ESTTA Tracking number:
`
`ESTTA1319057
`
`Filing date:
`
`10/30/2023
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Ex Parte Appeal -
`Serial No.
`
`97060107
`
`Appellant
`
`Truckvault, Inc.
`
`Applied for mark
`
`TRUCKVAULT
`
`Correspondence
`address
`
`Submission
`
`Attachments
`
`Filer's name
`
`Filer's email
`
`Signature
`
`Date
`
`CLARK A. PUNTIGAM
`JENSEN & PUNTIGAM, P.S.
`2033 6TH AVE, SUITE 990
`SEATTLE, WA 98121
`UNITED STATES
`Primary email: clark@jensenpuntigam.com
`Secondary email(s): docket@jensenpuntigam.com
`206-448-3200
`
`Supplemental brief
`
`20231030_Substitute Appeal Brief_0202-0009TUS.pdf(880942 bytes )
`
`James C. Larsen
`
`jim@larsen-ip.com
`
`/James C. Larsen/
`
`10/30/2023
`
`

`

`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`Ex Parte Appeal Serial No.: 97060107
`
`Appellant:
`
`
`
`Applied for mark:
`
`
`
`
`
`TruckVault, Inc.
`
`TRUCKVAULT
`
`Correspondence Address:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`James C. Larsen
`Larsen IP, PLLC
`24207 25th Ave SE
`Bothell, WA 98021
`United States
`Primary email: Jim@Larsen-IP.com
`425-298-6846
`
`
`
`
`
`Supplemental Appeal Brief
`
`The Examining Attorney requested remand of the application on July 26, 2023 due to the
`
`assignment of a new Examining Attorney having a desire to supplement the evidence of record.
`
`This Substitute Appeal Brief is filed in response to a Subsequent Final Office Action dated
`
`August 30, 2023, in which the Examining Attorney (a) provided allegedly supplemental evidence
`
`to support the assertion that the applied for mark is merely descriptive and (b) asserted that the
`
`Appellant’s arguments presented in an Appeal Brief June 13, 2023 were unpersuasive. Appellant
`
`addresses the supplied evidence and assertions.
`
`
`
`Response to Rejection Under Section 2(e)(1) – The mark is not merely descriptive when
`considered as a whole.
`
`
`Appellant maintains that the mark, when considered as a whole as it must be, is not
`
`merely descriptive. The mark, TRUCKVAULT, is not a “telescoped mark” as the Action asserts.
`
`Unlike the cited marks FIRSTIER and NANDRIVE, even if the terms “truck” and “vault” could
`
`reasonably be considered separately as the Action asserts, they do not share any letters.
`
`Appellant maintains that TRUCKVAULT is unitary and conveys a commercial impression
`
`distinct from the individual meanings of its components. In viewing the mark as a whole
`
`(TRUCKVAULT), Appellant maintains and reiterates that there is no recognized definition of
`
`TRUCKVAULT as a single term (as a whole), which is the case here, nor is there a generally
`
`
`
`1
`
`

`

`Supplemental Appeal Brief
`Filed October 30, 2023
`
`
`
`Attorney Docket 0202-0009TUS
`
`understood meaning of the single term. The refusal of registration is an example of not taking
`
`into account use and registration of Appellant’s mark in the industry, a “real world”
`
`understanding of Appellant’s mark.
`
`The Subsequent Final Office Action appears to address Appellant’s claim—that the only
`
`use of TRUCKVAULT in the industry is by the Appellant—by identifying various uses of
`
`“truck” and “vault” separately, and in a few cases the use of “truck vault”. However, as is shown
`
`below, these uses do not evidence descriptive use of “TRUCKVAULT” as a whole, and in most
`
`relevant instances the appearance of “truck vault” in the cited material appears to reference the
`
`Appellant’s own business and products, clearly supporting the Appellant’s position that the mark
`
`is consistently used in commerce—and recognized—for identifying the source of Appellant’s
`
`goods.
`
`The Office Action asserts (at p. 4, paragraph beginning “Furthermore, …”) that "the
`
`wording 'truck vault' is commonly used to refer to goods of the type applicant provides."
`
`However, each of the identified pieces of evidence (a) only use the word "vault" and not "truck
`
`vault" (Applicant stipulates that the word "vault" alone has a well-known meaning in reference to
`
`a secure storage container), (b) uses “truck vault” informally in reference to the Appellant and/or
`
`the Appellant’s products, and/or (c) uses “truck vault” in homage or comparison with Appellant’s
`
`long-existing business and products and well-known mark. Appellant asserts that informal blog
`
`and forum entries included in some of the citations—where non-commercial posts tend not to
`
`follow common grammatical rules, much less respect trademark use—are very weak evidence of
`
`the alleged descriptiveness and/or genericness of the instant unitary mark considered as a whole.
`
`
`
`Reference (page
`number of the
`Use of "truck vault"
`Office Action)
`Motortrend (p. 109) (p. 111) "Robertson is especially fond
`of the gun storage container. 'It's
`called a 'truck vault.' You can lock it
`up, and it pulls out like a long
`drawer."
`(p. 12) "Also in Miller's shop is an old
`ambulance from the Los Angeles
`Police Department that he is
`renovating to be a disaster vehicle
`complete with a few days' worth of
`
`The Reflector (p. 7)
`
`Response
`This July 2015 statement
`presumably references
`Appellant's actual product,
`albeit presented in lower case
`and spaced.
`The article, published in 2019,
`quotes disaster prepper TJ
`Miller of Battleground, WA.
`Miller lives reasonably close
`the Appellant's main factory in
`
`
`
`2
`
`

`

`Supplemental Appeal Brief
`Filed October 30, 2023
`
`
`
`Attorney Docket 0202-0009TUS
`
`food. a fire ax and a truck vault.
`something he builds to securely store
`items in a vehicle. Also equipped with
`a truck vault is Miller's Jeep
`Wrangler, which has everything from
`a snorkeling system to an air
`compressor.
` "It's got everything I think people
`should have on their car in case of a
`disaster," Miller said before pulling
`out the truck vault containing a flare
`gun, hiking equipment and enough
`food and water to survive for a week."
`(p. 215) "Besides BR5930 Old Glory
`"Battle Ready" Tactical Gun Safe, the
`company also offers vault doors, gun
`racks, diversion safes, truck vaults,
`and wall safes, just to name a few."
`
`(p. 145) The size of your gun rack or
`storage box depends on the type of
`firearm you own. For instance, you
`may not want a full-length gun rack if
`you carry a Beretta 92FS. For storing
`your Beretta, you may want to
`consider buying a truck vault gun
`storage unit."
`
`United Commerce
`Group (p. 214)
`
`Decked (p. 138)
`
`State News Service
`(p. 245)
`
`(p. 246-247) "At the shop, agents
`seized 15 pounds of cocaine from
`hidden compartments in the vehicle
`
`
`
`3
`
`Sedro Wooley, WA, and the
`article was published over 20
`years after Appellant's asserted
`date of first use in commerce.
`Appellant respectfully asserts
`that Miller's reference to a
`"truck vault" for his (non-
`commercial) storage units
`should reasonably be
`considered an homage to
`Appellant's products.
`
`This announcement, published
`July 28, 2017—long after
`Appellant began use of the
`mark—refers to a safe offered
`by GunSafes.com.
`GunSafes.com is a reseller of
`gun safe products, including
`Appellant's products. See
`further response below with
`regard to GunSafes.com
`Decked is a direct competitor
`of Appellant. Decked is aware
`of and generally respects the
`Appellant's trademarks, even
`respectfully comparing the
`products. In referring to
`storage for a Beretta (pistol),
`the cited page implicitly
`acknowledges Decked's lack of
`a small secure storage solution,
`and recommends a "truck
`vault", presumably referring to
`smaller-size secure firearm
`solutions offered in the
`Appellant's line. I.e., Appellant
`believes the article refers to
`Appellant's own mark, although
`the blogger mis-presented the
`mark without capitalization and
`adds a space.
`This reference describes a
`standard vault being
`transported by a cargo truck,
`
`

`

`Supplemental Appeal Brief
`Filed October 30, 2023
`
`
`
`Attorney Docket 0202-0009TUS
`
`Global Broadcast
`Database (p. 242)
`
`and an additional 119 pounds of
`cocaine from the cargo truck vault."
`
`p. 242) "Unknown persons entered the
`vehicle which was equipped with a
`truck vault that was loaded with
`sporting guns."
`
`and is thus not a use of "truck
`vault" relevant to the present
`appeal.
`Given the publication date of
`the tv news transcript (May
`2006), and the limited
`alternatives at the time,
`Appellant presumes the "truck
`vault" reference is to
`Appellant's own early product,
`and that the (likely automated)
`news transcription service
`simply neglected to
`appropriately unspace and
`capitalize "TruckVault" to
`correctly indicate the
`trademark.
`
`
`
`Company
`
`Use of "truck vault"
`
`Response
`
`GunSafes.com (p. 204)
`
`Product page labeled "Truck
`Vaults"
`
`Although GunSafes.com
`uses the term "truck vault,"
`to reference a collection of
`vehicle-mounted storage
`units, the manufacturers of
`those products (aside from
`Appellant) consistently
`refer to their respective
`products as a "locker,"
`"safe," or "console."
`According to extensive
`records at
`internetarchive.org,
`GunSafe.com first used the
`term "Truck Vault" online
`around mid-September
`2010 when it first debuted
`Appellant's truck bed
`Secure Storage Solutions.
`(See Appendix, p. 1.)
`Other secure storage
`devices marketed prior to
`that time, were identified
`only as "Console Vaults."
`Appellant is in the process
`of requesting that
`
`
`
`4
`
`

`

`Supplemental Appeal Brief
`Filed October 30, 2023
`
`
`
`Attorney Docket 0202-0009TUS
`
`S&S Canopies & Campers
`(p. 209)
`
`Alpha Outdoor Specialties
`(p. 220)
`
`(p. 212) "Follow this link
`https://www.4are.com/ and it will
`direct you to ARE's website.
`From there you will hit "Build
`Your Own." This will take you to
`a new page and will go through
`the following steps: …
`5. Additional accessories- add
`anything extra you may want
`such as cargo glides, truck
`vaults, bed rugs, or topper EZ
`Lift."
`(p. 221) "DAKOTA
`BADLANDS 283 TRUCK
`VAULT LITE" (product)
`
`GunSafes.com revise its
`labeling to respect
`Appellant's trademark
`rights.
`Utilizing the instructions,
`one finds that the only
`products that appear in
`association with "truck
`vaults" on the site are
`Appellant's own
`TruckVault secure locking
`storage products. (See
`Appendix, p.4)
`
`While Alpha Outdoor
`Specialties refers to the
`product it resells as a
`"truck vault," the product's
`manufacturer (Dakota 283)
`respects the TruckVault
`mark and has always
`identifies its storage
`product instead as
`"Lifestyle Vault" (see
`Appendix, p.5). Alpha
`Outdoor Specialties
`presumably intends to
`capitalize on the reputation
`and name recognition of
`"TruckVault" by its
`unauthorized use of the
`term in its marketing.
`
`
`
`Consumer
`
`reference
`
`Concealed
`Carry (p.
`84)
`
`Use of "vault"
`
`
`
`(p. 106, comment) "I carry
`everyday everywhere it is legal or
`won't get me fired. At work I take it
`off in the parking lot and keep it in
`a truck vault until I leave work and
`strap on again.
`
`This informal comment from May 2022
`in a forum website presumably
`references the Appellant's products, albeit
`incorrectly using the trademark.
`
`
`
`5
`
`

`

`Supplemental Appeal Brief
`Filed October 30, 2023
`
`
`
`Attorney Docket 0202-0009TUS
`
`Michigan
`Sportsman
`(p. 151)
`
`Refuge
`Forums (p.
`160)
`
`Retriever
`Training (p.
`155)
`
`
`
`"I have a homemade two drawer
`truck vault, that fits a five foot bed
`pickup."
`
`Another informal (sale) comment, from
`May 2015 paying homage to Appellant's
`products by referencing his homemade
`storage cabinet as a "truck vault".
`"Homemade truck vault...........???" Writer's Sept. 2012 forum inquiry
`explicitly references/compares
`Appellant's products to describe a need.
`(see p. 161 "something like this just not
`looking to spend 3400+:
`http://www.truckvault.com/ProductsByV
`ehicleType.aspx?CID=SO&VTID=PU"
`Writer's Oct. 2014 forum inquiry
`presumably references Appellant's
`products, as recognized by a subsequent
`commenter (p. 156): "Truck Vault are
`nice, …."
`
`"I've never had a truck vault or any
`other type of under the crate storage
`units and wondered how they've
`worked for you good folks on RTF."
`
`Furthermore, the Office Action asserts (at p. 4, paragraph beginning “Lastly, …”) that
`
`“third-parties commonly utilize the wording ‘vault’ to refer to storage containers specifically
`
`fitted for cargo areas of vehicles, the type of goods applicant provides.” On the contrary,
`
`Applicant asserts that third parties commonly use the word “vault” to reference a secure storage
`
`container, regardless of its location or portability. No evidence is presented by the Examining
`
`Attorney that suggests the word “vault” is selected by third parties over other options specifically
`
`due to placement in a vehicle. Notably, use of the word “vault” is distinct from a use of the
`
`subject trademark “TRUCKVAULT” as a whole. Each of the referenced sources identified in the
`
`above-identified paragraph of the Office Action uses “vault” only to describe a secure storage
`
`container. In at least one instance the term “console vault” is used, which arguably references
`
`products associated with another trademark (e.g., CONSOLE VAULT Reg. No. 5034351).
`
`Appellant does not claim rights in the word “vault” alone, and thus does not recognize in the
`
`Office-provided “evidence” an argument that TRUCKVAULT is fatally descriptive.
`
`Not only is the mark not “merely descriptive” within the meaning of the Trademark Act,
`
`it is certainly not “highly descriptive” as asserted by the examining attorney. The evidence
`
`provided by the examining attorney fails to show that the mark is considered generic under the
`
`Trademark Act or even the common meaning, as all references are arguably to the Appellant’s
`
`own mark, business, and/or product. The mark is not used in industry as the name for the goods,
`
`and evidence in the record is insufficient to support a conclusion of genericness.
`
`
`
`6
`
`

`

`Supplemental Appeal Brief
`Filed October 30, 2023
`
`
`
`Attorney Docket 0202-0009TUS
`
`Accordingly, Appellant respectfully requests that the Board find the application for
`
`registration of the mark TRUCKVAULT allowable. Such conclusion will permit the registration
`
`to join with sister registrations 2500465 and 6977761 (below) in preserving and promoting the
`
`Appellant’s business.
`
`
`
`
`
`
`
`Alternative assertion of Allowability
`
`
`In the alternative, i.e., if the Board is not persuaded that TRUCKVAULT is not merely
`
`descriptive, Appellant asserts that the mark has acquired distinctiveness under §2(f) of the
`
`Trademark Act. The mark has been in famous use nationwide for over 20 years, as mentioned in
`
`response to the original Office Action and in the original appeal brief. The above-mentioned
`
`prior registrations evidence the prior use in commerce for more than 5 years. The mark is not a
`
`generic term for vehicle-mounted secure storage solutions as many other terms are in wide use
`
`for such general description (as evidenced by many of the examiner-cited references themselves).
`
`The mark is, for this alternative reason, not merely descriptive or generic. Appellant respectfully
`
`requests that the application be judged as allowed.
`
`
`
`7
`
`

`

`
`
`
`
`
`
`
`
`
`APPENDIX
`
`to Supplemental Appeal Brief
`
`Proceeding No. 97060107
`
`
`
`
`

`

`8/30/23, 11:11 PM
`
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`1/3
`APPENDIX p. 1
`
`

`

`8/30/23, 11:11 PM
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`2/3
`APPENDIX p. 2
`
`

`

`8/30/23, 11:11 PM
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`
`3/3
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