`ESTTA291259
`ESTTA Tracking number:
`06/23/2009
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`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91190234
`Defendant
`FRATELLI RE S.P.A.
`G. MATHEW LOMBARD
`LOMBARD & GELIEBTER LLP
`230 PARK AVENUE, 10TH FLOOR
`NEW YORK, NY 10169
`UNITED STATES
`mail@lgtrademark.com
`Motion to Suspend for Settlement Discussions
`G. Mathew Lombard
`mlombard@lgtrademark.com
`/g mathew lombard/
`06/23/2009
`MOTION TO SUSPEND.pdf ( 3 pages )(31686 bytes )
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`Proceeding
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`Correspondence
`Address
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`Filer's Name
`Filer's e-mail
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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` Opposition No. 91190234
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`Atty Ref.: 109.0903
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`APX ALARM SECURITY SOLUTIONS, INC. |
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`Opposer,
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`FRATELLI RE S.P.A.
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`MOTION TO SUSPEND FOR 90 DAYS
`FOR SETTLEMENT DISCUSSIONS WITH CONSENT
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`For the reasons that follow, Applicant respectfully requests that the Board
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`SUSPEND the pending opposition for 90 days to allow the parties to engage in
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`settlement discussions.
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`The Notice of Opposition was filed on May 13, 2009 and the Board, in an order
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`dated May 15, 2009, set Applicant’s time to Answer on June 24, 2009. Counsel for
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`Applicant and counsel for Opposer have been in contact and believe that this matter may
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`be resolved between the parties without further resort to inter partes proceedings.
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`Accordingly, on June 22, 2009, counsel of record for Opposer, Grant R. Clayton,
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`consented to the requested extension by email.
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`In view of the foregoing, Applicant respectfully requests that the instant
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`proceeding be SUSPENDED for 90 days to allow the parties to engage in settlement
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`discussions. Moreover, Applicant respectfully request that the relevant trial dates be reset
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`accordingly at the end of the suspension period.
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`By:
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`Respectfully submitted,
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`FRATELLI RE SPA
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`______________________________
`G. Mathew Lombard
`Darren M. Geliebter
`LOMBARD & GELIEBTER LLP
`230 Park Avenue
`10th Floor
`New York, NY 10169
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`Attorneys for Applicant
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`Dated: June 23, 2009
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`CERTIFICATE OF SERVICE
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` hereby certify that a true and correct copy of MOTION TO SUSPEND FOR 90 DAYS
`FOR SETTLEMENT DISCUSSIONS WITH CONSENT was served on counsel for Opposer at the
`following address of record, by first class mail, postage prepaid, this 23rd day of June
`2009:
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`Grant R. Clayton
`CLAYTON, HOWARTH & CANNON, P.C.
`P.O. Box 1909
`Sandy, UT 84091
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`________________________
`G. Mathew Lombard



