Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA389583
`ESTTA Tracking number:
`01/21/2011
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`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91196902
`Plaintiff
`Sparrow LLC
`JON M LEADER
`LEADER GORHAM LLP
`1990 S BUNDY DRIVE, SUITE 390
`LOS ANGELES, CA 90025
`UNITED STATES
`jleader@lglaw.la
`Other Motions/Papers
`Brenda Chavez
`bchavez@lglaw.la
`/Brenda Chavez/
`01/21/2011
`Initial Disclosures Opposition No. 91196902.pdf ( 5 pages )(35231 bytes )
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`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
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`ESTTA389583
`ESTTA Tracking number:
`01/21/2011
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91196902
`Plaintiff
`Sparrow LLC
`JON M LEADER
`LEADER GORHAM LLP
`1990 S BUNDY DRIVE, SUITE 390
`LOS ANGELES, CA 90025
`UNITED STATES
`jleader@lglaw.la
`Other Motions/Papers
`Brenda Chavez
`bchavez@lglaw.la
`/Brenda Chavez/
`01/21/2011
`Initial Disclosures Opposition No. 91196902.pdf ( 5 pages )(35231 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`
`
`Jon M. Leader
`Brenda Chavez
`LEADER GORHAM LLP
`1990 South Bundy Drive, Suite 390
`Los Angeles, CA 90025
`Telephone: (310) 696-3300
`Facsimile: (310) 696-3305
`
`Attorneys for Sparrow LLC
`
`Opposed Mark: LOVE N LIFE
`U.S. Trademark Application Serial Number: 77825285
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`
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Opposition No.: 91196902
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`SPARROW LLC
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`Opposer,
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`vs.
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`JONATHAN FITCH,
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`Applicant.
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`OPPOSER’S INITIAL DISCLOSURES
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`Sparrow LLC (hereinafter referred to as “Opposer”), makes these initial disclosures as
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`required by Federal Rules of Civil Procedure 26(a)(1) and the Trademark Trial and Appeal
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`Board’s Order dated October 14, 2010. These Disclosures are based upon the information
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`reasonably available to the Opposer at this time. Opposer reserves the right to supplement or
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`amend these Disclosures and to use documents or rely on testimony not described herein as
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`additional information becomes available, as discovery and trial preparation progresses, and as
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`issued in this case develop and are clarified.
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`A. Individuals With Discoverable Information.
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`The names, addresses, and telephone numbers of individuals likely to have discoverable
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`information that the disclosing party may use to support its claims or defenses, unless solely for
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`impeachment, identifying the subjects of the information;
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`Opposer’s selection and use of the LIFE NATURE LOVE trademark:
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`Barbara Garduno
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`Sparrow LLC
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`6608 Lexington Avenue
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`Los Angeles, CA 90038
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`(323) 580-8855
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`Mr. Fitch’s selection and intended use of the LOVE N LIFE trademark:
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`Mr. Jonathan Fitch
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`14764 Via Sorrento Drive
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`Charlotte, NC 28277
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`(704) 222-6098
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`B.
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`Relevant Documents and Tangible Things.
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`A copy of, or a description by category and location of, all documents, data
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`compilations, and tangible things that are in the possession, custody, or control of the party and
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`that the disclosing party may use to support its claims or defenses, unless solely for
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`impeachment;
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`Response:
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`All documents, data compilations, and tangible things that are in the possession,
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`custody, or control of Opposer are located at its principal place of business, 6608 Lexington
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`Avenue, Los Angeles, CA 90038, including documents, data compilations and tangible things
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`related to Opposer’s selection and use of the LIFE NATURE LOVE trademark. Documents that
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`may be used to support Opposer’s claims and defenses in this matter will be made available for
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`inspection and copying at a mutually convenient time and location subject to any appropriate
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`objections and privileges applicable thereto.
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`Notwithstanding the foregoing, Opposer notes that certain documents related to
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`Opposer’s use of the LIFE NATURE LOVE trademark are publicly available. For example, the
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`file history for U.S. Trademark Application Serial No. 78203204, which matured into U.S.
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`Trademark Registration No. 2856929 for the LIFE NATURE LOVE trademark, is publicly
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`available at the U.S. Patent and Trademark Office’s official website.
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`C. Information Related to Calculation of Damages.
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`A computation of any category of damages claimed by the disclosing party, making
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`available for inspection and copying as under Rule 34 the documents or other evidentiary
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`material, not privileged or protected from disclosure, on which such computation is based,
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`including materials bearing on the nature and extent of injuries suffered;
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`Response:
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`In accordance with TBMP Section 502.05, damages are not available in a proceeding
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`before the Trademark Trial and Appeal Board. Therefore, documents related to damages are not
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`relevant to this opposition proceeding.
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`D. Insurance.
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`For inspection and copying as under Rule 34 of any insurance agreement under which
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`any person carrying on an insurance business may be liable to satisfy part of or all of a judgment
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`which may be entered in the action, or to indemnify or reimburse for payments made to satisfy
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`the judgment;
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`Response:
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`None.
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`DATED: January 21, 2010
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`Respectfully submitted,
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`______
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`Brenda Chavez
`Attorneys for Opposer
`Sparrow LLC
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the foregoing
`OPPOSER'S INITIAL DISCLOSURES was served upon Applicant Jonathan Fitch at the
`address and by the method(s) indicated below:
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`Mr. Jonathan Fitch
`14764 Via Sorrento Drive
`Charlotte, NC 28277
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`On this -.1.L day of January, 2011
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`_ Hand Delivery
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`l
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`United State Mail
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`_ Overnight Delivery
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`Facsimile Transmission
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`Electronic Email
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`Thao Vu
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