ESTTA Tracking number:
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`ESTTA1342007
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`Filing date:
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`02/22/2024
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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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`92081334
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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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`Plaintiff
`Edge Games, Inc.
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`TIM LANGDELL
`EDGE GAMES INC
`35 NORTH LAKE AVENUE
`SUITE 710
`PASADENA, CA 91101
`UNITED STATES
`Primary email: edgegames@gmail.com
`626-824-0097
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`Opposition/Response to Motion
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`Tim Langdell
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`edgegames@gmail.com
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`/Tim Langdell/
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`02/22/2024
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`Attachments
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`Response to Motion to Extend Time.pdf(392599 bytes )
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Cancellation No. 92081334
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`In the Matter of Registration No. 5,766,386
`For the Trademark BLEEDING EDGE
`Issued June 4, 2019
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`EDGE GAMES, INC.
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`Petitioner,
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`MICROSOFT CORPORATION
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`Registrant
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`__________________________________________)
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`Trademark Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1451
`Alexandria, Virginia 22313-1451
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`PETITIONER’S RESPONSE TO MOTION FOR EXTENSION
`OF TIME TO RESPOND TO WRITTEN DISCOVERY
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`Petitioner EDGE Games Inc. (“EDGE”) in pro se responds to Respondent’s motion for
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`extension of time as follows.
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`Petitioner has given consent to a 30-day extension of time and thus the motion is moot
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`(see Exhibit A). This motion should thus have been withdrawn by Respondent.
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`CORRECTING THE RECORD
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`That said, Petitioner must take this opportunity to correct the record on the false
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`statements made by Respondent in its motion. It is utterly preposterous for Respondent to state,
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`as it does, that Petitioner has a misguided notion of exclusive rights to the term “Edge” for
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`everything or anything, including foods and services it does not offer. This is quite absurd, since
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`Petitioner has never stated any such notion. Rather, Petitioner has firmly established exclusive
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`rights to the mark “Edge” for specific goods and services in U.S. commerce and has only ever
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`claimed such rights for the goods and services it sells or its licensees sell. Central to Petitioner’s
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`rights is the right not only to the mark “Edge” but to a family of Edge formative marks for
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`computer game software. And that is precisely the sole use to which Respondent puts the term
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`“Bleeding Edge,” for computer game software, in clear infringement of Petitioner’s 40-year-old
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`rights, and clearly passing off on Petitioner’s well-established goodwill in its Edge marks.
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`Respondent asked for two courtesy extensions of time last year, which Petitioner
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`promptly agreed to, also based on the same – now rather tired – excuse that Petitioner is such as
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`large company that their attorney cannot work out who to talk to in order to get the necessary
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`information required to litigate these proceedings. Respondent has now have some months in
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`which to determine who at Microsoft the attorney needs to speak with, and who at Ninja Theory
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`has information, so that there should have been no need for any extension to respond to these
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`written discovery requests.
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`Petitioner trusts this is the last time that Respondent trots out this tired excuse that it’s
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`attorney cannot work out who to speak to at the companies it represents and that before the next
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`deadline in this case Petitioner’s attorney will have worked out that simple problem and never
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`have to need to ask for another extension again.
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`Dated February 22, 2024
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`Respectfully submitted,
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`By: ____________________
`Dr. Tim Langdell, CEO
`Petitioner in pro se.
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`EDGE Games, Inc.
`530 South Lake Avenue 171
`Pasadena, CA 91101
`edgegames@gmail.com
`626 824 0097
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`CERTIFICATE OF SERVICE
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`I hereby certify that pursuant to CFR 2.101(b), on February 22, 2024 a true and correct copy of
`the foregoing PETITIONER’S RESPONSE TO MOTION FOR EXTENSION OF TIME TO
`RESPOND TO WRITTEN DISCOVERY served via email on Respondent’s counsel:
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`trademarkslv@dickinsonwright.com, jkrieger@dickinsonwright.com,
`cvillanueva@dickinsonwright.com
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`/Tim Langdell/____________
`Dr. Tim Langdell
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`EXHIBIT A
`EXHIBIT A
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`EDGE Games <edgegames@gmail.com>
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`Re: Microsoft Corporation adv. EDGE Games, Inc. / Cancellation No. 92081334 -
`Respondent's Motion to Extend Time to Respond to Written Discovery
`Tim@Edge <edgegames@gmail.com>
`To: "Ashley B. Moretto" <AMoretto@dickinson-wright.com>
`Cc: "John L. Krieger (he/him/his)" <JKrieger@dickinson-wright.com>, "Cindy A. Villanueva" <CVillanueva@dickinson-wright.com>,
`Clientdocket <Clientdocket@dickinson-wright.com>, EDGE Games <edgegames@gmail.com>
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`Thu, Feb 22, 2024 at 12:54 PM
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`Dear John
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`We consent to the requested 30-day extension. Please withdraw the motion as it is now moot.
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`Thank you,
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`Sincerely
`Dr Tim Langdell CEO
`EDGE Games Inc.
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`On Thu, Feb 22, 2024 at 9:18 AM Ashley B. Moretto <AMoretto@dickinson-wright.com> wrote:
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`Good Morning,
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` I
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` have attached Respondent Microsoft Corporation’s Motion to Extend Time To Respond To Written Discovery in the above
`referenced matter.
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`Kind regards,
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`Ashley
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`Ashley B. Moretto Legal Assistant
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`3883 Howard Hughes Parkway
`Suite 800
`Las Vegas NV 89169
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`Phone 702-550-4464
`Fax
`844-670-6009
`Email AMoretto@dickinsonwright.com
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