`
`ESTTA Tracking number:
`
`ESTTA786698
`
`Filing date:
`
`12/02/2016
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91230758
`
`Party
`
`Correspondence
`Address
`
`Defendant
`Picture Perfect Entertainment, Inc.
`
`Allan I. Zackler
`Wendel Rosen Black & Dean LLP
`1111 Broadway, 24th Floor
`Oakland, CA 94607
`
`Submission
`
`Filer's Name
`
`Filer's e-mail
`
`Signature
`
`Date
`
`Attachments
`
`tmdocket@wendel.com;azackler@wendel.com;rlogsdon@wendel.com
`
`Motion to Extend
`
`Allan Zackler
`
`tmdocket@wendel.com,azackler@wendel.com,rlogsdon@wendel.com
`
`/allan zackler/
`
`12/02/2016
`
`Motion for Extension of Time to Answer Opposition - Opposition
`91230758.pdf(89738 bytes )
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`Opposition No. 91230758
`
`Serial No. 86901410
`
`(MONSTERS OF THE FREEWAY)
`
`
`
`
` )
`Monster Energy Company )
`
`
` )
` Opposer,
` )
`
`
` )
`
`v.
` )
`
`
` )
`Picture Perfect Entertainment, Inc. )
`
`
` )
` Applicant.
` )
`
`
`
`
`MOTION FOR EXTENSION OF TIME TO ANSWER OPPOSITION
`
`
`The deadline to Answer is currently due on December 3, 2016. Picture Perfect Entertainment,
`Inc. (“Applicant”) requests that such date be extended for thirty (30) days, or until January 2,
`2017, and that all other dates be reset accordingly as listed 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
`
`
`
`1/2/2017
`
`2/1/2017
`
`2/1/2017
`
`3/3/2017
`
`7/1/2017
`
`7/31/2017
`
`9/14/2017
`
`10/29/2017
`
`11/13/2017
`
`12/28/2017
`
`1/12/2018
`
`2/11/2018
`
`
`
`Applicant requests this extension to give it sufficient time to respond to the opposition of
`Monster Energy Company (“Opposer”) and to determine whether the Opposer is engaging in
`unfair business practices in opposing the trademark application filed by Applicant. Although
`
`
`
`Applicant has requested through Opposer’s counsel approval to a continuance of the time to
`Answer, Applicant’s counsel has not yet received their concurrence.
`
`The undersigned hereby certifies that a copy of this paper has been served upon counsel for the
`Opposer, at counsel’s address of record, by First Class mail and email on this date.
`
`
`Dated: December 2, 2016
`
`Respectfully submitted,
`
`WENDEL ROSEN BLACK & DEAN LLP
`
`
`
`
`
`
`
`/Allan I. Zackler/
`Allan I. Zackler
`
`1111 Broadway, 24th Floor
`Oakland, CA 94607
`Telephone: 510-834-6600
`Email: azackler@wendel.com
`tmdocket@wendel.com
`
`Attorneys for Applicant
`Picture Perfect Entertainment, Inc.
`
`
`
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and complete copy of the foregoing MOTION FOR EXTENSION OF
`TIME TO ANSWER OPPOSITION WITH CONSENT has been served on Opposer Monster
`Energy Company by e-mailing said copy on December 2, 2016 to Opposer’s counsel of record
`identified below, to the email addresses listed below:
`
`
`
`Lynda Zadra-Symes
`Julianna M. Simon
`Knobbe Martens Olson & Bear LLP
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`Email:
`
`/Allan I. Zackler/
`Allan I. Zackler
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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