`ESTTA522740
`ESTTA Tracking number:
`02/21/2013
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91202898
`Plaintiff
`L'Oreal USA, Inc. and L'Oreal
`ROBERT L SHERMAN
`PAUL HASTINGS LLP
`75 EAST 55TH STREET
`NEW YORK, NY 10022
`UNITED STATES
`rls@paulhastings.com
`Other Motions/Papers
`Robert L. Sherman
`rls@paulhastings.com
`/Robert L. Sherman/
`02/21/2013
`Opposer's Pretrial Disclosure of Witnesses.pdf ( 4 pages )(120441 bytes )
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`Proceeding
`Party
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`Correspondence
`Address
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`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
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`
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the Matter of Application semi No. 35/270,272
`Published in the Official Gazette on August 2, 2011
`Mark: FOREAL FOREAL BY MIKI-IAIL
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`I
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`L’OREAL S.A. and L'C)REAL USA, I_NC.,
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`Opposer,
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`v.
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`'
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`Opposition No. 91202898
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`MIKHAIL LEVITIN T/A MIKI-IAIL
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`LEVITIN INSTITUTE,
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`1
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`Applicant.
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`OI°POSER’S PRETRIAL DISCLOSURE OF WITNESSES
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`Pursuant to Trademark Rule 2.121 (e), 37 C.F.R. 2.121 (e), and Rule 26(a) (3) of the Federal
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`Rules of Civil Procedure, Opposer L'Oréal SA. and L'Oréal USA, Inc. (collectively, “L'Oréal” or
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`-
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`“Opposer”) makes the following disclosures without waiving or intending to waive, but on the
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`contrary preserving and intending to preserve the right, at any time, to revise, correct, supplement,
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`clarify and/or amend the disclosures set forth herein as additional information and/or witnesses
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`become known or available.
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`The following individuals are expected to or may testify, either‘ by oral testimony or by
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`affidavit if the parties so stipulate in writing under Trademark Rule 2.123(b), 37 C.F.R. 2.123(b):
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`Lisa] Capparelli, Vice President, L’Oréal Paris, Integrated Marketing Communications.
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`Expected tesdmony and exhibits regarding the extent and nature of use, and intended use, of the
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`L’OREAL PARIS and L’OREAL marks; sales, advertising, marketing and promotion of the
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`LEGAL_Us_E # 1027366042
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`L’OREAL PARIS and L’OREAL marks; consumer awareness, marketplace presence and media
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`coverage of the L’OREAL PARIS and L’OREAL marks; fame of the L’OREAL PARIS and
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`L’OREALi marks; and-relatedness of L’Oréal’s goods and the goods for which Applicant has applied
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`to use its mark.
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`Mark B. Brooks, Vice President, Consumer Products Division, Consumer & Market
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`Intelligence. Expected testimony and exhibitsregarding the extent and nature of use, and intended
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`use, of the L’OREAL PARIS and L’OREAL marks; general market considerations -for the
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`L’OREAL PARIS and L’OREAL marks, including demographics of current and potential-
`consumers of L’OREAL PARIS and L’OREAI_, products, and market presence and image of
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`L’Oréal and its competitors; sales, advertising, and promotion of the L’OREAL PARIS and
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`L’OREAL marks; consumer awareness and perception of the L’OREAL PARIS and L’OREAL
`marks; fame of the L’OREAL PARIS and L’OREAL marks; and relatedness of L’Oréal’s goods and
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`the goods for which Applicant has applied to use its mark.
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`Manuel Manfredi, Mice President, L’Oréal Paris, Finance. Expected testimony and exhibits
`regarding the extent and nature of use, and intended use, of the IJOREAL PARIS and L’OREAI.
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`marks; sales, advertising, and promotion of the L’OREAL PARIS" and L’OREAL marks; consumer
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`awareness of the L’OREAL PARIS and L’OREAL marks; fame of the L’OREAL PARIS and
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`L’OREAL marks; financial information regarding the L’OREAL PARIS and L’OREAL marks; and
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`relatedness of L’Oré_:al’s goods and the goods foriwhich Applicant has applied to use its mark.
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`LEGAL_US_E # 1027366{)4.2
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`Each of the aforementioned individuals is employed by L’Oréal and has the following
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`address and telephone number:
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`"575 Fifth Avenue
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`New York, New York 10017-2450 2
`212-984-4000
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`1
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`Dated: February 21, 2013
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`Respectfully submitted,
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`PA
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`By:
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`HASTINGS LLP
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`fl
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`’
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`Robert L. Sherman
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`_
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`clad‘
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`75 East 55thAStreet
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`.
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`New York, NY 10022
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`(212) 318-6000
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`Attorneys for L’Oréal U.S.A., Inc. and L’Oréal S.A.
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`LEGAL_US_E # 1027366042
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and cornplete copy of Opposefs Pretrial
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`Disclosure of Witnesses has been served upon 1\/Iikhail Levitin, P.O. Box 102, Reeders, Pennsylvania
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`18352, by electronic transmission, as mutually agreed upon by the parties, and by depositing a true
`copy of the same with the U8. Postal Service, first—class mail, postagelprepaid, on February 21,
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`2013.
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`
`
`Edith Lopez
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`LEGAL_US_E # 102736604 2
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`_
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