`
`
`
`Juggling for Books
`
`Juggling Green
`
`Juggling For A Cure
`2309 Vera Avenue
`
`Cincinnati, OH 45237
`
`(513) 652-5574
`www.iugglingforacureorg
`
`info@iugglingforacureongg
`
`December 6, 2010
`
`United States Patent and Trademark Office
`
`Trademark Trial and Appeal Board
`P.O. Box 1451
`A
`4
`Alexandria, VA 22313-1451 ‘
`
`'
`
`To the Honorable Trademark Trial and Appeal Board,
`
`_
`4 Re: Proceeding No. 91 193784
`V
`(4
`’
`7 7 (7j '5 I
`
`2 S»;
`
`As required by the Board’s Scheduling Order of September 27, 2010, Applicant, Juggling For A
`
`Cure, makes the following initial disclosures under Fed. R. Civ. P. 26(a)(1)(A).
`
`(i)
`
`Juggling For A Cure likely to have discoverable information that Applicant may
`
`use to support its claim.
`
`Evidence that Juggling For A Cure has not hindered Opposer’s work
`
`Since Opposer’s initial opposition was filed, no evidence of Juggling For A Cure
`
`causing confusion, deception, or dilution of Opposer’s mark has surfaced in
`
`Cincinnati, Ohio, or elsewhere. No evidence of Juggling For A Cure slowing or
`
`hindering Opposer’s work has surfaced in Cincinnati, Ohio or elsewhere. Since
`
`no evidence has surfaced showing Juggling For A Cure causing any confusion,
`
`deception, dilution of Opposer’s mark, or slowing or hindering Opposer’s work in
`Cincinnati, Ohio,'the hometown and home base of Juggling For A Cure, it is
`
`reasonable to deduct that Juggling For A Cure is unlikely to cause any confusion,
`
`||||||||||l|||||||||1||||||||||l||||||l|||||||l|||
`
`12-09-2010
`
`Ll
`
`Patent
`
`43. T:“lC:V:rW Mail Pzpl Di WE
`
`
`
`deception, dilution of Opposer’s mark, or slowing or hindering of Opposer’s mark
`
`outside of the city of Cincinnati.
`
`(2)
`
`Juggling For A Cure added one of Opposer’s events to Juggling For a Cure’s web
`
`page, as it has done for many other charities. The purpose is to help make people
`
`aware of the great events put on by great charitable organizations, such as
`
`Opposer. Juggling For A Cure includes on its web page, the following statement:
`
`“Please note that Juggling For A Cure is not affiliated with Race for the Cure.”
`
`(3)
`
`Juggling For A Cure states on its web page that the company was founded in
`
`2008. This informs the public that Juggling For A Cure is a relatively new
`
`company, and therefore cannot be any company that is known to be a more older
`
`company.
`
`(4)
`
`We live in a big world. There is so much work to be done. There are so many
`
`people in need of help. Surely there is place for Juggling For A Cure’s work.
`
`Please allow Juggling For A Cure to continue to serve the people the company
`
`was meant to serve. If Juggling For A Cure reaches one person that you were
`
`unable to reach, than a good work was done. None of us can reach everyone,
`
`which is why we need to work together.
`
`Sin erely,
`
`Kér
`
`Ken Lewis
`
`Founder and President
`
`Juggling For A Cure
`
`
`
`Certificate of Service
`
`I hereby certify that on this 6”‘ day of December 201 O, a true and correct copy ofthe foregoing
`
`document was mailed on December 6, 2010 via U.S. First Class Mail postage prepaid on
`
`Opposition The Susan G. Komen Breast Cancer Foundation’s attorney, John M. Cone with
`
`Hitchcock Evert LLP, P.O. Box 131709, Dallas, TX 75313-1709.
`
`Kéér
`
`Ken Lewis,
`
`Founder and President,
`
`Juggling For A Cure
`
`December 6, 2010
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
