`ESTTA626719
`ESTTA Tracking number:
`09/11/2014
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`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91212364
`Plaintiff
`Target Brands, Inc. by assignment from Dermstore LLC
`JOHN M KIM AND RENEE A KEEN
`IP LEGAL ADVISORS PC
`4445 EASTGATE MALL, SUITE 200
`SAN DIEGO, CA 92121
`UNITED STATES
`negnatios@ipla.com
`Stipulated/Consent Motion to Extend
`Renee A. Keen
`rkeen@ipla.com
`/Renee A. Keen/
`09/11/2014
`2014-09-11 - Consent Motion to Extend Discovery and Trial Dates
`(JAPONESQUE).pdf(159939 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
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Opposition No. 91212364
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`Mark: BEAUTY FIXATION
`Serial No. 85027678
`Filing Date: April 30, 2010
`Published: July 16, 2013
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`Target Brands, Inc.,
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` Opposer,
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`Japonesque, LLC,
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` Applicant.
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`CONSENT MOTION TO EXTEND DISCOVERY AND TRIAL DATES
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`Opposer, Target Brands, Inc., through its counsel of record, hereby requests the
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`Trademark Trial and Appeal Board to extend the discovery and trial dates in the above-identified
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`proceeding by ninety (90) days, up to and including the dates set forth in the table below.
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`Action
`Initial Disclosures Due
`Expert Disclosures Due
`Discovery Closes
`Opposer’s Pretrial
`Opposer’s 30-day Trial
`Disclosures
`Applicant’s Pretrial
`Period Ends
`Applicant’s 30-day Trial
`Disclosures
`Opposer’s Rebuttal
`Period Ends
`Opposer’s 15-day Rebuttal
`Disclosures
`Period Ends
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`This motion is not for purposes of delay. The parties are actively engaged in settlement
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`Proposed Deadline
`12/11/2014
`04/09/2015
`05/09/2015
`06/23/2015
`08/07/2015
`08/22/2015
`10/06/2015
`10/21/2015
`11/20/2015
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`Current Deadline
`09/12/2014
`01/09/2015
`02/08/2015
`03/25/2015
`05/09/2015
`05/24/2015
`07/08/2015
`07/23/2015
`08/22/2015
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`discussions and require the additional time in order to try and reach an agreement. Counsel for
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`the respective parties discussed the need for the present ninety (90) day suspension, in light of
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`ongoing settlement discussions, via email correspondence on September 11, 2014. Opposer’s
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`counsel provided written consent to the present request on September 11, 2014.
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`Opposer respectfully requests that the Board grant the requested extension.
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`Dated: September 11, 2014
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`With consent hereby given.
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`/Renee A. Keen/
`_______________________________
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`John M. Kim
`jkim@ipla.com
`Renee A. Keen
`rkeen@ipla.com
`IP Legal Advisors, P.C.
`4445 Eastgate Mall, Suite 200
`San Diego, CA 92121
`Phone: (858) 272-0220
`Fax: (858) 272-0221
`Attorneys for Opposer, Target Brands, Inc.
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`/Romin P. Thomson/
`Romin P. Thomson
` rthomson@smwb.com
` Sweeney, Mason, Wilson & Bosomworth
` 983 University Avenue, Suite 104C
` Los Gatos, CA 95032-7637
` Attorneys for Applicant, Japonesque, Inc.
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`CERTIFICATE OF SERVICE
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`I hereby certify that on September 11, 2014 a copy of the foregoing was served by United
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`States mail to the address indicated below.
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`Romin P. Thomson
`Sweeney, Mason, Wilson & Bosomworth
`983 University Avenue, Suite 104C
`Los Gatos, CA 95032-7637
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`Dated: September 11, 2014
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`/Eunice Yu /
`_______________________________
`Eunice Yu
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`3
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