TTAB
`
`IN THE UNITED STATES PATENT AND TRADEMARK OF . .\,..
`
`TRADEMARK TRIAL AND APPEAL BOARD
`
`) )
`
`) Opposition No.:
`)
`
`) )
`
`Opposed Application:
`) TRANS INSURANCE BROKERS
`) App. Ser. No. 77/414,046
`
`TRANSAMERICA CORPORATION,
`
`Opposer,
`
`V.
`
`TRANS INSURANCE BROKERS,
`
`) )
`
`Applicant.
`
`NOTICE OF OPPOSITION
`
`Transamerica Corporation (“Opposer”), a Delaware corporation principally located at
`
`4333 Edgewood Road, Cedar Rapids, IA 52499, hereby opposes U.S. Service Mark Application
`
`Serial No. 77/414/046, filed on March 11, 2008, by Trans Insurance Brokers, for registration of
`
`“insurance brokerage in the field of property and casualty,” in International Class 36. Opposer
`
`believes that it will be damaged by registration of Applicant’s mark in Class 36, and that
`
`registration of Applicant’s mark is prohibited under Section 2(d) of the Federal Trademark Act
`
`of 1946, as amended (the “Lanham Act”), 15 U.S.C. § 1052(d), because the mark, if registered,
`
`is likely to be confiised with Opposer’s registration and use of service marks owned by Opposer
`
`featuring the pre-fix “TRANS” in connection with insurance.
`
`In support of this Opposition, Opposer states as follows:
`
`1.
`
`Opposer is one of the nation’s leading insurance underwriters with armual
`
`revenues in excess of $8 billion. Opposer operates through a network of direct and indirect
`
`wholly owned subsidiaries and operating units, historically including:
`
`(a)
`
`Transamerica Occidental Life Insurance Company (statutorily merged into
`Transamerica Life Insurance Company by operation of law effective October 1,
`2008), providing insurance products since 1906 with more than $940 billion of
`insurance in force as of December 31, 2007;
`03/ 10/2009 SHILSUNI 00000024 133405
`7?414046
`01 rc:e4oe
`300.00 DA
`
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`03-06-2009
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`
`5 Patent
`
`
`
`

`
`(b)
`
`(C)
`
`(d)
`
`(6)
`
`(0
`
`(g)
`
`(h)
`
`(i)
`
`2.
`
`Transamerica Life Insurance Company, underwriting life insurance since 1961
`with more than $55 billion of insurance in force as of December 31, 2007;
`
`Transamerica Financial Life Insurance Company, providing insurance products
`since 1947 with more than $293 billion of insurance in force as of December 31,
`
`2007;
`
`Transamerica Capital, Inc., a wholesale marketing and sales group that assists
`financial professionals in providing retirement services;
`
`Transamerica Financial Advisors, Inc., a full service broker/dealer and financial
`
`services provider;
`
`Transamerica Investment Management, LLC, a provider of investment
`management services;
`
`Transamerica Reinsurance, an operating unit of Transamerica Life Insurance
`Company, engaged in the supply of reinsurance and structured solutions, product
`development and consulting services to financial services companies, in the life
`and annuity markets;
`
`Transamerica Retirement Services, a marketing unit of Transamerica Financial
`Life Insurance Company and other Transamerica Companies, that assists
`companies in structuring of retirement plans for the benefit of their employees;
`and
`
`Transamerica Worksite Marketing, a marketing unit that provides voluntary
`supplemental products including term life, universal life, cancer, accident, and
`vision insurance.
`'
`
`Opposer offers its services from offices located throughout the United States and
`
`multiple websites including but not limited to wvwv.transamerica.com, vnvw.timllc.com,
`
`wwvwtransamericafunds.com, www.transamericaseriestrust.com, www.ta-retirementcom, and
`
`

`
` . The home page of Opposer’s flagship website at
`
`wvvw.transamerica.com currently appears as follows:
`
`i Tl{.r\NSAs\i1ElU(JA
`‘l'J'.I¢’ I'urm‘J' u!4!I'.‘r' l’)'!'.IH.'t}'f
`
`-‘-3'!-.it ‘
`
`ls.
`
`I-hoax’ tn-: F,.l”-7’*"C
`
`C-'-"EPVS
`
`font-Vt ii:
`
`IRANSAMERICA
`
`For Individuals 8: Families
`
`‘i§?;‘".:12E1;1‘i.‘;;“"“”'“"
`
`Fixed Anrit-il're:~
`Varial:/lie Aniiuities
`Mitual Funr_is
`
`Investment Management
`
`For Businesses
`
`Business Plan ning
`-tm §l<',. Retire rnem Plans
`lnvr:str11:_=nl: Mans garment
`wsricsite Ben. efits
`Reinsurance
`
`Cwlomor Loam
`
`lS£4.e-:t'_/‘:-.-1‘£r-Jduzt...
`
`Vicv .'l'JlltllZl'il.'l’\
`1
`International
`Financial
`-fmsmla | Huh: kc-1-3
`'
`Flroiassiunals
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`Slimrag-3: -f—
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`r‘-‘.r:u -:
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`,,-i Ln.-:. v Lu:--_t.-I .
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`«.1! r‘.L_L'l _'l ).1u
`l arizari ':'lL: ,'-.vi'.:.-r.:l.;
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`.'l.l~..
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`.aL‘1 ~‘,il _,
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`';.«.-I R'.‘lll!.lll.‘lIl *1.iIu|.xi'Iu*
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`
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`
`
`
`
`
`3.
`
`Since 1929 Opposer, through its subsidiaries and predecessors, has owned and
`
`used a family of service marks including the name “Transamerica” for financial services. Since
`
`1959 those services have included insurance underwriting. These marks are covered by a family
`
`of United States Trademark and Service Mark Registrations owned by Transamerica Corporation
`
`including the following:
`
`
`
`
`
` -EH11
`
`
`
`Goodslservices
`
`
`
`
`TRANSAMERICA
`
`718,353
`(7/11/1961)
`
`
`
`Consultation and advice to others in respect to
`corporate management having to do with
`questions of policy and the coordination of
`corporate policies and activities, in Class 35 (first
`use 1/1929)
`
`of monies of others, in Class 35 (first use 1/1929)
`
`
`(7/11/1961) Consultation and advice in respect to investment
`
`
`
`TRANSAMERICA
`
`718,358
`
`
`
`
`

`
` Goodslservices
`
`
`
` . No.
`
`831,626
`(7/4/1967)
`
`Underwriting of insurance — namely, life, including
`accident and health; in Class 36 (first use
`7/18/1959)
`
`978,808
`(2/12/1974)
`
`Financial services rendered to others — namely,
`insurance underwriting and investment services,
`in Class 35 (first use 1958)
`
`1,129,244
`(1/15/1980)
`
`
`
`Business forms, house organ, corporate reports
`and bulletins issued periodically, and employee
`and corporate directories, in Class 16 (first use
`3/1978)
`
`
`
`
`TRANSAMERICA
`
`TRANSAMERICA
`
`TRANSAMERICA
`
`
`
`
`
`TRANSAMERICA
`OCCIDENTAL LIFE
`
`1,240,567
`(5/31/1983)
`
`Undenrvriting of life insurance, in Class 36 (first
`use 9/1/1981)
`
`
`E TRANSAMERICA
`
`
`
`
`
`
`1,635,681
`(2/19/1991)
`
`Financial consulting services; investment
`management and counseling services; mutual
`funds management sales and distribution
`services; insurance premium financing services;
`insurance underwriting services for life and
`disability insurance; life and property and casualty
`reinsurance services; insurance agency services;
`
`surety bonding services; underwriting services for
`variable life insurance and variable annuity
`products, in Class 36 (first use 9/30/1989)
`
`
`
`
`
`
`
`
`TRANSAMERICA
`
`1.635.682
`(2/19/1991)
`
`TRANSAMERICA
`REINSURANCE
`
`1,869,955
`(12/27/1994)
`
`Reinsurance underwriting services in the field of
`life insurance, in Class 36 (first use 5/1993)
`
`TRANSAMERICA TRIBUTE
`
`2,224,207
`(2/16/1999)
`
`Life insurance underwriting services, in Class 36
`(first use 1/8/1998)
`
`TRANSAMERICA CLASSIC
`
`2,228,202
`(3/2/1999)
`
`Annuity underwriting services, in Class 36 (first
`use 1/8/1998)
`
`Life insurance and annuity underwriting services,
`in Class 36 (first use 10/19/1998)
`
`
`
`
`
`Life insurance and annuity undenlvriting services
`and retirement consulting services, in Class 36
`(first use 5/26/1998)
`
`2,246,732
`(5/18/1999)
`
`
`
`2,284,121
`(10/5/1999)
`
`
`
`2,288,612
`(10/26/1999)
`
`2,320,968
`(2/22/2000)
`
`
`
`Life insurance and annuity underwriting services,
`in Class 36 (first use 3/1/1998)
`
`Life insurance underwriting services, in Class 36
`(first use 3/4/1999)
`
`TRANSAMERICA BOUNTY
`
`TRANSAMERICA
`PLAN MAXIMIZER
`
`TRANSAMERICA CATALYST
`
`TRANSAMERICA LINEAGE
`
`
`
`
`
`
`

`
`Goodslservices
` —ElI1
`
`TRANSAMERICA ELITE
`
`3'
`
`2,458,663
`(6/05/2001)
`
`Life insurance underwriting and administration
`services, in Class 36 (first use 06/01/2000)
`
`TRANSAMERICA SECURE
`REWARDS
`
`2,486,240
`(9/4/2001
`
`Annuity underwriting services, in Class 36 (first
`use 2/1/2000
`
`TR::";|E§gCA
`
`2,609,854
`(8/20/2002)
`
`Self-directed stock brokerage account services
`offered to owners of 401 (k) pension accounts, in
`Class 36 (first use 9/30/2000)
`
`TRANSAMERICA POLICY
`STARTER
`
`2,663,133
`(12/17/2002)
`
`Life insurance undenivriting services, in Class 36
`(first use 2/1/2002)
`
`TRANSAMERICA
`LTC PLUS
`
`2,688,175
`(2/18/2003)
`
`Insurance underwriting and administration in the
`field of chronic health care, in Class 36 (first use
`6/1/2001)
`
`TRANSAMERICA CENTER
`FOR RETIREMENT STUDY
`
`3,058,524
`(2/14/2006)
`
`Public policy research and analysis of issues in
`the field of retirement and employee benefits, in
`Class 35 (first use 11/11/2002)
`
`Educational services, namely conducting forums
`and seminars in the field of retirement and
`
`employee benefits, in Class 41 (first use
`11/11/2002)
`
`TRANSAMERICA FULCRUM
`
`3,062,005
`(2/28/2006)
`
`Investment management services, in Class 36
`(first use 1/1/2005)
`
`TRANSAMERICA BROKER
`DEALER DIRECT
`
`3,147,208
`(9/26/2006)
`
`Insurance unden/vriting in the in the field of life
`insurance offered on a wholesale basis; life
`insurance administration, In Class 36 (first use
`11/1/2004)
`
`TRANSAMERICA. MASTER
`RETIREMENT.
`
`3,238,735
`(5/8/2007)
`
`Administration of retirement plans and investment
`management services, in Class 36 (first use
`8/1/2006)
`
`3,358,373
`(12/25/2007)
`
`Life insurance underwriting services, in Class 36
`(first use 5/1/2006)
`
`TRANSAMERICA
`OCCIDENTAL LIFE QUAN MEI
`REN SHOU BAO XIAN GONG
`SI <TRANSAMERICA LIFE
`INSURANCE COMPANY> &
`
`Design
`
`é
`
`TRANSAMERICA
`OCCIDENTAL LIFE
`
`‘2.%./\#’nTr&"¢~.‘$
`
`

`
` -EH11
`
`. TRANSAMERICA SECURE
`
`3,430,218
`(5/20/2008)
`
`Long term care insurance underwriting services,
`in Class 36 (first use 6/6/2002)
`
`Goodslservices
`
`
`TRANSITIONS BY
`TRANSAMERICA
`
`3,430,970
`(5/20/2008)
`
`Long term care insurance underwriting services,
`in Class 36 (first use 10/3/2007)
`
`4.
`
`In addition to the above, Opposer owns and uses a family of service marks
`
`featuring the prefix “TRANS” coupled with other terms in connection with insurance and
`
`financial services. This family of “TRANS” marks is covered by the following United States
`
`Trademark and Service Mark Registrations:
`
`Mark
`
`TRANSMAX
`
`Re -
`
`1,364,880
`(10/08/1985)
`
`Insurance undenivriting services, in Class 36 (first
`use 02/15/1985)
`
`TRANSCENDER
`
`1,424,244
`(1/06/1987)
`
`Life insurance undenivriting services, in Class 36
`(first use 11/1/1985)
`
`TRANSEQUITY
`
`1,487,796
`(5/10/1988)
`
`Life insurance underwriting services in Class 36
`(first use 4/7/1987)
`
`TRANSPLUS
`
`1,536,748
`(4/25/1989)
`
`Annuity underwriting services, in Class 36 (first
`use 11/1986)
`
`TRANS-SELECT
`
`1,650,333
`(7/9/1991)
`
`Investing the pension funds of others, in Class
`36 (first use 11/17/1988)
`
`TRANSCARE
`
`1,672,078
`(1/14/1992)
`
`Health insurance underwriting services, in Class
`36 (first used 12/03/1990)
`
`TRANSCARE OPTIONS
`
`2,672,415
`(1/07/2003)
`
`Health insurance underwriting services and/or
`long term care indemnity insurance underwriting
`providing for nursing and/or nursing home
`services, physical respiratory and/or speech
`therapy, audiological services, medical and/or
`social services, home care services, namely,
`bathing, dressing, toilet, adult day care services,
`nursing facility and/or assisted living care facility
`services, home modification services, therapeutic
`device rental or purchase, bed reservation
`services in nursing facilities and/or hospice care
`services, in Class 36 (first used 06/01/2002)
`
`T
`
`I
`
`I
`
`A
`
`1,731,606
`(11/10/1992)
`_i_
`
`Life insurance undenivriting services, in Class 36
`(first use 11/27/1991)
`I:
`
`

`
`
`
`
`
`
`
`1,902,999
`Life insurance unden/vriting services, in Class 36
`(7/4/1995)
`(first use 4/12/1994)
`
`1,934,916
`Life insurance underwriting services containing
`(11/14/1995)
`investment options for policy holders, in Class 36
`(first use 4/25/1994)
`
`
`
`
`
`1,982,523
`(6/25/1996)
`
`Life insurance underwriting services, in Class 36
`(first use 6/30/1995)
`
`2,218,549
`(1/19/1999)
`
`Life insurance underwriting services, in Class 36
`(first use 7/02/1997)
`
`Providing information on-line via computer to
`customers regarding pension accounts, in Class
`36 (first use 10/31/1996)
`
`
`
`
`
`2,125,499
`(12/20/1997)
`
`
`
`2,223,978
`(2/16/1999)
`
`Life insurance underwriting services, in Class 36
`(first use 9/13/1989)
`
`2,277,415
`(9/14/1998)
`
`Life insurance underwriting services, in Class 36
`(first use 11/17/1997)
`
`2,514,570
`(12/4/2001)
`
`Annuity underwriting services, in Class 36 (first
`use 2/1/2000)
`
`2,648,195
`(11/12/2002)
`
`Providing marketing information to insurance
`brokers, agents and consumers for purposes of
`marketing insurance products, in Class 35 (first
`use 9/11/1998)
`
`Providing insurance information to insurance
`brokers, agents and consumers for purposes of
`marketing insurance products, in Class 36 (first
`use 9/11/1998)
`
`liansllilvantage
`
`l~
`TRANSEQLIITV
`%I[___.___
`
`TRANSSAVERS
`
`TRANSVALUE
`
`TRANSDIRECT
`
`TRANSLIFE
`
`TRANSMILLENIUM
`
`TRANSFREEDOM
`
`TRANSACT
`
`TRANSACE
`
`2,717,097
`Life insurance underwriting services, in Class 36
`
`(5/20/2003)
`(first use 5/31/2001)
`
`
`TRANSACE SURVIVOR
`
`2,720,613
`(6/3/2003)
`
`
`Life insurance underwriting services, in Class 36
`(first use 5/31/2001)
`
`
`
`
`
`
`TRANSACCESS
`
`2,743,894
`(7/29/2003)
`
`Of information by means of telephone and by
`global computer networks concerning retirement
`plan account information; and administration of
`defined contribution retirement plans, in Class 36
`(first use 6/24/2002)
`
`TRANSSMILE
`
`2,761,407
`(9/09/2003)
`
`Dental insurance underwriting services, in Class
`36 (first used 06/01/2002)
`
`

`
`
`TRANSSECURE
`
`2,812,729
`(2/10/2004)
`
`Long-term health care insurance underwriting
`services, in Class 36 (first use 10/15/2002)
`
`2,812,735
`(2/10/2004)
`
`Life insurance unden/vriting services, in Class 36
`(first use 1/16/2003)
`
`2,836,281
`(4/27/2004)
`
`Health insurance underwriting services, in Class
`36 (first used 05/15/2003)
`
`2,963,660
`(6/29/2005)
`
`Annuity underwriting services, in Class 36 (first
`use 4/14/2003)
`
`2,963,661
`(6/28/2005)
`
`Annuity unden/vriting services, in Class 36 (first
`use 4/14/2003)
`
`3,000,511
`(9/27/2005)
`
`Life insurance unden/vriting, in Class 36 (first use
`
`9/15/2003)
`
`3,003,173
`(10/4/2005)
`
`Life insurance and annuity underwriting services,
`in Class 36 (first use 2/4/2002)
`
`3,022,835
`(12/06/2005)
`
`Health insurance underwriting services, in Class
`36 (first use 03/01/2004)
`
`
`
`3,073,968
`(3/28/2006)
`
`Life insurance underwriting services, in Class 36
`(first use 7/10/2003)
`
`3,117,788
`(7/18/2006)
`
`Life insurance underwriting services, in Class 36
`(first use 8/1/2005)
`
`3,1 17,789
`(7/18/2006)
`
`Life insurance underwriting services, in Class 36
`
`(first use 8/1/2005)
`
`3,131,783
`(8/22/2006)
`
`Life insurance unden/vriting services, in Class 36
`(first use 8/3/2005)
`
`
`
`
`
`3,170,495
`(11/14/2006)
`
`
`
`
`
`
`
`
`
`Insurance and annuity unden/vriting services;
`investment advisory and mutual fund brokerage
`services; investment advisory services in the
`nature of financial planning for retirement, in
`Class 36 (first use 11/1/2005)
`
`
`
`Computer software for use in estimating the
`appropriate amount of life insurance coverage
`and calculating premiums and future value of life
`insurance policies, in Class 9 (first use
`9/12/2005)
`
`
`
`
`
`
`3,170,496
`(11/14/2006)
`
`
`
`
`TRANSSHARE
`
`TRANSCONNECT
`
`TRANS 9
`
`TRANS 6
`
`TRANSSECURE
`
`TRANSACCUMULATOR
`
`TRANSCHOICE
`
`TRANSSOLUTION
`
`TRANSEXPRESS
`
` $s
`
`TRANSULTRA PLUS
`
`TRANSWARE
`
`TRANSKEY
`
`TRANS-$AVER
`
`3,204,909
`(2/6/2007)
`
`Life insurance unden/vriting, in Class 36 (first use
`3/15/2006)
`
`

`
`TRANSLINK
`
`TRANSPROTECTOR
`
`3,209,503
`(2/13/2007)
`
`3,238,738
`(5/8/2007)
`
`Health insurance underwriting featuring online
`enrollment, in Class 36 (first use 7/2005)
`
`Life insurance underwriting, in Class 36 (first use
`8/1/2006)
`
`
`
`
`
`
`
`TRANSDI
`
`Disability insurance underwriting services, in
`3,342,536
`Class 36 (first use 2/1/2007)
`(11/27/2007)
`
`
`5.
`
`Of the registrations pleaded above, all those over six years old are “incontestable”
`
`under Section 15 of the Lanham Act, 15 U.S.C. § 1065, and thereby constitute conclusive
`
`evidence of (i) the registration of the marks, (ii) the validity of the registered marks, (iii)
`
`Opposer’s ownership of the marks, and (iv) Opposer’s exclusive right to use the marks in
`
`commerce in connection with the identified goods and services, as provided by Section 33(b) of
`
`the Lanham Act, 15 U.S.C. § l115(b).
`
`6.
`
`For many years, Opposer has advertised its name and marks in national consumer
`
`publications such as Time, Newsweek, Sports Illustrated, The Wall Street Journal, Forbes, and
`
`US. News & World Report, and on network television, including the CBS, NBC, ABC television
`
`networks, as well as on cable television, network radio and other media.
`
`7.
`
`In recent years, Opposer’s advertisements have appeared on Sunday morning
`
`broadcast and cable news programs, CBS broadcasts of golf tournaments, and throughout the day
`
`on various cable television networks, including A&E, CNBC, CNN and CNN/Headline News,
`
`ESPN, Fox News, and the History Channel.
`
`8.
`
`National print publications carrying Opposer’s advertising in recent years include
`
`Smart Money, Kiplinger ’s, Barron ’s, Forbes, Investor ’s Business Daily, Money, Newsweek,
`
`Business Week, and The Wall Street Journal. Opposer’s advertisements also appear in dioramas
`
`in selected airports throughout the country.
`
`

`
`9.
`
`In addition to advertising by Opposer, Opposer’s subsidiaries have historically
`
`advertised and promoted Opposer’s name and marks through radio and television, newspapers,
`
`distribution of direct mailing pieces such as pamphlets, brochures, subscription letters, and other
`
`descriptive literature, press releases, office and window signs, decalcomania, and point-of-sale
`
`pieces such as counter displays, posters, and the like.
`
`10.
`
`In the years since Opposer’s sponsorship of the 1984 Summer Olympics, Opposer
`
`has spent hundreds of millions of dollars advertising its name and marks.
`
`11.
`
`Opposer actively polices its marks. To that end, Opposer’s counsel has
`
`corresponded with Applicant’s principal John Tran in an effort to avoid this opposition, but the
`
`parties are in disagreement on the merits.
`
`12.
`
`Due to extensive sales and advertising for many years, the name “Transamerica”
`
`and the family of “TRANS” marks pleaded above are well known to the public as a designation
`
`of origin that identifies Opposer and its subsidiaries as the source of insurance services offered
`
`under those marks. As a result, it is likely that members of the public who encounter Applicant’s
`
`“TRANS INSURANCE BROKERS” mark in connection with insurance services will be
`
`confused, mistaken and deceived, and will believe, erroneously, that Applicant’s insurance
`
`services are those of Opposer, or are sponsored, endorsed or approved by Opposer, or that there
`
`is an affiliation, relationship or some other connection between Applicant and Opposer.
`
`Consequently, Applicant’s “TRANS INSURANCE BROKERS” mark is prohibited from
`
`registration under Section 2(d) of the Lanham Act, 15 U.S.C. § 1052(d).
`
`WHEREFORE, Opposer requests the Board to sustain this Opposition.
`
`10
`
`

`
`Filing Fee
`
`The Board is hereby authorized to debit the deposit account of the undersigned law firm,
`
`Acc’t No. 133405, in the amount of $300, to cover the filing fee for this Notice of Opposition.
`
`Respectfully submitted,
`
`TRANSAMERICA CORPORATION
`
`Kt/>,_ /zacfaw ML ,4
`
`Date: March 4, 2009
`
`By:
`
`Bruce A. McDonald
`
`SCHNADER HARRISON SEGAL & LEWIS LLP
`750 19"‘ St., N.W., Suite 550
`Washington, D.C. 20001
`Tel.
`(202) 419-4200
`Fax:
`(202) 419-3454
`e-mail: bmcdonald@schnader.com
`
`11
`
`

`
`'
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on March 4, 2009, a copy of the foregoing Notice
`
`of Opposition was sent by UPS overnight delivery to Applicant at the following address:
`
`Trans Insurance Brokers
`
`1129 W. Gardena Blvd.
`
`Gardena, CA 90247
`
`flt/x .
`
`/I/Lk,/lfl;V(}“/\/\ ova - 4
`
`Bruce A. McDonald
`
`Attorney
`SCHNADER HARRISON SEGAL & LEWIS LLP
`
`

`
`9
`
`CERTIFICATE OF MAILING
`
`I hereby certify that a copy of this Notice of Opposition has been deposited with the
`'
`United States Postal Service as first class mail in an envelope addressed to: Commissioner for
`Trademarks, P.O. Box 1451, Alexandria, VA 22313-1451 on the date shown below:
`
`K/>‘ ‘
`
`gL.»Q. ,{
`
`Bruce A. McDonald
`
`March 4, 2009
`
`13
`
`

`
`Schnader
`'-ATTORNEYS AT LAW
`
`750 9TH STREET. NW surna 550
`WASHINGTON, DC 20001-4534
`202.419.4200 FAX 202.419.3454 schnadencom
`
`BRUCE A. MCDONALD
`PARTNER
`(202) 4 194235
`
`March 4, 2009
`
`Commissioner for Trademarks
`
`U.S. Patent and Trademark Office
`
`P.O. Box 1451
`
`Alexandria, VA 22312-1451
`
`Re:
`
`Transamerica Corporation v. Trans Insurance Brokers, Notice of Opposition
`against U.S. Service Mark Application Serial No. 77/414,046, “TRANS
`INSURANCE BROKERS,” in Class 36, Our Ref. 3007650.120.597
`
`Dear Sir or Madam:
`
`Enclosed for filing in this matter please find a notice of opposition in the captioned
`
`matter. The Board is hereby authorized to debit the deposit account of the undersigned law firm,
`
`Acc’t No. 133405, in the amount of $300, to cover the filing fee for this Notice of Opposition.
`
`Sincerely,
`
`AA. /l’\A//EV/V\ 0.12.4
`
`Bruce A. McDonald
`
`BAM:me
`
`Enclosure
`
`cc:
`
`Transamerica Corporation (w/enc-.)
`
`NEW YORK
`
`& Lewis LLP
`Schnader Harrison Segal
`PENNSYLVANIA
`CALIFORNIA WASHINGTON.DC
`NEW JERSEY
`
`HIIIIIllilllllllllllllilll|||||||||l||I||lllillll
`
`03-06-2009
`Y~1_¢‘:,"YM Ne)‘. R:;t
`
`'3'.
`
`=2-tart