Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
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`ESTTA Tracking number:
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`ESTTA1293830
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`Filing date:
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`06/27/2023
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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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`92081622
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`Party
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`Correspondence
`address
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`Defendant
`SM Beauty, LLC
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`SANG LEE
`LAW OFFICES OF SANG LEE
`505 E GOLF RD STE H
`ARLINGTON HEIGHTS, IL 60005
`UNITED STATES
`Primary email: slee000@aol.com
`Secondary email(s): softbeeus@gmail.com, jlee@leebreenlaw.com,
`mlee@leebreenlaw.com
`847-208-8617
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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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`Motion to Extend
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`John Y. Lee
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`jlee@leebreenlaw.com
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`/s/ John Y. Lee
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`06/27/2023
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`Attachments
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`Respondent Motion for Extension.pdf(133573 bytes )
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`YG ENTERTAINMENT INC.,
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` Petitioner,
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` vs.
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` SM BEAUTY, LLC,
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` Respondent.
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`Cancellation No. 92081622
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`Mark: BLACKPINK
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`Reg. No.5376449
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`RESPONDENT’S MOTION FOR EXTENSION
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` Respondent, SM Beauty, LLC, by its counsel Lee & Breen, moves this Court for
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`an extension to respond to Petitioner’s first sets of interrogatories, document requests and request
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`for admissions (hereafter “First Written Discovery”), and in support of this motion states as
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`follows:
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`1. Petitioner serves its First Written Discovery on June 1, 2023.
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`2. There are significant amounts of documents and information being gathered while
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`Respondents’ counsel and employees are juggling their summer schedules.
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`3. Respondent needs more time to respond to Petitioner’s First Written Discovery which
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`will allow it to complete its searches.
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`4. Such an extension would not prejudice Petitioner in any way; Petitioner has not
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`answered a single interrogatory or produced a single document in any event; (and
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`Respondent’s first sets of written discovery were served on Petitioner on April 29,
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`2023 and its Motion to Compel against Petitioner is pending).
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`5. Respondent has requested Petitioner to agree to this motion, but has not received any
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`response.
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`WHERFORE, Respondent respectfully requests that TTAB grant it an extension of 21
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`days to respond to Petitioner’s first sets of interrogatories, document requests and request for
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`admissions.
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`Dated: June 27, 2023
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` Respectfully submitted,
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` By: /s/John Y. Lee
` One of the Attorneys for Respondent SM Beauty
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`John Y. Lee
`Attorney for Registrant
`jlee@leebreenlaw.com
`Lee & Breen LLC
`188 Industrial Drive, Suite 403
`Elmhurst, IL 60126
`Tel.: (312) 241-1420
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`Sang Lee
`USPTO Reg. No. 67,541
`Attorney for Registrant
`slee000@aol.com,
` softbeeus@gmail.com
`Law Offices of Sang Lee
`505 E Golf Road, Suite H
`Arlington Heights, IL 60005
`Tel: 1-847-208-8617
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing Respondent’s Motion for
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`Extension was served on the following via email, on June 27, 2023, as follow:
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`Govinda M. Davis, Esq.
`Dinsmore & Shohl, LLP
`255 East Fifth Street, Suite 1900
`Cincinnati, OH 45202
`Telephone: (513) 977-8200
`Facsimile: (513) 977-8141
`govinda.davis@dinsmore.com
`Attorneys for Petitioner YG Entertainment Inc.
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`/s/ John Y. Lee
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