ESTTA Tracking number:
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`ESTTA1339095
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`Filing date:
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`02/08/2024
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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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`92081622
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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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`Attachments
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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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`Other Motions/Submissions
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`JOHN Y LEE
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`mlee@leebreenlaw.com
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`/s/ John Y. Lee
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`02/08/2024
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`Motion for Leave to File Response in Opposition to Petitioner Motion to Compel
`and Respondent Counter Motion to Compel.pdf(99380 bytes )
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`
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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 LEAVE TO FILE
`RESPONSE IN OPPOSITION TO PETITIONER’S MOTION TO COMPEL AND
`RESPONDENT’S COUNTER-MOTION TO COMPEL
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` Respondent SM Beauty, by its counsel, respectfully moves the Board for leave to file a
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`response in opposition to Petitioner’s motion to compel as well as Respondent’s counter-motion
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`to compel within 14 days. In support of this motion, Respondent states as follows:
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` On February 6, 2024, counsel for both parties held a meet and confer. On February 7,
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`2024, Respondent’s counsel sent to Petitioner’s counsel a confirming meet and confer letter. On
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`February 7, 2024, Petitioner also filed a motion to compel. Lead counsel for respondent has a
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`daunting number of depositions in a large arbitration and a Title VII action in the next ten
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`days. After that, Respondent will be able to file a response in opposition to Petitioner’s motion
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`to compel as well as Respondent’s own motion
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`to compel (second one
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`in
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`this
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`proceeding). Granting Respondent leave to file those will not prejudice Petitioner in any way.
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` For the foregoing reasons, Respondent respectfully moves the Board for leave to file a
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`response in opposition to Petitioner’s motion to compel and its own counter-motion to compel
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`within fourteen days (by February 22, 2024).
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`1
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`Dated: February 8, 2024
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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
`Leave to File Response in Opposition to Petitioner’s Motion to Compel and Respondent’s Counter-
`Motion to Compel was served on the following via email, on February 8, 2024, 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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`2
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