use] Application Serial No. 87/939,686 for the mark “Diva Attorney
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`Lonita K. Baker.” Petition for Cancellation, ¶ 3. Petitioner has not stated any facts
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`alleging that she has ever used this mark for the purposes stated in her application
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`nor does she state any facts detailing how the registered mark DIVA LAWYERS
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`causes her any harm. Moreover, Petitioner states that “[t]he continued existence of
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`Registration No. 5,769,971, in connection with the collective mark identified in
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`Respondent’s registration, damages Petitioner, as the registration confers upon
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`Respondent various statutory presumptions to which it is not entitled.” This
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`conclusory allegation states no facts to show how Petitioner has been or will be
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`harmed by the registered mark.
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`This basic statement that Petitioner is the owner of an application for a mark
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`does not demonstrate that Petitioner has any real interest in this proceeding or that
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`she will suffer any damage. In fact, there is nothing to indicate that Petitioner has a
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`reasonable belief that she is being or will be damaged by Registrant’s registration.
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`Petitioner has not alleged any ownership in any similar registered mark, and
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`has not alleged any other interest that could possibly be affected by this cancellation
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`proceeding. Petitioner never alleges how and why she is possibly harmed by the
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`Mark DIVA LAWYERS. The conclusory statement that Petitioner “believes that she
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`is and will continue to be damaged by the registration of the mark DIVA
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`LAWYERS” fails to meet the pleading requirements of Federal Rule 8 because it
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`completely lacks any facts showing how Petitioner is or would be harmed by the
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`Mark. Given the lack of allegations regarding any real interest or possible harm, this
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`cancellation proceeding should be dismissed due to Petitioner’s lack of standing.
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`C. PETITIONER FAILS TO STATE ANY LEGALLY PERMISSIBLE
`GROUND FOR CANCELLATION
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`Even if the Board somehow determines that Petitioner had standing to bring
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`this cancellation proceeding, Petitioner fails to establish a valid and meritorious
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`claim for abandonment due to allegations that Registrant has never used the mark
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`DIVA LAWYERS in interstate commerce. Section 45 of the Lanham Act provides
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`that a mark will be deemed “abandoned” if (i) the mark is not being used in
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`commerce for three consecutive years, and (ii) the owner does not intend to resume
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`use of the mark. See 15 U.S.C. § 1127; see also Exec. Coach Builders, Inc. v. SPV
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`Coach Co., 123 U.S.P.Q.2d 1175, 1180 (T.T.A.B. 2017). “Because registrations are
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`7
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`presumed valid under……..Section 7…..the party seeking cancellation based on
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`abandonment bears the burden of proving a prima facie case by a preponderance of
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`the evidence.” AD5, Inc. v. Jennifer M. Estes DBA #SELFiE T’s, Cancellation No.
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`92064555, slip op. at 5 (T.T.A.B. June 4, 2018).
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`1. The Petitioner Fails to State Facts Sufficient to Allege that Members
`of the Registrant Never Used the Collective Membership Mark
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`Registrant is the owner of the registered Mark which is a collective
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`membership mark. A collective membership mark is a mark adopted to indicate
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`membership in a collective group. It is not used to identify and distinguish the source
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`or origin of goods or services. See United States v. Nation, 370 F. Supp. 3d 1090,
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`1096 (C.D. CA 2019). Its sole function is to indicate that the person displaying the
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`mark is a member of an organized collective group. Id; see also U.S. PATENT &
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`TRADEMARK OFFICE, TMEP § 1302 (8th ed. 2017); TMEP § 1304.08(d). “Under
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`the Trademark Act, a collective mark must be owned by a collective entity even
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`though the mark is used by the members of the collective.” TMEP § 1302. “There
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`are basically two types of collective marks: (1) collective trademarks or collective
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`service marks; and (2) collective membership marks.” Id. “A collective membership
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`mark is a mark adopted for the purpose of indicating membership in an organized
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`collective group, such as a union, an association, or other organization. Neither the
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`collective nor its members uses the collective membership mark to identify and
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`distinguish goods or services; rather, the sole function of such mark is to indicate
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`that the person displaying the mark is a member of the organized collective group.”
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`Aloe Creme Laboratories, Inc. v. American Society for Aesthetic Plastic Surgery,
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`Inc., 192 USPQ 170, 173 (TTAB 1976).
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`The Mark “DIVA LAWYERS” is a mark used by initiated members to
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`indicate their membership in the DIVA LAWYERS SOCIAL CLUB, INC, a social
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`club of select female attorneys, similar to a sorority or fraternity. Members of the
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`social club use the Mark to indicate that they are an initiated member of the
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`organization.
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`The owner of a collective membership mark exercises control over the use of
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`the mark but does not itself use the mark to indicate membership. A specimen of use
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`of a collective membership mark must show use by members to indicate membership
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`in the collective organization. 37 C.F.R. 2.56(b)(4); In re International Association
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`for Enterostomal Therapy, Inc., 218 USPQ 343 (TTAB 1983); In re Triangle Club
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`of Princeton University, 138 USPQ 332 (TTAB 1963); see also TMEP § 1304.03.
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`The most common type of specimen is a membership card. Membership certificates
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`are also appropriate. TMEP § 1304.08(e).
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`Petitioner’s Petition fails to state facts sufficient to show that the members of
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`the collective never used the Mark to indicate membership in THE DIVA
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`LAWYERS SOCIAL CLUB. In fact, Petitioner cannot show facts to establish that
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`Registrant never used the mark in interstate commerce because the owner of
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`collective membership mark is not required to use the mark in interstate commerce.
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`In fact, as discussed above, it is prohibited from doing so. As such, the Petition fails
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`and should be dismissed.
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`2. Petitioner Fails to State Any Facts Sufficient to Support the Petition
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`Even if the TTAB evaluates the Petition from a failure to use in interstate
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`commerce standpoint that is applicable to regular trademarks and/or services marks
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`and is not applicable to the collective membership mark, Petitioner still fails to
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`produce any facts to support her Petition for Cancellation.
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`In the Petition, Petitioner merely refers to documents she claims she did not
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`receive during the discovery process of the related Opposition proceedings
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`(Opposition No. 91268921) to make incorrect conclusions that Registrant never used
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`the Mark in commerce, which is contrary to the fact that the Mark was properly
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`registered on June 4, 2019 and has been used by its members to identify their
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`membership in the social club since at least May 1, 2018. Petitioner further alleges
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`that Registrant did not provide any documents showing use in any way with its filed
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`Notice of Reliance in the Opposition proceedings. However, those proceedings are
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`still in the trial phase and Registrant still has until November 20, 2022 to provide
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`additional documents in rebuttal to Petitioner’s claims in that proceeding. See
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`Opposition Docket No. 10. Moreover, whether Registrant used its mark in interstate
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`commerce is irrelevant to the matters at issue in the Opposition proceeding.
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`Additionally, these allegations do not include facts to show that Registrant has
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`not properly used its mark. Petitioner makes no reference to what discovery was
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`requested, what discovery was provided and how that produced discovery (or lack
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`thereof) failed to show that Registrant’s members never used this collective
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`membership mark to indicate their membership in the social club. Petitioner states
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`no facts showing how any documents submitted as part of Registrant’s initial Notice
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`of Reliance package failed to show that Registrant’s members have not ever used
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`the Mark to indicate their membership in the organization.
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`Moreover, Petitioner fails to allege that Registrant has any intent to abandon
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`the mark, which is required to allege abandonment. See Rivard v. Linville, 45
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`U.S.P.Q.2d (BNA) 1374, 1376 (Fed. Cir. 1998) (“Trademark law provides for
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`cancelling a registration ‘at any
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`time
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`if
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`the register mark….has been
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`abandoned,’……….and defines abandonment as discontinued use with an intent not
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`to resume…….”) (internal citation omitted). The fact that Registrant has filed
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`Opposition proceedings against Petitioner’s intent-to-use mark application clearly
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`shows that Registrant’s members intend to continuously use the registered Mark to
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`indicate their membership in THE DIVA LAWYERS SOCIAL CLUB.
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`Simply making inaccurate and conclusory statements that purport, albeit
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`insufficiently, to satisfy the elements for abandonment or failure to use in commerce
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`do not rise to the level of “preponderance of the evidence,” and Petitioner fails to do
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`more than merely make speculatory, false, and conclusory allegations rather than
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`providing proper facts to support her abandonment claim in relation to the proper
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`use of a collective membership mark. At best, such statements are misleading and
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`contrary to the fact that Registrant acquired the mark with the intent to identify
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`members of its social club and has spent significant time, money and resources
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`opposing Petitioner’s proposed application for a mark that will likely lead to
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`confusion with Registrant’s Mark. For these reasons, the Board should dismiss
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`Petitioner’s abandonment claim in its entirety and with prejudice.
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`II. CONCLUSION
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`For the foregoing reasons, Registrant’s motion to dismiss should be granted
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`in its entirety with prejudice because Petitioner lacks standing and cannot state facts
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`sufficient to support a petition for cancellation of a collective membership mark.
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`The following e-mail address below is provided so that any order on this
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`motion may be issued electronically by the Board.
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`atyriasclark@gmail.com
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`divalawyers@gmail.com
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`Dated: October 10, 2022
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`THE LAW OFFICE OF ATYRIA S CLARK, APC
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`__/s/Atyria S. Clark______________________
`Atyria S. Clark
`400 Corporate Pointe, Suite 300
`Culver City, CA 90230
`atyriasclark@gmail.com
`Tel: 310-492-4032
`Fax: 310-496-1284
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`Attorneys for Registrant
`THE DIVA LAWYERS SOCIAL CLUB INC
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`11
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and complete copy of the foregoing MOTION TO
`DISMISS PETITION TO CANCEL PURSUANT TO FED. R. CIV. P. 12(b)(1) and
`12(b)(6) was electronically filed with the TTAB using the ESTTA system, and was
`served by forwarding a copy via e-mail on October 10, 2022 and served via regular
`mail.
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`Petitioner Lonita K. Baker
`c/o Andrea Evans, Esq.
`THE LAW FIRM OF ANDREA HENCE EVANS, LLC
`14625 Baltimore Avenue, Suite 853
`Laurel, MD 20707
`Andrea.evans@evansiplaw.com
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`/s/Atyria S. Clark______________
`Atyria S. Clark
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`12
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