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`07284 998
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`v THE UNITED STATES PATEN I AND TRADEMARK OFFICE
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`Applicant:
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`Mayo Foundation
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`Serial No.:
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`75/298,180
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`Filed:
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`Mark:
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`May 27, 1997
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`MAYO ONE
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`Examining Attorney
`Daniel P. Vavonese
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`Law Office 109
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`—_________)
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`C
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`Signature
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`The Examining Attorney has refused registration of the above-identified mark under
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`Section 2(d) of the Lanham Act because he believes that Applicant’s mark, MAYOFE.1:
`Express Mail mailing label number
`TB586319932US
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`RESPOJSSJQ
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`I
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`Assistant Commissioner
`for Trademarks
`BOX RESPONSES-—NO FEE
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`2900 Crystal Drive
`Arlington, VA 22202—35 13
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`Dear Sir:
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`This responds to Office Action No. 1, dated February 2, 1998, in which registration of the
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`above-identified mark was refused under Section 2(d) of the Lanharn Act because the Examining
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`Attorney believes that Applicant’s mark is confusingly similar to a registered mark. The
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`Examining Attorney also inquired whether Applicant is the owner of certain registrations. This
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`response addresses the Examining Attorney‘s concerns in the order they were raised.
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`Registration No. 2,046,966
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`Date of Deposit
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`July 28, 1998
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`I hereby certify that this paper or fee is being deposited with the
`United States Postal Service “Express Mail Post Office to
`Addressee” service under 37 CFR 1.10 on the date indicated above
`and is addressed to the Assistant Commissioner for Trademarks,
`2900 Crystal Drive, Arlington, Virginia 22202-3513
`Elvina Smith
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`8 2
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`g
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`‘*
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`Name
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`used in connection with the identified services, is likely to be confused with Registration No.
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`2,046,966. Applicant respectfully disagrees with the Examining Attorney’s determination that
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`confusion is likely. Applicant, however, has obtained Registrant’s consent to the registration of
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`Applicant’s mark. This consent is the result of a negotiated Settlement Agreement entered into to
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`resolve a dispute between the parties. Before executing the Agreement, Applicant and Registrant
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`undertook a careful evaluation of their market situation and determined that confusion between
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`Applicant is the owner ofReg. Nos. 1,613,827; 1,614,853; 1,670,238; 2,025,755; and 2,028,929.
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`the two marks was unlikely, based in part upon the coexistence of the marks for approximately
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`fourteen years without any incidents of actual confusion occurring. A copy of this consent is
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`8 attached hereto as Exhibit A.
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`The Federal Circuit has repeatedly held that an agreement between two parties whereby
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`the owner of a federally registered mark (or marks) consents to the federal registration of the
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`other’s mark should be given considerable weight by the Examining Attorney and the PTO in
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`determining whether there is a likelihood of confusion. In re Four Seasons Hotels Limited, 987
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`F.2d 1565, 1566 (Fed. Cir. 1993). Here, those parties most interested in preventing confusion
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`have reached an appropriate solution. The Federal Circuit has indicated that it is “desirable to
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`encourage th[is] kind of cooperative dispute resolution.” Bongrain Int’l Corp. v. Delice de France
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`Inc., 1 USPQ2d 1775, 1776 (Fed. Cir. 1987). Accordingly, the Examining Attorney should give
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`considerable weight to this determination and approve Applicant’s mark for publication.
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`Prior Registrations
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`The Examining Attorney inquired whether Applicant is the owner of certain registrations.
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`I»!
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`‘0'
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`CONCLUSION
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`With the Examining Attorney’s reconsideration and withdrawal of his refusal of
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`registration under Section 2(d) of the Lanham Act, the application appears to be in proper form for
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`publication. Accordingly, Applicant respectfully requests that the mark be published in the
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`Official Gazette pursuant to 15 U.S.C. § 1062(a).
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`0,;ng ,
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`_
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`Respectfully submitted,
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`_ / '
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`Minneapolis, Minnesota 55402
`(612) 343—2178
`Attorneys for Applicant
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`. Buckingham, Esq.
`urke, Esq.
`V
`Joshua J.
`Dorsey & Whitney LLP
`Pillsbury Center South
`220 South Sixth Street
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`esident (
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`said mark in connection with its services since May 1, 1978, believes that there is no likelihood
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`of confusion with respect to the use of this mark, and hereby consents to the registration of the
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`mark set forth in the above identified application by Mayo Foundation for the services set forth
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`therein.
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`Respectfully submitted,
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`MAYO AVIATION, INC.
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`Dateiwcfifia
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`j:
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`Gwendolyn Mayo,
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`.
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`In Re Trademark Application of
`Mayo Foundation
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`Serial No.2 75/298,180
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`Filed: May 27, 1997
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`For:
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`51A Y 0 ONE
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`CONSENT
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`Mayo Aviation, Inc, 7765 S. Peoria Street, Englewood, Colorado 80112, which is
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`using the service mark MAYO AVIATION to identify its air taxi and ambulance services and
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`which owns a United States Trademark Registration No. 2,046,966, and which has been using
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