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Trademark Trial and Appeal Board Electronic Filing System. httgj/estta.usQto.gov
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`91205122
`
`Defendant
`Lila Natural Cosmetics Inc.
`
`DAVID M ANDERSEN
`BACAL LAW GROUP PC
`6991 E CAMELBACK RD, STE D—102
`SCOTTSDALE, AZ 85251
`UNITED STATES
`
`david.andersen@baca|group.com,jamie.tuccio@baca|group.com
`
`Motion to Suspend for Settlement Discussions
`David M. Andersen
`
`)
`
`david.andersen@baca|group.com,jamie.tuccio@baca|group.com
`/David M. Andersenl
`
`11/15/2013
`
`Joint Motion to Extend Time for Filing Answer with Good Cause.pdf(45104 bytes
`
`Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA571203
`ESTTA Tracking number:
`11/15/2013
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91205122
`Defendant
`Lila Natural Cosmetics Inc.
`DAVID M ANDERSEN
`BACAL LAW GROUP PC
`6991 E CAMELBACK RD, STE D-102
`SCOTTSDALE, AZ 85251
`UNITED STATES
`david.andersen@bacalgroup.com,jamie.tuccio@bacalgroup.com
`Motion to Suspend for Settlement Discussions
`David M. Andersen
`david.andersen@bacalgroup.com,jamie.tuccio@bacalgroup.com
`/David M. Andersen/
`11/15/2013
`Joint Motion to Extend Time for Filing Answer with Good Cause.pdf(45104 bytes
`)
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`

`
`
`
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`3M COMPANY,
`
`
` Opposition No. 91205122
`
`
`
` Opposer,
`
` Serial No.: 85/212,198
`
`v.
`
`LILA NATURAL COSMETICS, INC.,
`
` For the mark: SCOTCH NATURALS
`
` Filed: January 6, 2011
`
`
`
`
`Applicant.
`
` Published: November 15, 2011
`
`
`
`JOINT MOTION TO EXTEND TIME FOR FILING ANSWER FOR GOOD CAUSE
`
`3M Company (“3M”) and Lila Natural Cosmetics, Inc. (“LNC”) herby jointly move to
`
`suspend the time to file an answer along with all other discovery and trial deadlines in this matter
`
`by thirty (30) days pursuant to 37 CFR § 2.117 and TBMP § 510.
`
`
`
`In the Board’s November 8, 2013 Order, the Board required that the parties make a
`
`showing of good cause for any future motions to extend or suspend, including a status report of the
`
`parties’ settlement negotiations. Since the date of the parties’ last motion, the parties have
`
`continued to negotiate and finalize the terms of a proposed settlement agreement (the
`
`“Agreement”). The parties have exchanged multiple drafts of the Agreement over the last several
`
`months. The latest version of the settlement agreement was exchanged on November 13, 2013.
`
`Nearly all of the terms in the Agreement are resolved and the parties currently just have a
`
`couple of remaining items they are negotiating. Counsel for the parties last discussed these
`
`remaining items just today (November 15, 2013) and are now in the process of discussing these
`
`few remaining items with and getting feedback from their clients. The parties anticipate that
`
`
`60075 001 ck154302j3
`
`

`
`
`
`they will exchange a new draft of the settlement agreement within a week. The parties are
`
`hopeful that they can work out the details of these remaining items in a matter of weeks.
`
`Settlement discussions have been complicated in this matter by, among other things, the
`
`fact that several business units requiring approval are involved. Further, settlement between the
`
`parties also has been complicated by matters involving third-parties.
`
`The parties believe that an additional 30 days will be sufficient to negotiate and settle the
`
`outstanding issue and finalize the Agreement. As a result, the parties hereby move to suspend all
`
`remaining dates an additional 30 days based on the schedule outlined below.
`
`
`
`
`Time to Answer
`Deadline for Discovery Conference
`Discovery Opens
`
`
`
`Initial Disclosures Due
`
`
`Expert Disclosures Due
`
`
`Discovery Closes
`
`
`
`Plaintiff's Pretrial Disclosures
`
`Plaintiff's 30-day Trial Period Ends
`Defendant’s Pretrial Disclosures
`
`Defendant’s 30-day Trial Period Ends
`Plaintiff’s Rebuttal Disclosures
`
`Plaintiff’s 15-day Rebuttal Period Ends
`
`Respectfully submitted this 15th day of November, 2013.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`12/15/2013
`01/14/2014
`01/14/2014
`02/13/2014
`06/13/2014
`07/13/2014
`08/27/2014
`10/11/2014
`10/26/2014
`12/10/2014
`12/25/2014
`01/24/2015
`
`
`
`
`
`/s/ David M. Andersen
`David M. Andersen
`BACAL LAW GROUP, P.C.
`6991 E. Camelback Rd., Suite D-102
`Scottsdale, AZ 85251
`Phone: (480) 245-6230 ext. 102
`Email: david.andersen@bacalgroup.com
`Counsel for Applicant,
`Lila Natural Cosmetics Inc.
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Christopher M. Kindel
`Christopher M. Kindel
`PIRKEY BARBER PLLC
`600 Congress Avenue, Suite 2120
`Austin, Texas 78701-4078
`Phone: (512) 474-5201
`Email: CKindel@pirkeybarber.com
`Counsel for Opposer,
`3M Company
`
`By:
`
`
`
`
`
`
`
`
`
`60075 001 ck154302j3
`
`

`
`
`
`Certificate of Service Pursuant to 37 C.F.R. § 2.119
`
`Application No.:
`
`85/212,198
`
`Mark:
`
`Opposer:
`
`Applicant:
`
`SCOTCH NATURALS
`
`3M Company
`
`Lila Natural Cosmetics, Inc.
`
`Type of Filing:
`
`Joint Motion to Extend Time for Filing Answer for Good Cause
`
`I hereby certify that this Joint Motion to Extend Time for Filing Answer for Good Cause is
`
`being filed electronically with the United States Trademark Trial and Appeal board 37 C.F.R. §1.8.
`
`By mutual agreement of the parties, the foregoing also is being served electronically on
`
`counsel of record for the parties via email.
`
`/s/ David M. Andersen
`
`Signature
`
`
`
`Date
`
`November 15, 2013
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`60075 001 ck154302j3

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