Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA673434
`ESTTA Tracking number:
`05/20/2015
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`Notice of Opposition
`
`Notice is hereby given that the following party opposes registration of the indicated application.
`Opposer Information
`
`Name
`Granted to Date
`of previous ex-
`tension
`Address
`
`Forever, Inc.
`05/20/2015
`
`One PPG Place, 20th Floor
`Pittsburgh, PA 15222
`UNITED STATES
`
`Attorney informa-
`tion
`
`Rochelle D. Alpert
`Morgan, Lewis & Bockius LLP
`One Market, Spear Street Tower
`San Francisco, CA 94105
`UNITED STATES
`ralpert@morganlewis.com, shall@morganlewis.com, sftrade-
`marks@morganlewis.com Phone:415-442-1326
`Applicant Information
`
`Application No
`Opposition Filing
`Date
`Applicant
`
`86437660
`05/20/2015
`
`Publication date
`Opposition Peri-
`od Ends
`
`01/20/2015
`05/20/2015
`
`The FANROD Group
`247 W. 87th Street, Apt. 17F
`New York, NY 10024
`UNITED STATES
`Goods/Services Affected by Opposition
`
`Class 042. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Providing a website featuring non-
`downloadable software for uploading images and data to create personalized yearbooks;providing
`temporary use of online non-downloadable cloud computing software foruse in electronic storage of
`images/data
`
`Applicant Information
`
`Application No
`Opposition Filing
`Date
`Applicant
`
`86437648
`05/20/2015
`
`Publication date
`Opposition Peri-
`od Ends
`
`02/03/2015
`
`The FANROD Group
`247 W. 87th Street, Apt. 17F
`New York, NY 10024
`UNITED STATES
`
`

`
`Goods/Services Affected by Opposition
`
`Class 042. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Providing a website featuring non-
`downloadable software for uploading images and data to create personalized yearbooks;providing
`temporary use of online non-downloadable cloud computing software foruse in electronic storage of
`images/data
`
`Grounds for Opposition
`
`Priority and likelihood of confusion
`
`Trademark Act section 2(d)
`
`Marks Cited by Opposer as Basis for Opposition
`
`U.S. Registration
`No.
`Registration Date
`
`Word Mark
`Design Mark
`
`4598177
`
`09/02/2014
`
`FOREVER
`
`Application Date
`
`04/12/2013
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`Goods/Services
`
`The mark consists of the word FOREVER with a ring as the letter O.
`
`Class 009. First use: First Use: 2014/02/11 First Use In Commerce: 2014/02/11
`Downloadable computer software that allows for the storage, organization and
`sharing of electronic data and media by others
`Class 039. First use: First Use: 2013/11/22 First Use In Commerce: 2013/11/22
`Storage services for archiving documents, media and other electronic data
`Class 042. First use: First Use: 2013/11/22 First Use In Commerce: 2013/11/22
`Providing temporary use of online non-downloadable computer software for use
`inelectronic storage of data and media; conversion of data or documents from
`physical to electronic media
`
`U.S. Application/ Registra-
`tion No.
`Registration Date
`Word Mark
`
`Goods/Services
`
`NONE
`
`Application Date
`
`NONE
`
`NONE
`Forever trade name; Forever, Inc. corporate name; FOREVER.COM
`domain name; FOREVER mark; THE FOREVER GUARANTEE mark;
`FOREVER MEDIA SERVICES mark; 1-888-FOREVER mark;
`FOREVER LIVE! mark; FOREVER and design mark.
`As specified in the attached Notice of Opposition.
`
`Attachments
`
`85902473#TMSN.png( bytes )
`Consolidated Notice of Opposition (Exs A).pdf(512700 bytes )
`
`The undersigned hereby certifies that a copy of this paper has been served upon all parties, at their address
`record by First Class Mail on this date.
`
`Certificate of Service
`
`

`
`Signature
`Name
`Date
`
`/RDA/
`Rochelle D. Alpert
`05/20/2015
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of:
`
`Application Serial No. 86/437,660
`Filed October 28, 2014
`for the mark FOREVER CONNECTED
`
`Published in the OFFICIAL GAZETTE on January 20, 2015
`
`AND
`
`Application Serial No. 86/437,648
`Filed October 28, 2014
`for the mark FOREVER CONNECTED TECHNOLOGIES
`
`Published in the OFFICIAL GAZETTE on February 3, 2015
`
`Forever, Inc.,
`
`Opposition No.:
`
`Opposer,
`
`v.
`
`The FANROD Group,
`
`Applicant.
`
`CONSOLIDATED NOTICE OF OPPOSITION
`
`Forever, Inc. (“Opposer” or “Forever”), a Delaware corporation, having its principal
`
`place of business at One PPG Place, 20th Floor, Pittsburgh, Pennsylvania 15222, believes that it
`
`will be damaged by the applications of The FANROD Group (“Applicant”) to register the
`
`FOREVER CONNECTED designation through its intent-to—use application Serial No.
`
`86/437,660 and to register the FOREVER CONNECTED TECHNOLOGIES designation
`
`through its intent-to~use application Serial No. 86/437,648 (together, the “Opposed
`
`Applications”), and hereby opposes these applications.
`
`As grounds for the Consolidated Notice of Opposition, Forever alleges as follows:
`
`F0rever’s Trademark and Other Rights
`
`1.
`
`Under the Forever name, the FOREVER trademark, other FOREVER formative
`
`trademarks, the forever.com domain, the 1-888-FOREVER toll free number, and the registered
`
`1332/ 2591 11g7_1
`
`1
`
`Consolidated Notice of Opposition
`Ser1alNoS. 86/437,660 and 86/437,648
`
`

`
`FOREVER and Design mark, Forever offers and provides both a website and a mobile
`
`application with which users can upload, organize, access, search and share their own content,
`
`images and videos as well as content, images and videos of others. In connection with these
`
`products and services, Forever offers users additional services, including scanning, digital
`
`conversion, online storage and organization services.
`
`2.
`
`Since well before the October 28, 2014 filing date of the Opposed Applications,
`
`Forever has marketed, promoted and offered products through its www.forever.com website,
`
`where it uses the Forever trade name and trademark
`
`3.
`
`Forever has used the trade name Forever and the corporate name Forever, Inc. in
`
`connection with developing, promoting, marketing and/or offering its goods and services since
`
`before the October 28, 2014 filing date of the Opposed Applications. Forever also uses the
`
`1-888-FOREVER toll~free number for its services and also offers a FOREVER blog. Both have
`
`been in use before the filing of the Opposed Applications.
`
`4.
`
`Forever owns a valid, subsisting, uncancelled and unrevoked federal trademark
`
`registration for its FOREVER and Design mark (U.S. Reg. No. 4,598,177), which was filed on
`
`April 12, 2013 and registered on September 2, 2014, for “downloadable computer software that
`
`allows for the storage, organization and sharing of electronic data and media by others” in
`
`International Class 09, “Storage services for archiving documents, media and other electronic
`
`data” in International Class 39, and “Providing temporary use of online non—downloadable
`
`computer software for use in electronic storage of data and media; conversion of data or
`
`documents from physical to electronic media” in International Class 42. The mark has been used
`
`in commerce by Forever in connection with the goods identified in International Class 9 since at
`
`least as early as February 1 1, 2014, and in connection with the services identified in International
`
`Classes 39 and 42 since at least as early as November 22, 2013. A true and correct copy of the
`
`D132/25911137.]
`
`2
`
`Consolidated Notice of Opposition
`Serial Nos. 86/437,660 and 86/437,648
`
`

`
`TSDR and Assign Status pages for this mark from the USPTO web site are attached hereto as
`
`Exhibit A.
`
`5.
`
`Forever also has used other formatives of its registered FOREVER and design
`
`mark, including but not limited to FOREVER, THE FOREVER GUARANTEE, FOREVER
`
`MEDIA SERVICES, 1~888—FOREVER and FOREVER LIVE!.
`
`6.
`
`Forever has expended much time and effort in the development, marketing, and
`
`promotion of its products and services using its federally registered FOREVER and Design mark
`
`and other FOREVER marks, its Forever corporate name and trade name, and its forever.com
`
`domain name and its toll free 1-888-FOREVER.
`
`Agplicant’s Intent—t0—Use Trademark Applications
`
`7.
`
`On October 28, 2014, Applicant filed an intent-to-use application for the
`
`designation FOREVER CONNECTED, Serial No. 86/437,660, and filed an intent-to—use
`
`application for the designation FOREVER CONNECTED TECHNOLOGIES, Serial No.
`
`85/43 7,648. The Opposed Applications both cover the following services in International Class
`
`42: “Providing a website featuring non-downloadable software for uploading images and data to
`
`create personalized yearbooks; providing temporary use of online non-downloadable cloud
`
`computing software for use in electronic storage of images/data.”
`
`8.
`
`The October 28, 20l4 filing date of the Opposed Applications is well after the
`
`filing dates and first use of Forever’s FOREVER and Design mark and well after Forever’s
`
`corporate and trade name, domain name and common law trademark rights were first used and
`
`established.
`
`9.
`
`Applicant’s designation FOREVER CONNECTED was published for opposition
`
`in the Official Gazette on January 20, 2015 and App1icant’s designation FOREVER
`
`CONNECTED TECHNOLOGIES was published for opposition in the Official Gazette on
`
`D132/2591 1137.1
`
`3
`
`Consolidated Notice of Opposition
`Serial Nos. 86/437,660 and 86/437,648
`
`

`
`February 3, 2015
`
`10.
`
`The Trademark Trial and Appeal Board granted Opposer’s request to extend the
`
`opposition period for Applicant’s designation FOREVER CONNECTED through May 20, 2015
`
`and granted Opposer’s request to extend the opposition period for Applicant’s designation
`
`FOREVER CONNECTED TECHNOLOGIES through June 3, 2015. Thus, this Consolidated
`
`Notice of Opposition is timely filed.
`
`FIRST CAUSE OF ACTION
`
`(Likelihood of Confusion)
`
`l 1.
`
`Forever incorporates by reference and realleges as though fully set forth herein
`
`the allegations of paragraphs 1 through 10 of this Consolidated Notice of Opposition.
`
`12.
`
`The services set forth in the Opposed Applications on their face are competitive
`
`with, overlap with, and/or directly relate to the products and services Forever offers and sells
`
`under its federally registered FOREVER and Design mark, the FOREVER mark at common law,
`
`the Forever corporate and trade name, and the forever.com domain name. Further, on
`
`information and belief, the services listed in the Applications will be offered, promoted and/or
`
`are likely to be sold or offered for sale through the same or overlapping channels of trade and/or
`
`in the same geographic locations, will be used and/or are likely to be used by the same or
`
`overlapping users, and will be used and/or are likely to be directed to the same or overlapping
`
`type of customers to whom Forever markets, offers and sells its products and services, and
`
`intends to market, promote and sell its products and services using its federally registered
`
`FOREVER and Design mark, and FOREVER marks and names at common law.
`
`13.
`
`The opposed, applied-for designations are both confusingly similar in sight,
`
`sound, meaning and/or overall commercial impression to Forever’s federally registered
`
`FOREVER and Design mark, its FOREVER marks, its corporate and trade name, its domain
`
`name, and its toll free number. The dominant element of both of Applicant’s applied-for
`
`DB2/25911137,]
`
`4
`
`Consolidated Notice of Opposition
`Serial Nos. 86/437,660 and 86/437,648
`
`

`
`designations — “forever” — is identical in terms of sight, sound and meaning to Forever’s
`
`FOREVER and Design mark, its FOREVER marks at common law, the Forever corporate name,
`
`and trade name, the Forever domain name and the Forever toll free number. Indeed, the applied-
`
`for designations both fully incorporate Forever’s FOREVER mark and name.
`
`14.
`
`The designations covered by the Opposed Applications are likely to cause
`
`confusion, or to cause mistake or disparage or deceive by falsely suggesting a connection with
`
`Forever and the products and services for which Forever uses its FOREVER & Design and
`
`FOREVER marks, and the Forever corporate name, trade name and domain name, when there is
`
`no such connection.
`
`l5.
`
`Forever believes it will be damaged by registration of the applied-for FOREVER
`
`CONNECTED designation and the applied-for FOREVER CONNECTED TECHNOLOGIES
`
`designation in violation of Section 2(d) of the Lanham Act, l5 U.S.C. § 1052(d). Unless the
`
`Opposed Applications are denied, Forever will suffer injury as a result of the confusion and false
`
`association that is likely to arise from their registration.
`WHEREFORE, Forever prays that application Serial Nos. 86/437,660 and 86/437,648 be
`
`rejected, that no registrations be issued thereon to Applicant, and that this Consolidated Notice of
`
`Opposition be sustained in favor of Forever.
`
`DATE: May 20, 2015
`
`Respectfully submitted,
`
`By:
`
`/rda/
`Rochelle D. Alpert
`Attorney for Forever, Inc.
`
`Rochelle D. Alpert
`Stephanie L. Hall
`Morgan, Lewis & Bockius, LLP
`One Market, Spear Street Tower
`San Francisco, CA 94105
`Telephone: (415) 442-1326
`Facsimile: (415) 442-1001
`Email:
`ralpert@morganlewis.com
`shall@morganlewis.com
`
`D132/259111g7,1
`
`5
`
`Consolidated Notice of Opposition
`Serial Nos. 86/437,660 and 86/437,648
`
`

`
`EXHIBIT A
`
`to Consolidated Notice of Opposition
`(Serial Nos. 86/437,660 and 86/467,648)
`
`Forever, Inc. vs. The FANROD Groug
`Serial Nos.: 86/437,660 and 86/437,648
`Submitted by: Forever, Inc. (Opposer)
`
`DB2/ 2591 1 187.1
`
`

`
`Page 1 of 4
`
`STATUS
`
`DQCUMENTS
`
`A
`
`Back to Search
`
`3
`
`Print
`
`Generated on: This page was generated by TSDR on 2015—05-20 19:23:38 EDT
`
`Mark: FOREVER
`
`R E V E R
`
`US Serial Number: 85902473
`
`Application Filing Date: Apr. 12, 2t
`
`US Registration Number: 4598177
`
`Registration Date: Sep. 02, 2
`
`Register: Principal
`
`Mark Type: Trademark, Service Mark
`
`Status: Registered. The registration date is used to determine when post-registration maintenance dOCl
`
`Status Date: Sep. 02, 2014
`
`Publication Date: Sep. 10, 2013
`
`Notice of Allowance Date: Nov. 05, 2
`
`Mark information
`
`Mark Literal Elements: FOREVER
`it Standard Character Claim: No
`
`Mark Drawing Type: 3 — AN lLLUSTRATiON DRAWING WHICH INCLUDES WORD(S)/ LETTER(S)/NUMBER(S)
`
`Description of Mark: The mark consists of the word FOREVER with a ring as the letter O.
`
`Co|or(s) Claimed: Color is not claimed as a feature of the mark.
`
`Design Search Code(s): 26.01.02 - Circles, plain single line; Plain single line circles
`27.03.01 — Geometric figures forming letters, numerals or punctuation
`
`Related Properties Information
`
`international Registration
`Number:
`
`international Application A0046283
`
`(s) lRegistration(s) Based
`on this Property:
`
`Goods and Services
`
`Note:
`
`The following symbols indicate that the registrant/owner has amended the goods/services:
`~ Brackets [..] indicate deleted goods/services;
`- Double parenthesis ((,.)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and
`° Asterisks *..* identify additional (new) wording in the goods/services.
`
`E
`
`For: Downloadable computer software that allows for the storage, organization and sharing of electn
`
`international Class(es): O09 — Primary Class
`
`U.S C|ass(es): O21, 023,
`
`Class Status: ACTIVE
`
`

`
`Basis:
`
`1 (a)
`
`First Use:
`
`Feb. 11, 2014
`
`Page 2 of 4
`
`Use in Commerce: Feb. 11, 2
`
`For:
`
`Storage services for archiving documents, media and other electronic data
`
`International Class(es):
`
`039 - Primary Class
`
`U.S Class(es): 100, 105
`
`Class Status:
`
`ACTIVE
`
`Basis:
`
`1(a)
`
`First Use:
`
`Nov. 22, 2013
`
`Use in Commerce: Nov. 22, 2
`
`1
`
`For:
`
`Providing temporary use of online non—down|oadab|e computer software for use in electronic st<
`data or documents from physical to electronic media
`
`International Class(es):
`
`042 - Primary Class
`
`U.S Class(es): 100, 101
`
`Class Status:
`
`ACTlVE
`
`Basis:
`
`1(a)
`
`First Use:
`
`Nov. 22, 2013
`
`Basis information (Case Level)
`
`Filed Use:
`
`Filed ITU:
`
`Filed 44D:
`
`Filed 44E:
`
`Filed 66A:
`
`Filed No Basis:
`
`No
`
`Yes
`
`No
`
`No
`
`No
`
`No
`
`Current Owner(s) Information
`
`Owner Name:
`
`Forever, lnc.
`
`Owner Address:
`
`One PPG Place, 20th Floor
`
`Pittsburgh, PENNSYl_VANlA 15222
`UNITED STATES
`
`Legal Entity Type:
`
`CORPORATION
`
`Attorney/Correspondence information
`
`Use in Commerce: Nov. 22, 2
`
`Currently Use: Yes
`
`Currently ITU: No
`
`Currently 44D: No
`
`Currently 44E: No
`
`Currently 66A: No
`
`Currently No Basis: No
`
`State or Country Where DELAWAF
`Organized:
`
`Attorney of Record
`Attorney Name:
`
`(0
`
`Attorney Primary Email
`Address:
`
`Rochelle D. Alpert
`
`Docket Number: 061729—2(
`
`ralQert@morganlewis.com
`
`Attorney Email Authorized: Yes
`
`

`
`Page 3 of 4
`
`Correspondent
`
`Correspondent ROCHELLE D. ALPERT
`Name/Address: MORGAN, LEWIS & BOCKIUS LLP
`1 MARKET SPEAR STREET TOWER
`
`SAN FRANCISCO, CALIFORNIA 94105
`UNITED STATES
`
`Phone: 415-442-1329
`
`Fax: 415-4224
`
`Correspondent e-mail:
`
`raIpert@morganIewis.com
`
`Correspondent e-mail Yes
`Authorized:
`
`Domestic Representative - Not Found
`
`Prosecution History
`
`Date
`
`Sep. 02, 2014
`
`§Aug. 01, 2014
`
`IJUI. 31, 2014
`
`Uul. 30, 2014
`‘E
`
`§JuI. 08, 2014
`
`,JuI. 29,2014
`
`/
`
`giul. 08, 2014
`
`May 03,2014
`I
`
`;May 01,2014
`May 01, 2014
`
`May 01,2014
`
`1; Nov. 05, 2013
`7
`
`Isep. 10, 2013
`
`:Sep. 10,2013
`
`%Aug. 21, 2013
`I
`IAug, 21, 2013
`
`‘Jul. 30, 2013
`
`Description
`
`Proceeding Number
`
`REGISTEREDPRINCIPAL REGISTER
`
`NOTICE OF ACCEPTANCE OF
`STATEMENT OF USE E—MAILED
`ALLOWED PRINCIPAL REGISTER —
`sou ACCEPTED
`
`STATEMENT OF USE PROCESSING
`COMPLETE
`
`USE AMENDMENT FILED
`
`71034
`
`71034
`
`CASE ASSIGNED TO INTENT TO USE 71034
`
`PARALEGAL
`
`TEAS STATEMENT OF USE
`RECEIVED
`NOTICE OF APPROVAL OF
`EXTENSION REQUEST E—MAILED
`
`1
`
`EXTENSION 1 GRANTED
`EXTENSION 1 FILED
`
`98765
`98765
`
`TEAS EXTENSION RECEIVED
`
`NOA E—MAILED - SOU REQUIRED
`FROM APPLICANT
`
`OFFICIAL GAZETTE PUBLICATION
`CONFIRMATION E—MAILED
`PUBLISHED FOR OPPOSITION
`
`ASSIGNMENT OF OWNERSHIP NOT
`UPDATED AUTOMATICALLY
`NOTIFICATION OF NOTICE OF
`PUBLICATION E—MAILED
`
`APPROVED FOR PUB — PRINCIPAL
`REGISTER
`
`

`
`Jul. 29, 2013
`
`IApr. 19, 2013
`I
`
`§Apr. 18, 2013
`
`IApr. 16,2013
`~
`
`ASSIGNED TO EXAMINER
`
`81840
`
`NOTICE OF DESIGN SEARCH CODE E
`-MAILED
`
`NEW APPLICATION OFFICE
`SUPPLIED DATA ENTERED IN TRAM
`
`NEW APPLICATION ENTERED IN
`TRAM
`
`TM Staff and Location Information
`
`TM Staff Information - None
`
`File Location
`Current Location: PUBLICATION AND ISSUE SECTION
`
`Assignment Abstract Of Title Information -— Click to Load
`
`Proceedings - Click to Load
`
`Page 4 of 4
`
`Date in Location:
`
`Jul. 31, 20
`
`

`
`Page 1 of 1
`
`
`
`United States Patent and Trademark Office
`
`HomeI§ite IndexISearchIauidesICon'i:actsIeBusinessIe3iz
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`Assignments on the Web > Trademark Query
`
`Trademark Assignment Abstract of Title
`
`Total Assignments: 1
`Serial#:85902473 Filing Dt: 04/12/2013
`
`Reg #:4598177
`
`Reg. Dt: 09/02/2014
`
`Registrant: Forever, Inc.
`Mark: FOREVER
`
`Assignment: 1
`Reel/Frame: 509110877
`
`Conveyance: CHANGE OF NAME
`
`Assignor: FOREVER.COM INC.
`
`
`Assignee: FOREVER INC.
`
`ONE PPG PLACE, 20TH FLOOR
`PITTSBURGH, PENNSYLVANIA 15222
`
`Correspondent: ROCHELLE D. ALPERT
`ONE MARKET, SPEAR STREET TOWER
`
`SAN FRANCISCO, CA 94105
`
`Recorded: 08/15/2013
`
`Pages: 4
`
`Exec Dt: 08/08/2013
`Entity Type: CORPORATION
`
`Citizenship: DELAWARE
`
`Entity Type: CORPORATION
`
`Citizenship; DELAWARE
`
`If you have any comments or questions concerning the data dispiayed, contact PRD / Assignments at 571-272-3350. V125
`Web interface last modified: Juiy 25, 2014 v.2.5
`
`Search Results as of: 05/20/2015 07:29 PM
`
`I HOME I INDEXI SEARCH I eBUS|NESS I CONTACT US I PRIVACY STATEMENT
`
`

`
`PROOF OF SERVICE
`
`I am a resident of the State of California and over the age of eighteen years, and not a party
`to the within action; my business address is One Market, Spear Street Tower, San Francisco,
`CA 94105.
`
`On May 20, 2015, I served the within documents:
`
`CONSOLIDATED NOTICE OF OPPOSITION (Exhibit A) — Serial Nos. 86/437,660
`and 86/437,648
`
`(BY MAIL) I placed the sealed envelope(s) for collection and mailing by following the
`ordinary business practices of Morgan, Lewis & Bockius LLP, San Francisco, California.
`readily familiar with the firm’s practice for collecting and processing of correspondence for
`mailing with the United States Postal Service, said practice being that, in the ordinary course of
`business, correspondence with postage fully prepaid is deposited with the United States Postal
`Service the same day as it is placed for collection.
`
`I am
`
`(BY OVERNIGHT DELIVERY) I placed the sealed envelope(s) or package(s) designated by
`the express service carrier for collection and overnight delivery by following the ordinary
`business practices of Morgan, Lewis & Bockius LLP, San Francisco, California.
`I am readily
`familiar with the firm’s practice for collecting and processing of correspondence for overnight
`delivery, said practice being that, in the ordinary course of business, correspondence for
`overnight delivery is deposited with delivery fees paid or provided for at the carrier’s express
`service offices for next—day delivery the same day as the correspondence is placed for collection.
`
`(BY PERSONAL SERVICE) I caused t the document(s) listed above to be personally
`delivered to the person(s) at the address(es) set forth above (through Professional Messenger).
`
`(BY FACSIMILE) I caused the documents to be transmitted by facsimile machine at the time
`stated on the attached transmission report(s). The facsimile transmission(s) was reported as
`complete and without error.
`
`l_]
`
`D D
`
`E (E-MAIL) I transmitted via E-MAIL the document(s) listed above to the person(s) at the
`address(es) set forth below.
`
`PARTY SERVED
`
`I
`
`1
`
`A METHOD OF SERVICE
`
`Joseph P. Kincart
`Ideation Law PLLC
`PO BOX 936
`
`Vails Gate, New York 12584-0936
`
`.
`.
`.
`Via First Class Mail
`
`I declare under penalty of perjury,
`Executed on May 20, 2015, at San Francisco, California.
`under the laws of the United States of America, that the foregoing is true and correct.
`
`. [Mi
`
`Yele a Lolua
`
`DB2/ 2591 1 187.1