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`ESTTA Tracking number:
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`ESTTA1233858
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`Filing date:
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`09/06/2022
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Petition for Cancellation
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`Notice is hereby given that the following party has filed a petition to cancel the registration indicated below.
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`Petitioner information
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`Name
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`Entity
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`Address
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`Correspondence
`information
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`Robert J. Warren
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`Individual
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`703 N. MAIN ST.
`SUITE C
`GAINESVILLE, FL 32601
`UNITED STATES
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`Citizenship
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`UNITED STATES
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`JEREMY PETER GREEN ECHE
`JPG LEGAL
`163 23RD ST
`GROUND FLOOR
`BROOKLYN, NY 11232
`UNITED STATES
`Primary email: docket@jpglegal.com
`Secondary email(s): doglifebrand@gmail.com
`9172687054
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`Registration subject to cancellation
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`Registration no.
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`5413367
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`Registration date
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`02/27/2018
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`Register
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`International re-
`gistration no.
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`Registrant
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`Principal
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`NONE
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`Northern Feather Canada Ltd.
`8088 RIVER WAY
`DELTA, V4G1K9
`CANADA
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`International re-
`gistration date
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`NONE
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`Goods/services subject to cancellation
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`Class 020. First Use: Nov 30, 2016 First Use In Commerce: Nov 30, 2016
`All goods and services in the class are subject to cancellation, namely: Dog beds
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`Grounds for cancellation
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`Abandonment
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`Trademark Act Section 14(3)
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`Attachments
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`Dog Life Petition for Cancellation.pdf(51823 bytes )
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`Signature
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`/JPG/
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`
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`Name
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`Date
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`Jeremy Peter Green Eche
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`09/06/2022
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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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`Robert J. Warren
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`Petitioner,
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`v.
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`Northern Feather Canada Ltd.
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`Registrant.
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`Cancellation No.:
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`Mark: DOG LIFE
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`Reg. No. 5413367
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`PETITION FOR CANCELLATION
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`Robert J. Warren, an individual United States citizen, with an address at 703 N.
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`Main St., Suite C, Gainesville, FL 32601 (“Petitioner”), believes he will be damaged by
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`the continued registration of the mark DOG LIFE (“the Mark”) in connection with dog
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`beds in International Class 020, as identified in U.S. Trademark Reg No. 5413367 (“the
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`Registration”), and hereby petitions to cancel it.
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`1. As grounds for its Petition, Petitioner alleges that, upon actual knowledge with
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`respect to itself and its own actions, and upon information and belief as to other
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`matters:
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`2. Petitioner has been using the Mark in connection with various goods for
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`several years dating at least as far back as June 1, 2018.
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`3. Petitioner owns trademark reg. no. 5697974 for design with the wording DOG
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`LIFE, registered in connection with decorative decals for vehicle windows and graphic
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`t-shirts in International Classes 016 and 025 respectively.
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`4. Petitioner has a pending trademark application with the USPTO for the word
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`mark DOG LIFE for retail store services and online retail store services for various
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`goods in International Class 035.
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`5. Petitioner owns a domain name containing wording that is similar to
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`Registrant’s Mark and uses it in connection with goods and services that relate to the
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`goods claimed by Registrant on the Registration.
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`6. Petitioner has been harmed, and continues to be harmed, by the Registration
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`because of the doubt its existence causes in relation to the future of Petitioner’s
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`business.
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`COUNT ONE: Abandonment
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`7. Petitioner repeats and re-alleges each and every allegation set forth in the
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`foregoing paragraphs as though fully set forth herein.
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`8. Upon information and belief, if Registrant ever used the Mark in commerce,
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`Registrant has abandoned the Mark pursuant to Section 14(3) of the Trademark Act,
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`15 U.S.C. § 1064(3).
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`9. Upon information and belief, Registrant is not currently using the Mark as
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`indicated in the Registration in connection with Class 020.
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`10. Upon information and belief, even if it has been less than three years since
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`Registrant last used the Mark, Registrant has discontinued use of the Mark with
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`intent not to resume such use, constituting abandonment in accordance with Section
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`14(3).
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`WHEREFORE, Petitioner believes that it will be damaged by continued
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`registration of the Mark and respectfully requests that the Petition be sustained and that
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`registration of Registrant’s Mark be cancelled.
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`September 6, 2022
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`Respectfully Submitted,
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`/Jeremy Peter Green Eche/
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`JPG Legal
`163 23rd St, Ground Floor
`Brooklyn, NY 11232
`Phone: (917) 268-7054
`Email: docket@jpglegal.com
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`Attorney for Petitioner
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