Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA362398
`ESTTA Tracking number:
`08/10/2010
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91192042
`Plaintiff
`Annco, Inc.
`Ronald W. Meister
`Cowan, Liebowitz & Latman, P.C.
`1133 Avenue of the Americas
`New York, NY 10036
`UNITED STATES
`wmb@cll.com, rwm@cll.com, mel@cll.com, trademark@cll.com
`Motion to Amend Pleading/Amended Pleading
`Maryann E. Licciardi
`mel@cll.com, trademark@cll.com
`/Maryann E. Licciardi/
`08/10/2010
`LOFT (Storck) - Amended Notice of Opposition.pdf ( 13 pages )(35472 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`

`
`Ref. No. 24719-096
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`In re Application Serial No. 79/057849
`Filed: July 25, 2008
`For Mark: LOFT
`Published in the Official Gazette: June 9, 2009
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`ANNCO, INC.
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`:
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`Opposer,
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`v.
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`:
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`:
`AUGUST STORCK KG
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`:
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`:
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`Applicant.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`Trademark Trial and Appeal Board
`P.O. Box 1451
`Alexandria, VA 22313-1451
`
`
`
`
`
`
`Opposition No. 91192042
`
`AMENDED NOTICE
`OF OPPOSITION
`
`Opposer, Annco, Inc., a Delaware corporation, located at 7 Times Square, New York,
`
`
`
`New York 10036, believes that it will be damaged by registration of the mark LOFT as shown in
`
`Application Serial No. 79/057849 (the “Application”), filed by Applicant August Storck KG
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`(“Applicant”), and Annco, Inc., having been granted an extension of time to oppose up to and
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`including October 9, 2009, and having thereafter been granted leave to amend its notice of
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`opposition up to and including August 16, 2010, hereby opposes same.
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`
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`As grounds for opposition, it is alleged that:
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`OPPOSER’S BUSINESS AND RIGHTS
`
`1.
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`Opposer, its affiliates and their predecessors (referred to collectively as
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`“Opposer”) is a leading retailer of women’s apparel, accessories and other products in the United
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`States. For almost 15 years, which is long prior to January 28, 2008, Applicant’s claimed
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` 24719/096/1186703.4
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`

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`Ref. No. 24719-096
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`priority filing date, Opposer has been in the business of designing, having manufactured, selling
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`and distributing a wide array of goods sold in its retail stores and through its website using marks
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`consisting of or containing the word LOFT, used either separately or in conjunction with other
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`words, letters or design elements (the “LOFT Marks”). Candy is among the products in
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`connection with which Opposer has used its LOFT Marks.
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`2.
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`Since the launch of Opposer’s LOFT brand in 1995, when its first LOFT retail
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`store opened, Opposer has extensively marketed and promoted a variety of goods bearing the
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`LOFT Marks through its retail stores and website in the United States. Opposer’s net sales under
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`the LOFT Marks have been approximately one billion dollars ($1,000,000,000) in each of the
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`fiscal years ending January 28, 2006, February 3, 2007, February 2, 2008, January 31 2009 and
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`January 30, 2010. In fiscal year 2007 alone, prior to Applicant’s claimed priority filing date,
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`there were over 500 LOFT retail stores in the United States, the District of Columbia and Puerto
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`Rico, and this continues to date. Also in fiscal year 2007, the term LOFT was featured in paid
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`advertising appearing in magazines having a circulation of over 34 million readers, and the term
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`LOFT was mentioned in unpaid features showing LOFT products appearing in magazines having
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`a circulation of over 190 million readers, and similar advertising and promotion continues to
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`date. Thus, before Applicant’s claimed priority filing date and continuing to the present, the
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`LOFT business has become a huge commercial success, and the term LOFT has not only come
`
`to identify the stores and products of Opposer, but also has become a famous and distinctive
`
`symbol associated with Opposer by consumers and the trade overall.
`
`3.
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`As a result of the extensive sales and promotion of its goods and services bearing
`
`or offered in connection with Opposer’s LOFT Marks, Opposer has built up highly valuable
`
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` 24719/096/1186703.4
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`2
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`

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`Ref. No. 24719-096
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`goodwill in the LOFT Marks, and before Applicant’s claimed priority date of January 28, 2008,
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`the LOFT Marks became famous and distinctive of Opposer’s retail stores and website and
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`Opposer’s women’s apparel, accessories and other goods sold in Opposer’s stores and through its
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`website.
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`4.
`
`Annco, Inc. is the owner of the following registrations and applications in the
`
`United States Patent and Trademark Office (“USPTO”) for the LOFT Marks:
`
`Mark
`LOFT
`
`LOFT
`
`LOFT
`
`Reg. No./
`Ser. No.
`3,359,615
`
`3,434,715
`
`3,488,664
`
`LOFT
`LOFT
`
`3,756,220
`3,700,020
`
`5/27/2008
`
`8/19/2008
`
`Reg. Date/
`Filing Date Goods/Services
`12/25/2007
`35: ON-LINE AND IN STORE
`RETAIL STORE SERVICES IN THE
`FIELDS OF CLOTHING,
`FOOTWEAR, HANDBAGS, SMALL
`LEATHER ACCESSORIES,
`TOILETRIES, CONSUMABLE BATH
`PRODUCTS AND COSMETIC
`PRODUCTS
`26: HAIR ACCESSORIES, NAMELY,
`SCRUNCHIES, BARRETTES AND
`CLIPS; PONYTAIL HOLDERS
`25: CLOTHING, NAMELY,
`DRESSES, SKIRTS, SUITS, JEANS,
`SWEATERS, SHIRTS, T-SHIRTS,
`TANK TOPS, BODYSUITS,
`JUMPERS, VESTS, GLOVES, SLEEP
`WEAR, ROBES, SWIMSUITS,
`BLOUSES, PANTS, SHORTS,
`JACKETS, COATS, SOCKS,
`HOSIERY, BELTS, SCARVES,
`UNDERWEAR; HEADWEAR; AND
`FOOTWEAR
`3: SOAPS FOR PERSONAL USE
`36: CREDIT CARD SERVICES
`
`3/2/2010
`10/20/2009
`
`
` 24719/096/1186703.4
`
`3
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`

`
`Ref. No. 24719-096
`
`
`Mark
`LOFT
`
`Reg. No./
`Ser. No.
`3,703,017
`
`Reg. Date/
`Filing Date Goods/Services
`10/27/2009
`9: SUNGLASSES AND SUNGLASS
`CASES
`
`14: JEWELRY
`
`18: HANDBAGS, SHOULDER BAGS,
`EVENING HANDBAGS, COSMETIC
`CASES SOLD EMPTY, WALLETS,
`CLUTCH PURSES, TOTE BAGS,
`UMBRELLAS
`
`LOFT
`
`77/568,440 9/12/2008
`
`LOFT
`LOFT
`
`77/828,024 9/16/2009
`85/058,270 6/9/2010
`
`LITTLE LOFT
`
`3,373,790
`
`1/22/2008
`
`
` 24719/096/1186703.4
`
`4
`
`3: PERFUME; COLOGNE; TOILET
`WATER; BATH OIL; BATH GEL;
`BATH SALT; BATH CREAM; SKIN
`LOTION; MAKEUP FOR LIPS, EYES
`AND CHEEKS; FACIAL CLEANSER;
`SKIN MOISTURIZER; PERSONAL
`SOAPS
`30: CANDY
`41: ON-LINE JOURNALS, NAMELY
`BLOGS FEATURING FASHION
`INFORMATION; ENTERTAINMENT
`AND EDUCATION SERVICES IN
`THE NATURE OF A SERIES OF
`SHORT VIDEOS FEATURING
`FASHION AND ACCESSORIES
`ADVICE ACCESSIBLE BY
`COMPUTER NETWORKS
`
`42: COMPUTER SERVICES,
`NAMELY, CREATING AN ON-LINE
`COMMUNITY FOR REGISTERED
`USERS TO PARTICIPATE IN
`DISCUSSIONS, GET FEEDBACK
`FROM THEIR PEERS, FORM
`VIRTUAL COMMUNITIES, AND
`ENGAGE IN SOCIAL NETWORKING
`FEATURING SOCIAL MEDIA AND
`TOPICS ON FASHION AND
`ACCESSORIES
`25: CLOTHING; NAMELY,
`DRESSES, SKIRTS, BLOUSES,
`SHOES, PANTS, SHORTS, JACKETS,
`COATS, SOCKS, JEANS,
`
`

`
`Ref. No. 24719-096
`
`
`Mark
`
`Reg. No./
`Ser. No.
`
`LOFT FOR LIFE
`
`3,399,970
`
`LOFT FOR LIFE
`
`3,247,044
`
`LOFT PETITES
`
`3,350,308
`
`LOFTBEACH
`
`3,268,087
`
`3/18/2008
`
`5/29/2007
`
`Reg. Date/
`Filing Date Goods/Services
`SWEATERS, SHIRTS, T-SHIRTS,
`TANK TOPS, BODYSUITS,
`JUMPERS, VESTS AND
`SLEEPWEAR
`35: ON-LINE AND IN STORE
`RETAIL STORE SERVICES IN THE
`FIELDS OF CLOTHING,
`FOOTWEAR, HANDBAGS, SMALL
`LEATHER ACCESSORIES,
`JEWELRY, TOILETRIES, BATH
`PRODUCTS AND COSMETIC
`PRODUCTS
`25: CLOTHING, NAMELY,
`DRESSES, SKIRTS, SUITS, JEANS,
`SWEATERS, SHIRTS, T-SHIRTS,
`TANK TOPS, BODYSUITS,
`JUMPERS, VESTS, GLOVES,
`SLEEPWEAR, ROBES, SWIMSUITS,
`BLOUSES, SHOES, PANTS, SHORTS,
`JACKETS, COATS, SOCKS,
`HOSIERY, HATS AND CAPS,
`BELTS, SCARVES
`25: CLOTHING, NAMELY,
`DRESSES, SKIRTS, SUITS,
`BLOUSES, SWEATERS, SHIRTS, T-
`SHIRTS, TANK TOPS, JUMPERS,
`VESTS, PANTS, JEANS, SHORTS,
`JACKETS, COATS, SLEEPWEAR,
`SWIMSUITS
`
`35: ON-LINE AND IN STORE
`RETAIL STORE SERVICES IN THE
`FIELDS OF CLOTHING,
`FOOTWEAR, HANDBAGS, SMALL
`LEATHER ACCESSORIES,
`JEWELRY, TOILETRIES,
`CONSUMABLE BATH PRODUCTS
`AND COSMETIC PRODUCTS
`9: SUNGLASSES
`
`18:HANDBAGS, STRAW BAGS,
`TOTE BAGS, SHOULDER BAGS,
`CROCHETED BAGS, MACRAME
`BAGS, HOBO BAGS, LINEN BAGS,
`
`12/4/2007
`
`7/24/2007
`
`
` 24719/096/1186703.4
`
`5
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`

`
`Ref. No. 24719-096
`
`
`Mark
`
`Reg. No./
`Ser. No.
`
`LOFT CARES
`
`3,699,420
`
`LOFT LOVES
`TEACHERS
`
`3,697,910
`
`LIVE. LOVE.
`LOFT.
`
`3,782,059
`
`10/20/2009
`
`Reg. Date/
`Filing Date Goods/Services
`BEADED BAGS
`
`25: CLOTHING, NAMELY
`DRESSES, SKIRTS, JACKETS,
`PANTS, JEANS, SHORTS, BLOUSES,
`SHIRTS, KNITTED TOPS, STRETCH
`TOPS, JERSEY TOPS, HOODED
`SWEATSHIRTS, CROCHETED TOPS,
`CAMISOLES, HALTER TOPS,
`SLEEVELESS TOPS, TUNICS,
`PULLOVERS, SWEATERS, T-
`SHIRTS, BIKINI TOPS, TANK TOPS,
`ZIPPERED TOPS, SWIMWEAR,
`BELTS, SASHES, SCARVES,
`FOOTWEAR
`35: ENVIRONMENTALLY
`RESPONSIBLE RETAIL STORE
`SERVICES IN THE FIELD OF
`CLOTHING, FOOTWEAR,
`HANDBAGS, SMALL LEATHER
`ACCESSORIES, JEWELRY,
`TOILETRIES, BATH PRODUCTS,
`AND COSMETIC PRODUCTS
`
`36: CHARITABLE FUND RAISING
`SERVICES, NAMELY SHARING
`PROFITS FROM PRODUCT SALES
`WITH NOT-FOR-PROFIT
`ORGANIZATIONS, AND
`CHARITABLE FUND RAISING
`35: ADMINISTRATION OF A
`PROGRAM FOR ENABLING
`PARTICIPANTS TO OBTAIN
`DISCOUNTS ON GOODS AND
`RECEIVE IMPROVED SERVICES
`35: ON-LINE RETAIL STORE
`SERVICES IN THE FIELDS OF
`CLOTHING, FOOTWEAR,
`HANDBAGS, SMALL LEATHER
`ACCESSORIES, JEWELRY,
`TOILETRIES, CONSUMABLE BATH
`PRODUCTS, AND COSMETIC
`PRODUCTS
`
`10/20/2009
`
`4/27/2010
`
`
` 24719/096/1186703.4
`
`6
`
`

`
`Ref. No. 24719-096
`
`
`Mark
`LIVE. LOVE.
`LOFT.
`
`Reg. Date/
`Reg. No./
`Filing Date Goods/Services
`Ser. No.
`88/066,538 6/18/2010
`25: CLOTHING, NAMELY,
`DRESSES, SKIRTS, SUITS, JEANS,
`SWEATERS, SHIRTS, T-SHIRTS,
`TANK TOPS, BODYSUITS,
`JUMPERS, VESTS, GLOVES,
`SLEEPWEAR, ROBES, SWIMSUITS,
`BLOUSES, PANTS, SHORTS,
`JACKETS, COATS, SOCKS,
`HOSIERY, BELTS, SCARVES,
`UNDERWEAR; HEADWEAR; AND
`FOOTWEAR
`42: RETAIL CLOTHING STORE
`SERVICES
`
`5/13/1997
`
`2,061,836
`
`2,334,051
`
`3/28/2000
`
`
`
`
`
`ANNTAYLOR
`LOFT
`
`ANN TAYLOR
`LOFT
`ANNTAYLOR
`LOFT
`
`2,704,411
`
`4/8/2003
`
`2,825,310
`
`3/23/2004
`
`3,078,844
`
`4/11/2006
`
`ANNTAYLOR
`LOFT
`
`3,202,185
`
`1/23/2007
`
`
` 24719/096/1186703.4
`
`7
`
`25: CLOTHING, NAMELY
`DRESSES, SKIRTS, SUITS,
`BLOUSES, SHOES, PANTS, SHORTS,
`JACKETS, COATS, SOCKS,
`HOSIERY, HATS, BELTS, SCARVES
`AND UNDERWEAR
`9: SUNGLASSES AND SUNGLASS
`CASES
`
`14: JEWELRY
`
`18: HANDBAGS, POCKETBOOKS,
`SHOULDER BAGS, ROLL BAGS,
`EVENING HANDBAGS, COSMETIC
`CASES SOLD EMPTY, WALLETS,
`KEY CASES, CLUTCH PURSES,
`CLUTCH BAGS, GENERAL
`PURPOSE PURSES, DRAWSTRING
`POUCHES, TOTE BAGS,
`BACKPACKS, SLING BAGS,
`BRIEFCASE-TYPE PORTFOLIOS,
`SATCHELS, UMBRELLAS
`
`20: JEWELRY CASES NOT OF
`PRECIOUS METAL
`25: SWIMWEAR
`
`

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`Ref. No. 24719-096
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`Mark
`ANNTAYLOR
`LOFT
`
`ANNTAYLOR
`LOFT
`
`ANNTAYLOR
`LOFT
`
`Reg. No./
`Ser. No.
`3,327,631
`
`Reg. Date/
`Filing Date Goods/Services
`10/30/2007
`4: CANDLES
`
`3,500,924
`
`9/16/2008
`
`78/437,981 6/18/2004
`
`26: HAIR ACCESSORIES, NAMELY,
`SCRUNCHIES, BARRETTES AND
`CLIPS; PONYTAIL HOLDERS
`3: PERFUME; COLOGNE; TOILET
`WATER; BATH OIL; BATH GEL;
`BATH SALT; BATH CREAM; SKIN
`LOTION; SKIN MOISTURIZER;
`PERSONAL SOAPS
`25: CLOTHING, NAMELY,
`DRESSES, SKIRTS, SUITS, JEANS,
`SWEATERS, SHIRTS, T-SHIRTS,
`TANK TOPS, BODYSUITS,
`JUMPERS, VESTS, GLOVES, SLEEP
`WEAR, ROBES, SWIMSUITS,
`BLOUSES, PANTS, SHORTS,
`JACKETS, COATS, SOCKS,
`HOSIERY, BELTS, SCARVES,
`UNDERWEAR; HEADWEAR; AND
`FOOTWEAR
`
`35: RETAIL STORE SERVICES IN
`THE FIELDS OF CLOTHING,
`FOOTWEAR, HANDBAGS, SMALL
`LEATHER ACCESSORIES, AND
`TOILETRIES
`25: CLOTHING, NAMELY,
`DRESSES, SKIRTS, SUITS, JEANS,
`SWEATERS, SHIRTS, T-SHIRTS,
`TANK TOPS, JUMPERS, VESTS,
`SLEEPWEAR, ROBES, BLOUSES,
`PANTS, SHORTS, JACKETS, COATS
`
`ANN TAYLOR
`LOFT
`
`77/857,455 10/26/2009
`
`ANNTAYLOR
`LOFTMATERNITY
`
`3,455,810
`
`6/24/2008
`
`
`Registration Nos. 2,061,836, 2,334,051, 2,704,411 and 2,825,310 have become incontestable.
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`APPLICANT’S APPLICATION AND LACK OF RIGHTS
`
`
`5.
`
`On July 25, 2008, the Application filed by Applicant sought an extension of its
`
`International Registration No. 974,627 to the USPTO to register in the United States the mark
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`LOFT for “confectionery, namely, candy, chocolates, chocolate chips, fruit gums, chewing
`
`
` 24719/096/1186703.4
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`8
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`

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`Ref. No. 24719-096
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`gums, lollipops; chocolate products, namely, chocolate powder and chocolate syrup; pastries,
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`ice-cream; preparations for making the aforementioned products, namely, cocoa powder and
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`sugar” claiming a priority filing date of January 28, 2008.
`
`6.
`
`Upon information and belief, Applicant did not use prior to January 28, 2008 the
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`LOFT mark in U.S. commerce for some or all of the goods claimed in its Application.
`
`7.
`
`Upon information and belief, Applicant has never used prior to the date of this
`
`Amended Notice of Opposition the LOFT mark in U.S. commerce for some or all of the goods
`
`claimed in its Application.
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`8.
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`Upon information and belief, Applicant has not taken any steps prior to the date
`
`of this Amended Notice of Opposition to use or to license the use of the LOFT mark in U.S.
`
`commerce for some or all of the goods claimed in its Application.
`
`APPLICANT’S REPEATED AND CONTINUING HISTORY OF FAILING TO
`ESTABLISH RIGHTS
`
`9.
`
`Applicant has a history of first seeking or obtaining a registration of LOFT in the
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`USPTO based on non-U.S. rights and then failing to file any evidence that it has used the LOFT
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`mark in U.S. commerce.
`
`10.
`
`Upon information and belief, on November 29, 1990, Applicant previously filed
`
`in the USPTO an application, Serial No 74/119484, to register LOFT for “confectionery,
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`chewing gum for nonmedical purposes, chocolate, chocolate products, including pralines;
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`pastries” in Class 30 based on a German application, and on April 2, 1992, Applicant abandoned
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`that application in the USPTO by failing to respond to an office action.
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` 24719/096/1186703.4
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`9
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`

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`Ref. No. 24719-096
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`11.
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`Upon information and belief, Applicant had a previous registration in the USPTO,
`
`Registration No. 1,972,196 issued May 7, 1996, of LOFT for “candy” in Class 30 based on a
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`German registration, and that registration in the USPTO was cancelled on February 8, 2003 for
`
`failure to file a statement of use.
`
`12.
`
`Upon information and belief, Applicant had a previous registration in the USPTO,
`
`Registration No. 2,731,327 issued July 1, 2003, of LOFT for “candy, chocolate, chocolate
`
`candies and pastries” in Class 30 based on a German registration, and that registration in the
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`USPTO was cancelled on February 6, 2010 for failure to file a statement of use.
`
`APPLICANT’S FALSE STATEMENTS
`
`13.
`
`Upon information and belief, at the time Applicant requested that its International
`
`Application be extended to the United States resulting in the Application here in issue, Applicant
`
`made a statement to the effect that Applicant had a bona fide intention to use the mark on all of
`
`the goods claimed in its Application.
`
`14.
`
`Upon information and belief, at the time Applicant requested that its International
`
`Application be extended to the United States resulting in the Application here in issue, Applicant
`
`did not have a bona fide intention to use the LOFT mark in U.S. commerce for some or all of the
`
`goods claimed in its Application.
`
`15.
`
`Upon information and belief, in requesting that its International Application be
`
`extended to the United States resulting in the Application here in issue, Applicant made one or
`
`more false statements about Applicant’s intention to use the trademark LOFT in U.S. commerce
`
`for some or all of the goods claimed in its Application.
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` 24719/096/1186703.4
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`10
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`

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`Ref. No. 24719-096
`
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`16.
`
`Upon information and belief, in requesting that its International Application be
`
`extended to the United States resulting in the Application here in issue, Applicant committed
`
`fraud on the USPTO by making one or more false statements about Applicant’s intention to use
`
`the trademark LOFT in U.S. commerce for some or all of the goods claimed in its Application,
`
`and these were knowingly false statements of material fact with the intent to deceive the USPTO,
`
`and were made in reckless disregard of the truth or falsity of those statements.
`
`OPPOSER’S INJURY
`
`17.
`
`The tremendous amount of time, effort and money expended by Opposer to build
`
`up the LOFT brand name over the past years, and the phenomenal growth of that business,
`
`caused the LOFT Marks to become famous and distinctive of Opposer’s business since long
`
`prior to Applicant’s claimed priority filing date of January 28, 2008. Opposer would be injured
`
`by the granting of such registration because Applicant’s LOFT mark is likely to cause dilution
`
`by blurring or tarnishment of the distinctive significance and quality of the LOFT Marks that
`
`uniquely identify Opposer’s products and services in the United States.
`
`18.
`
`Applicant’s LOFT mark also is likely, when applied to the goods identified in the
`
`Application, to cause confusion, or to cause mistake or to deceive in that prospective consumers
`
`of Applicant’s goods and services naturally will believe that the goods originated, were approved
`
`or were sponsored by Opposer. Opposer would thereby be injured by the granting to Applicant
`
`of the registrations sought.
`
`
`
`WHEREFORE, Opposer, by its attorneys, respectfully requests that its opposition be
`
`sustained and that the Application be denied.
`
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` 24719/096/1186703.4
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`11
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`

`
`Ref. No. 24719-096
`
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`
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`Please recognize as attorneys for Opposer in this proceeding William M. Borchard,
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`Ronald W. Meister, Mary L. Kevlin and Maryann E. Licciardi (members of the bar of the State
`
`of New York) and the firm Cowan, Liebowitz & Latman, P.C., 1133 Avenue of the Americas,
`
`New York, New York 10036.
`
`
`
`Please address all communications to Ronald W. Meister, Esq. at the address listed
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`below.
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`Dated: New York, New York
`August 10, 2010
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`Respectfully submitted,
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`COWAN, LIEBOWITZ & LATMAN, P.C.
`Attorneys for Opposer
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`By:
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`/Maryann E. Licciardi/
`William M. Borchard
`Ronald W. Meister
`Mary L. Kevlin
`Maryann E. Licciardi
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`1133 Avenue of the Americas
`New York, New York 10036
`(212) 790-9200
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`Ref. No. 24719-096
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that, on August 10, 2010, I caused a true and complete copy of
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`the foregoing Amended Notice of Opposition to be sent via First Class Mail, postage prepaid, to
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`Applicant’s attorney and Correspondent of Record, addressed as follows:
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`Joseph F. Schmidt, Esq.
`Husch Blackwell Sanders Welsh & Katz
`120 South Riverside Plaza, 22nd Floor
`Chicago, IL 60606-3912
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`Dated: New York, New York
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`August 10, 2010
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`/Maryann E. Licciardi/
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` Maryann E. Licciardi
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`13