Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
`
`ESTTA Tracking number:
`
`ESTTA1296621
`
`Filing date:
`
`07/11/2023
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding no.
`
`92081622
`
`Party
`
`Correspondence
`address
`
`Submission
`
`Filer's name
`
`Filer's email
`
`Signature
`
`Date
`
`Attachments
`
`Plaintiff
`YG Entertainment Inc.
`
`GOVINDA M DAVIS
`DINSMORE & SHOHL LLP
`255 E FIFTH STREET SUITE 1900
`CINCINNATI, OH 45202
`UNITED STATES
`Primary email: govinda.davis@dinsmore.com
`Secondary email(s): trademarks@dinsmore.com
`513-977-8200
`
`Opposition/Response to Motion
`
`Govinda M. Davis
`
`govinda.davis@dinsmore.com, trademarks@dinsmore.com
`
`/Govinda M. Davis/
`
`07/11/2023
`
`YG Entertainment v SM Beauty - YG Entertainments Response to Motion t o Ex-
`tend and Exhibit A.pdf(688671 bytes )
`
`
`
`ESTTA Tracking number:
`
`ESTTA1296621
`
`Filing date:
`
`07/11/2023
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding no.
`
`92081622
`
`Party
`
`Correspondence
`address
`
`Submission
`
`Filer's name
`
`Filer's email
`
`Signature
`
`Date
`
`Attachments
`
`Plaintiff
`YG Entertainment Inc.
`
`GOVINDA M DAVIS
`DINSMORE & SHOHL LLP
`255 E FIFTH STREET SUITE 1900
`CINCINNATI, OH 45202
`UNITED STATES
`Primary email: govinda.davis@dinsmore.com
`Secondary email(s): trademarks@dinsmore.com
`513-977-8200
`
`Opposition/Response to Motion
`
`Govinda M. Davis
`
`govinda.davis@dinsmore.com, trademarks@dinsmore.com
`
`/Govinda M. Davis/
`
`07/11/2023
`
`YG Entertainment v SM Beauty - YG Entertainments Response to Motion t o Ex-
`tend and Exhibit A.pdf(688671 bytes )
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`YG Entertainment, Inc.,
`
`Petitioner,
`
`
`v.
`
`
`
`SM Beauty, LLC,
`
`
`
`
`)
`)
`)
`)
`)
`)
`
`
`
`)
`
`
`
`Respondent. )
`
`
`
`
`
`
`
`
`
`
`
`In the matter of:
`Registration No. 5376449
`
`For the mark: BLACKPINK
`
`Cancellation No: 92081622
`
`
`
`
`
`
`PETITIONER’S RESPONSE TO RESPONDENT’S MOTION FOR EXTENSION
`
`Petitioner YG Entertainment, Inc. (“YG Entertainment”) hereby responds to Respondent
`
`SM Beauty, LLC’s (“SM Beauty”) June 27, 2023 motion for extension (the “Motion”) (see
`
`TTABVUE Doc. No. 11). In principle, YG Entertainment does not object to a reasonable extension
`
`of time for SM Beauty to substantively respond to YG Entertainment’s written discovery requests,
`
`served June 1, 2023 (“YG Entertainment’s Written Discovery Requests”).1 As outlined in further
`
`detail below, however, YG Entertainment submits this response to bring certain facts to the Board’s
`
`attention, including, in light of the correspondence between counsel for the parties, SM Beauty’s
`
`actions to this point make it likely that SM Beauty’s forthcoming responses to YG Entertainment’s
`
`Written Discovery Requests will unnecessarily complicate the discovery process in this matter and
`
`potentially require additional discovery motion practice. Further, YG Entertainment requests that
`
`the Board confirm that SM Beauty’s additional discovery obligations are not suspended.
`
`
`1 YG Entertainment’s Written Discovery Requests hereinafter refer only to the interrogatories and requests for
`production that YG Entertainment served upon SM Beauty on June 1, 2023. Even though the Motion refers to
`“request[s] for admission,” SM Beauty has since responded to the Requests for Admission; therefore the Motion is
`moot with respect to these particular requests.
`
`
`
`1
`
`
`
`
`
`
`
`A.
`
`Relevant Background.
`
`SM Beauty’s Filing the Motion
`
`At the outset, SM Beauty failed to properly serve the Motion upon counsel for YG
`
`Entertainment, as is required by Trademark Rule § 2.119. See also Trademark Trial and Appeal
`
`Board Manual of Procedure (“TBMP”) §§ 113; 502.02(a). SM Beauty’s Certificate of Service
`
`incorrectly indicated that YG Entertainment’s counsel had been served with the Motion via email
`
`on June 27, 2023. (TTABVUE Doc. No. 11 at 3.) YG Entertainment presumes this to have been
`
`a clerical error; however, the fact remains that the Motion was never properly served.
`
`
`
`In addition, YG Entertainment notes that, on June 26, 2023 at 10:24 a.m. EDT, counsel for
`
`SM Beauty did, in fact, email counsel for YG Entertainment requesting the three-week extension
`
`of time sought in the Motion. As YG Entertainment considered the multiple issues raised in this
`
`Opposition and was in the process of committing those concerns to writing to respond to SM
`
`Beauty’s request, on June 27, 2023 at 12:42 p.m. EDT, counsel for YG Entertainment received an
`
`ESTTA Filing Receipt indicating that SM Beauty had already filed the Motion. Of note, SM
`
`Beauty’s responses to YG Entertainment’s Written Discovery Requests, all served on June 1, 2023,
`
`were not due until Monday, July 3, 2023, so it is unclear why SM Beauty rushed to file the Motion
`
`before conferring with YG Entertainment on a stipulated motion. YG Entertainment notes these
`
`facts only to rebut any implication that it improperly delayed in responding to SM Beauty’s request
`
`for consent to the extension now sought by the Motion, since the Motion was filed just over twenty-
`
`four hours after the initial request for consent. Again, subject to the multiple concerns raised in
`
`this Opposition, YG Entertainment is not opposed to any reasonable extension of time. Indeed,
`
`
`
`2
`
`
`
`YG Entertainment hopes that, if the roles were ever to be reversed, SM Beauty would consent to a
`
`reasonable request for an extension made by YG Entertainment.
`
`SM Beauty’s Motion to Compel
`
`
`
`As the Board is aware, on June 15, 2023, SM Beauty filed a motion to compel YG
`
`Entertainment to answer SM Beauty’s interrogatories and respond to SM Beauty’s document
`
`requests. (See TTABVUE Doc. Nos. 8, 9, & 10.) On July 3, 2023, YG Entertainment opposed
`
`SM Beauty’s motion to compel as frivolous and in direct contravention of the applicable law.
`
`(TTABVUE 12.) The misguided gravamen of SM Beauty’s argument in support of its motion to
`
`compel was that YG Entertainment had, when faced with interrogatories and document requests it
`
`believed to be excessive, improperly objected to the whole of SM Beauty’s requests. (See
`
`TTABVUE Doc. Nos. 8, 9, & 10.) Of course, SM Beauty is incorrect. See Trademark Rule §
`
`2.120(d) & (e); see also TTABVUE Doc. No. 12.
`
`
`
`The correspondence between counsel for the parties, exhibited with SM Beauty’s motion
`
`to compel, is particularly relevant to YG Entertainment’s concerns here in this extension to permit
`
`SM Beauty with additional time to respond to discovery. (See TTABVUE Doc. No. 10.) SM
`
`Beauty’s counsel clearly indicated that—in response to YG Entertainment’s purportedly improper
`
`general objections to SM Beauty’s discovery requests—he planned to retaliate with similar tactics
`
`(i.e., not providing substantive responses to YG Entertainment’s Written Discovery Requests).
`
`Indeed, in a June 1, 2023 letter to YG Entertainment’s counsel, SM Beauty’s counsel stated: “[w]e
`
`can parse words too, but our response is not due for a while.” (TTABVUE Doc. No. 10, at D2.)
`
`This in reference to YG Entertainment’s Written Discovery Requests for which SM Beauty now
`
`seeks an extension via the Motion. Therefore, to the extent that SM Beauty plans to use the
`
`
`
`3
`
`
`
`additional 21-day extension to carefully craft its retaliatory objections, this simply cannot be
`
`permitted by the Board or the parties will be entrenched in another motion to compel in short order.
`
`
`
`
`
`
`B.
`
`SM Beauty’s Course of Discovery-Related Conduct Warrants An Advisory by
`the Board.
`
`Although YG Entertainment does not oppose an extension in principle, given SM Beauty’s
`
`stated intent to object to YG Entertainment’s Written Discovery Requests in whole (and therefore,
`
`presumably not serve substantive responses to the same), YG Entertainment does not agree to
`
`extend SM Beauty’s time to answer for merely the to permit SM Beauty to lodge baseless
`
`objections.
`
`
`
`To date, SM Beauty’s responses to YG Entertainment’s June 1, 2023 First Set of Requests
`
`for Admission to Respondent (the “RFAs”), which SM Beauty served on June 29, 2023, do not
`
`inspire confidence as to future cooperation in discovery-related matters and do not indicate that
`
`SM Beauty will engage in the discovery process in good faith. (The RFAs and SM Beauty’s June
`
`29, 2023 responses thereto are annexed hereto as Exhibit A). An egregious example of obstinacy:
`
`SM Beauty refused to provide an answer to YG Entertainment’s Request for Admission No. 1, in
`
`part, because SM Beauty objected to the word “authentic” as being vague and ambiguous.
`
`Likewise, SM Beauty unreasonably objected—also on grounds of vagueness and ambiguity—to
`
`such common and seemingly impossible-to-misinterpret terms, including but not limited to2:
`
` “part of the business records”
` “kept in the normal course of”
` “admissible as evidence”
` “Federal Rules of Evidence”
` “trademark BLACKPINK”
`
`
`2 YG Entertainment has selected these examples as particularly egregious. There are myriad other examples of SM
`Beauty’s bad faith objections to YG Entertainment’s RFAs contained in SM Beauty’s responses thereto. See generally
`id.
`
`
`
`4
`
`
`
` “in interstate commerce”
` “indicator of source”
` “specimen of use”
`
`
`Id. Notably, these are all commonly used terms during the course of TTAB and Trademark Office
`
`practice. If these objections and non-responses are indicative of the manner in which SM Beauty
`
`plans to conduct discovery in this matter moving forward, YG Entertainment expects similarly
`
`non-responsive responses to YG Entertainment’s Written Discovery Requests. Indeed, as stated
`
`above, YG Entertainment specifically anticipates SM Beauty will serve general objections
`
`pursuant to Trademark Rule § 2.120(d) & (e)—of which SM Beauty’s counsel is now belatedly
`
`aware—as a misguided “retaliation” for YG Entertainment’s own general objections served
`
`pursuant to those subsections or, as evidenced by SM Beauty’s Responses to YG Entertainment’s
`
`First Set of Requests for Admissions, SM Beauty will find nearly every word – even commonly
`
`used terms -- objectionable.
`
`
`
`To be clear, in the event that the Motion is granted and SM Beauty is given an additional
`
`21 days to respond to discovery requests, YG Entertainment expects good-faith substantive
`
`responses to YG Entertainment’s Written Discovery Requests, not further gamesmanship or any
`
`misguided retaliation (e.g., “parsing” of words or frivolous objections to commonplace words and
`
`phrases, including elementary trademark law terms of art) by SM Beauty.
`
`Lastly, YG Entertainment notes that, on June 9, 2023, it served SM Beauty with three
`
`deposition notices for witnesses disclosed in its initial disclosures, for depositions to commence
`
`on August 9, 10, and 11 of 2023, respectively. SM Beauty has not yet confirmed its witnesses’
`
`availability. Regardless of the Board’s decision on the Motion, these depositions will move
`
`forward on the dates for which they have been noticed or on other dates as the parties agree.
`
`
`
`5
`
`
`
`CONCLUSION
`
`
`
`YG Entertainment responds to the Motion because, in light of SM Beauty’s course of
`
`conduct to this point, it expects to receive frivolous objections to YG Entertainment’s Written
`
`Discovery Requests and requests that the Board issue an advisory or order to SM Beauty that it is
`
`expected to cooperate in the discovery process and provide good-faith responses to YG
`
`Entertainment’s properly propounded requests. Subject to the concerns raised herein, YG
`
`Entertainment has no additional objection to the relief requested in the Motion.
`
`
`
`Date: July 11, 2023
`
`
`
`
`
`
`
`Respectfully submitted,
`
`DINSMORE & SHOHL LLP
`
`By: /Govinda M. Davis/
`Govinda M. Davis
`Dinsmore & Shohl LLP
`255 E. Fifth Street
`Suite 1900
`Cincinnati, OH 45202
`Tel: (513) 977-8200
`Fax: (513) 977-8141
`govinda.davis@dinsmore.com
`Counsel for YG Entertainment, Inc.
`
`
`
`
`
`6
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing PETITIONER’S
`
`RESPONSE TO RESPONDENT’S MOTION FOR EXTENSION has been served upon the
`
`following by e-mail this 11th day of July 2023:
`
`
`
`Sang Lee
`Law Offices Of Sang Lee
`505 E Golf Rd Ste H
`Arlington Heights, IL 60005
`slee000@aol.com, softbeeus@gmail.com, jlee@leebreenlaw.com, mlee@leebreenlaw.com
`
`John Y. Lee
`Lee & Breen LLC
`188 Industrial Drive,
`Suite 403 Elmhurst, IL 60126
`jlee@leebreenlaw.com
`
`
`
`
`___/Govinda M. Davis/______________
`
`
`
`
`
`7
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`EXHIBIT A
`EXHIBIT A
`
`
`
`
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`
`
`Cancellation No. 92081622
`
`Mark: BLACKPINK
`
`Reg. No.5376449
`
`
`
`
`
`
`YG ENTERTAINMENT INC.,
`
` Petitioner,
`
` vs.
`
` SM BEAUTY, LLC,
`
` Respondent.
`
`
`RESPONDENT’S RESPONSE TO PETITIONER’S FIRST REQUEST FOR ADMISSION
`
`
`Respondent, SM Beauty, LLC, by its counsel, to Petitioner’s First Set of Request for
`
`Admission to Respondent as follows:
`
`Respondent’s General Objections and Reservation of Rights
`
` Nothing in Respondent’s Responses to Petitioner’s Request for Admission should
`
`be deemed a waiver of objections; or of right to amend or supplement; or of right to object to
`
`specific use of the Responses or documents or information referenced in Responses or Requests
`
`based on privilege, confidentiality, trade secrets, relevance, materiality or other grounds. Subject
`
`to these general objections and reservation of rights, Respondent responds as follows:
`
`Responses
`
`1.
`
` Admit that all documents and things produced in response to any discovery request
`
`in this proceeding are authentic pursuant to the Federal Rules of Evidence.
`
`Answer: In addition to Respondent’s General Objections and Reservation of Rights, Respondent
`
`objections to this request, as no documents or things sought to be authenticated
`
`accompanies this request. Respondent further objects based on vague and ambiguous terms
`
`
`
`1
`
`
`
`such as “all documents and things produced in response to any discovery request” or
`
`“authentic”.
`
`2.
`
` Admit that all documents and things produced in response to any discovery request
`
`in this proceeding are part of the business records of Respondent kept in the normal course of
`
`Respondent’s business.
`
`Answer: See Response to No. 1. Respondent further objects based on vague and ambiguous terms
`
`such as “part of the business records” or “kept in the normal course of “.
`
`3.
`
` Admit that all documents and things produced in response to any discovery request
`
`in this proceeding are admissible as evidence in this proceeding under the Federal Rules of
`
`Evidence, subject to any objections of Respondent on the grounds of relevance.
`
`Answer: See Response to No. 1. Respondent further objects based on vague and ambiguous terms
`
`such as “admissible as evidence” or “ Federal Rules of Evidence”.
`
`4.
`
` Admit that prior to the filing date of its U.S. Trademark Application No.
`
`87/215,031, Sang Lew did not use the trademark BLACKPINK in the United States in connection
`
`with all of the Class 003 goods listed in U.S. Trademark Application No 87/215,031.
`
`Answer: In addition to Respondent’s General Objections and Reservation of Rights, Respondent
`
`objects based on vague and ambiguous terms such as “use”, “trademark BLACKPINK”,
`
`or “in connection with all”. Without waiving these objections, admitted.
`
`5.
`
`Admit that prior to the filing date of its U.S. Trademark Application No.
`
`87/215,031, Sang Lew predecessor did not use the trademark BLACKPINK in the United States
`
`in connection with any of the Class 003 goods listed in U.S. Trademark Application No
`
` 87/215,031.
`
`
`
`2
`
`
`
`Answer: See Response to No. 4. Respondent further objects based on vague and ambiguous terms
`
`such as “Sang Lew predecessor”. Without waiving these objections, admitted.
`
`6.
`
` Admit that Respondent does not use the trademark BLACKPINK in the United
`
`States in connection with body and beauty care cosmetics.
`
`Answer: Denied.
`
`7.
`
` Admit that Sang Lew did not provide goods in Class 003 under the mark depicted
`
`in U.S. Registration No. 5,376,449 in interstate commerce on February 20, 2017.
`
`Answer: In addition to Respondent’s General Objections and Reservation of Rights, Respondent
`
`objects based on vague and ambiguous terms such as “provide goods” or “under the mark”,
`
`and Respondent cannot determine what happened on February 20, 2017. Without waiving
`
`these objections, admitted.
`
`8.
`
` Admit that Respondent did not provide goods in Class 003 under the mark depicted
`
`in U.S. Registration No. 5,376,449 in interstate commerce on February 20, 2017.
`
`Answer: See Response to No. 7.
`
`9.
`
` Admit that Sang Lew did not provide goods in Class 003 under the mark depicted
`
`in U.S. Registration No. 5,376,449 in interstate commerce on October 1, 2017.
`
`Answer: In addition to Respondent’s General Objection and Reservation of Rights, Respondent
`
`objects based on vague and ambiguous terms such as “provide goods”, “under the mark”,
`
`or “in interstate commerce”, and Respondent cannot determine what precisely happened
`
`on October 1, 2017. Without waving these objections, denied.
`
`10.
`
` Admit that Respondent did not provide goods in Class 003 under the mark depicted
`
`in U.S. Registration No. 5,376,449 in interstate commerce on October 1, 2017.
`
`Answer: See Response to No. 9.
`
`
`
`3
`
`
`
`11.
`
` Admit that Respondent has not provided goods in Class 003 under the mark
`
`depicted in U.S. Registration No. 5,376,449 continuously in interstate commerce since October 1,
`
`2017.
`
`Answer: See Response to No. 9.
`
`12.
`
` Respondent’s Mark is not used by Respondent as an indicator of source.
`
`Answer: In addition to Respondent’s General Objections and Reservation of Rights, Respondent
`
`objects based on vague and ambiguous terms such as “used” or “indicator of
`
`source”. Without waiving these objections, denied.
`
`13.
`
` Petitioner has no documents which evidence Petitioner’s sales of products under
`
`the trademark BLACKPINK in the United States dating back to October 1, 2017.
`
`Answer: Respondent does not know what Petitioner has or does not have or what Petitioner did
`
`dating back to October 1, 2017.
`
`14.
`
` Admit that Respondent has evidence of mistake as to the source, sponsorship,
`
`association, or approval of Respondent’s Good’s and Petitioner’s Goods and Services.
`
`Answer: In addition to Respondent’s General Objections and Reservation of Rights, Respondent
`
`Objections based on vague and ambiguous terms such as “evidence of mistake”, “source”,
`
`“sponsorship”, “association”, “approved”, “Petitioner’s Goods and services”. Without
`
`waiving these objections, denied.
`
`15.
`
`Admit that Petitioner is the prior user of the mark BLACKPINK in the United
`
`States.
`
`Answer: Denied.
`
`16.
`
` Admit that Sang Lew was aware of the musical group named “Blackpink” when
`
`choosing Respondent’s Mark.
`
`
`
`4
`
`
`
`Answer: Denied.
`
`17.
`
`Admit that Sang Lew was aware of the musical group named “Blackpink” when
`
`adopting Respondent’s Mark.
`
`Answer: Denied
`
`18.
`
`Admit that Respondent was aware of the musical group named “Blackpink” when
`
`adopting Respondent’s Mark.
`
`Answer: Denied.
`
`19.
`
` Admit that Respondent was aware of the musical group named “Blackpink” when
`
`using Respondent’s Mark.
`
`Answer: Denied.
`
`20.
`
` Admit that Sang Lew had no business operations on February 20, 2017.
`
`Answer: Denied.
`
`21.
`
` Admit that U.S. Trademark Application Serial No. 87/215,031 was purportedly
`
`assigned from Sang Lew to Respondent an agreement dated February 20, 2017.
`
`Answer: Admitted
`
`22.
`
`Admit that no goodwill was assigned in the transfer of U.S. Trademark Application
`
`Serial No. 87/215,031 from Sang Lew to Respondent.
`
`Answer: In addition to Respondent’s General Objections and Reservation of Rights, Respondent
`
`objects based on vague and ambiguous terms such as “goodwill”, “assigned”, or “transfer”.
`
`Without waving these objections, denied.
`
`23.
`
` Admit that the specimen of use submitted to the USPTO on November 3, 2017 for
`
`U.S. Trademark Application Serial No. 87/215,031 was a digital advertisement.
`
`
`
`5
`
`
`
`Answer: In addition to Respondent’s General Objections and Reservation of Rights, Respondent
`
`objected based on vague and ambiguous terms such as “specimen of use” or “digital
`
`advertisement”. Without waving these objections, Respondent admits that submissions to
`
`USPTO were digital, but denies that Respondent’s marketing, advertisement, sale and use
`
`of its trademark was only digital, as the trademark was used both digitally and non-
`
`digitally.
`
`24.
`
`Admit that products sold under Respondent’s Mark originate in Korea.
`
`Answer: In addition to Respondent’s General Objections and Reservation of Rights, Respondent
`
`objects based on vague and ambiguous terms such as “products”, “sold under” or
`
`“originate”. Without waiving these objections, Respondent partially admits in that one
`
`product called eyelash glue comes from Korea, although Respondent does not know from
`
`where it originates. As to all other products or parts of products, denied, as far as
`
`Respondent knows.
`
`25.
`
`Admit that Respondent knew of Petitioner prior to filing of its statement of use for
`
`the trademark application that matured into U.S. Trademark Registration No. 5,376,449 for the
`
`mark “BLACKPINK.”
`
`Answer: Denied.
`
`26.
`
`Admit that Respondent knew of the K-pop group “Blackpink” prior to filing its
`
`statement of use for the trademark application that matured into U.S. Trademark Registration No.
`
`5376449 for the mark “BLACKPINK.”
`
`Answer: Denied.
`
`27.
`
`Admit that when filing the trademark application that matured into U.S. Trademark
`
`Registration No. 5,376,449 for the mark “BLACKPINK,” Sang Lew intended to falsely suggest a
`
`
`
`6
`
`
`
`connection with the musical group “Blackpink”.
`
`Answer: Denied.
`
`28.
`
`Admit that when filing the statement of use for the trademark application that
`
`matured into U.S. Trademark Registration No. 5,376,449 for the mark “BLACKPINK,”
`
`Respondent intended to falsely suggest a connection with the musical group “Blackpink.”
`
`Answer: Denied.
`
`29.
`
` Admit that when filing the statement of use for the trademark application that
`
`matured into U.S. Trademark Registration No. 5,376,449 for the mark “BLACKPINK,” Sang Lew
`
`intended to trade in on the goodwill and reputation of the K-pop group “Blackpink.”
`
`Answer: Denied.
`
`30.
`
` Admit that in actively maintaining the U.S. Trademark Registration No. 5,376,449
`
`for the mark “BLACKPINK,” Respondent intends to trade in on the goodwill of the K-pop group
`
`“Blackpink”.
`
`Answer: Denied.
`
`31.
`
` Admit that in actively maintaining the U.S. Trademark Registration No. 5,376,449
`
`or the mark “BLACKPINK,” Respondent intends to trade in on the reputation of the K-pop group
`
`Blackpink”.
`
`Answer: Denied.
`
`32.
`
` Admit that “Sistar” is a well-known musical group in Korea.
`
`Answer: Denied.
`
`
`
`
`
`
`
`
`
`7
`
`
`
`SM Beauty, LLC
`
`
`By: /s/John Y. Lee
`One of the Attorneys for Plaintiff
`
`
`
`
`John Y. Lee
`Attorney for Registrant
`jlee@leebreenlaw.com
`Lee & Breen LLC
`188 Industrial Drive, Suite 403
`Elmhurst, IL 60126
`Tel.: (312) 241-1420
`
`Sang Lee
`USPTO Reg. No. 67,541
`Attorney for Registrant
`Email: 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
`
`
`
`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies that a copy of the foregoing Respondent’s Response to
`
`Petitioner’s First Request for Admission was served on the following via email, on June 29,
`
`2023, as follow:
`
`
`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.
`
`/s/ John Y. Lee
`
`
`
`
`
`
`
`8
`
`
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
