`ESTTA593487
`ESTTA Tracking number:
`03/19/2014
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91182377
`Plaintiff
`RCN Telecom Services, Inc.
`GLENN A GUNDERSEN
`DECHERT LLP
`2929 ARCH STREET , CIRA CENTRE
`PHILADELPHIA, PA 19104-2808
`UNITED STATES
`trademarks@dechert.com, glenn.gundersen@dechert.com,
`christine.hernandez@dechert.com
`Motion to Extend
`Jacob Bishop
`trademarks@dechert.com, glenn.gundersen@dechert.com,
`jacob.bishop@dechert.com
`/Jacob Bishop/
`03/19/2014
`RCN -- Motion to Extend Trial Deadlines in Consolidated Proceeding.pdf(10007
`bytes )
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`Proceeding
`Party
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`Correspondence
`Address
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`Submission
`Filer's Name
`Filer's e-mail
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`Signature
`Date
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Consolidated Proceeding No.
`91182377 (parent)
`91192058
`91192065
`91192239
`91194069
`91201298
`91207257
`92051509
`92052167
`92052330
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`RCN TELEVISIÓN, S.A.
`
`Petitioner,
`
`v.
`
`RCN TELECOM SERVICES, INC.
`RCN TELECOM SERVICES, LLC
`
`Respondents.
`
`CONSENT MOTION TO EXTEND TRIAL DEADLINES FOR
`CONSOLIDATED PROCEEDING NO. 91182377
`
`RCN TELECOM SERVICES, INC. and RCN TELECOM SERVICES, LLC
`
`(collectively, “Respondents”), by their attorneys, respectfully request that the trial deadlines for
`
`Consolidated Proceeding No. 91182377 be extended as follows:
`
`Deadline for discovery conference for Opp. No. 91207257:
`
`April 7, 2014
`
`Discovery opens in Opp. No. 91207257:
`
`Initial disclosures in Opposition No. 91207257 due:
`
`All expert disclosures due:
`
`Discovery closes:
`
`April 7, 2014
`
`May 7, 2014
`
`September 8, 2014
`
`October 8, 2014
`
`RTS’s pretrial disclosures in Opp. No. 91182377 due:
`
`December 7, 2014
`
`RTS’s 30-day testimony period as plaintiffs in Opp. No.
`91182377 to close:
`
`January 21, 2015
`
`RCN TV’s pretrial disclosures in all proceedings due:
`
`February 5, 2015
`
`RCN TV’s 30-day testimony period as defendant in Opp.
`No. 91182377 and as plaintiff in the remaining proceedings
`to close:
`
`March 22, 2015
`
`
`
`RTS’s pretrial disclosures for rebuttal as plaintiffs in
`Opp. No. 91182377 and as defendants in the remaining
`proceedings due:
`
`RTS’s 30-day testimony period as defendants in the
`Remaining proceedings and for rebuttal as plaintiffs in
`Opp. No. 91182377 to close:
`
`RCN TV’s rebuttal disclosures as plaintiff in the remaining
`Proceedings due:
`
`RCT TV’s 15-day rebuttal testimony period as plaintiff in
`The remaining proceedings to close:
`
`April 5, 2015
`
`April 21, 2015
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`May 21, 2015
`
`June 20, 2015
`
`Brief for RTS as plaintiffs in Opp. No. 91182377 due:
`
`August 19, 2015
`
`Brief for RCN TV as defendant in Opp. No. 91183277 and as
`Plaintiff in the remaining proceedings due:
`
`September 18, 2015
`
`Brief for RTS as defendants in the remaining proceedings
`And reply brief, if any, as plaintiffs in Opp. No. 91182377 due:
`
`October 18, 2015
`
`Reply brief, if any, for RCN TV as plaintiff in the remaining
`Proceedings due:
`
`November 17, 2015
`
`Respondents request this extension because Christine Hernandez, the attorney at Dechert
`
`LLP with primary responsibility for this proceeding, left Dechert LLP effective March 14, 2014,
`
`and Respondents’ attorneys require additional time to familiarize themselves with the
`
`complicated history of this proceeding. Respondents submit that these events constitute good
`
`cause for the extension of the trial dates under Section 509.01(a) of the TBMP.
`
`Petitioner RCN Television SA consents to the filing of this motion.
`
`
`
`Dated: March 19, 2014
`
`Respectfully submitted,
`
`/Jacob R. Bishop/
`Glenn A. Gundersen
`Jacob R. Bishop
`Dechert LLP
`Cira Centre, 2929 Arch Street
`Philadelphia, PA 19104-2808
`(215) 994-2183
`
`Attorneys for Respondents
`RCN TELECOM SERVICES, INC. and
`RCN TELECOM SERVICES, LLC.
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing Answer is being deposited
`with the U.S. Postal Service, postage prepaid, addressed to Gary H. Fechter, Esq., McCarter &
`English, LLP, 245 Park Avenue, New York, NY 10167 on March 19, 2014.
`
`/Jacob R. Bishop/
`Jacob R. Bishop



