Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA899569
`05/29/2018
`
`ESTTA Tracking number:
`
`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
`
`McDonald's Corporation
`
`Granted to Date
`of previous ex-
`tension
`
`Address
`
`Attorney informa-
`tion
`
`05/27/2018
`
`111 North Carpenter Street
`Chicago, IL 60607-2101
`UNITED STATES
`
`John A. Cullis
`Reed Smith LLP
`10 South Wacker Drive, 40th Floor
`Chicago, IL 60606
`UNITED STATES
`Email: ipdocket-chi@reedsmith.com, rsMcDonaldsTMTeam@ReedSmith.com,
`mbenson@reedsmith.com
`Phone: 312-207-1000
`
`Applicant Information
`
`Application No
`
`87543877
`
`Publication date
`
`11/28/2017
`
`Opposition Filing
`Date
`
`Applicant
`
`05/29/2018
`
`Opposition Peri-
`od Ends
`
`05/27/2018
`
`Lee H. Skolnick
`75 Broad Street, Suite 2700
`New York, NY 10004
`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: Architectural consultation; Architectural
`design; Architectural research; Architectural services
`
`Grounds for Opposition
`
`Priority and likelihood of confusion
`
`Trademark Act Section 2(d)
`
`Dilution by blurring
`
`Trademark Act Sections 2 and 43(c)
`
`Marks Cited by Opposer as Basis for Opposition
`
`U.S. Registration
`No.
`
`1947099
`
`Registration Date
`
`01/09/1996
`
`Application Date
`
`08/08/1991
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MC
`
`NONE
`
`Class 042. First use: First Use: 1995/06/14 First Use In Commerce: 1995/06/14
`restaurant services
`
`U.S. Registration
`No.
`
`1352168
`
`Registration Date
`
`07/30/1985
`
`Word Mark
`
`Design Mark
`
`MC DONALD'S
`
`Application Date
`
`05/23/1983
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 042. First use: First Use: 1968/12/31 First Use In Commerce: 1968/12/31
`RESTAURANT SERVICES
`
`U.S. Registration
`No.
`
`1426681
`
`Registration Date
`
`01/27/1987
`
`Application Date
`
`09/30/1982
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MCDONALDS
`
`NONE
`
`Class 029. First use: First Use: 1948/00/00 First Use In Commerce: 1953/05/00
`CHICKEN, HASHBROWN POTOTOES, PREPARED EGGS, MILK, FRESH
`GARDEN SALADS AND PROCESSED INGREDIENTS THEREOF, FOR CON-
`SUMPTION ON OR OFF THE PREMISES
`Class 030. First use: First Use: 1948/00/00 First Use In Commerce: 1953/05/00
`HAMBURGER AND CHEESEBURGER SANDWICHES AND SPECIAL COM-
`BINATION SANDWICHES FEATURING HAMBURGERS AND CHEESEBUR-
`GERS, [ ROAST BEEF SANDWICHES, HOT CHOCOLATE, PREPARED CAT-
`SUP, COOKIES, ] HOTCAKES, TABLE SYRUP, FRUIT PIES, SPECIAL COM-
`BINATION EGGSANDWICHES, TEA, [ COFFEE, SOFT SERVE ICE CREAM
`OR ICE CREAM SUBSTITUTE, ICE CREAM OR ICE CREAM SUBSTITUTE
`SUNDAES, SOFT SERVE ICE MILK, SOFT SERVE ICE MILK SUNDAES,
`DONUTS, ] PASTRIES, CHICKEN SANDWICHES, PORK SANDWICHES, [
`BISCUIT AND HAM SANDWICHES ] AND BISCUIT AND SAUSAGE SAND-
`WICHES FOR CONSUMPTION ON OR OFF THE PREMISES
`Class 032. First use: First Use: 1948/00/00 First Use In Commerce: 1953/00/00
`CARBONATED AND NON-CARBONATED SOFT DRINKS [ AND FRUIT
`JUICES ] FOR CONSUMPTION ON OR OFF THE PREMISES
`
`U.S. Registration
`No.
`
`1113227
`
`Application Date
`
`10/17/1977
`
`

`

`Registration Date
`
`02/13/1979
`
`Word Mark
`
`Design Mark
`
`MCDONALD'S
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 028. First use: First Use: 1976/08/15 First Use In Commerce: 1976/08/15
`TOYS
`
`U.S. Registration
`No.
`
`1440655
`
`Registration Date
`
`05/26/1987
`
`Application Date
`
`09/30/1982
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MCDONALDS
`
`NONE
`
`Class 025. First use: First Use: 1973/09/00 First Use In Commerce: 1973/09/00
`MEN'S CLOTHING, WOMEN'S CLOTHING AND CHILDREN'S CLOTHING,
`NAMELY, T-SHIRTS, [ NIGHT SHIRTS, ] HATS, [ SWEATERS ][, SHORTS, ]
`ATHLETIC SHIRTS, [ VESTS, ] SWEAT SHIRTS AND JERSEYS
`
`U.S. Registration
`No.
`
`2399953
`
`Registration Date
`
`10/31/2000
`
`Word Mark
`
`Design Mark
`
`MCDONALD'S
`
`Application Date
`
`10/26/1999
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 025. First use: First Use: 1968/10/00 First Use In Commerce: 1968/11/00
`Men's, women's and children's clothing,namely, coats, jackets, shirts, ties, visors
`and scarves
`
`U.S. Registration
`No.
`
`2482828
`
`Registration Date
`
`08/28/2001
`
`Application Date
`
`06/19/1998
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MCCAFE
`
`NONE
`
`Class 042. First use: First Use: 2001/05/02 First Use In Commerce: 2001/05/02
`restaurant services
`
`U.S. Registration
`No.
`
`3201441
`
`Registration Date
`
`01/23/2007
`
`Word Mark
`
`Design Mark
`
`MCCAFE
`
`Application Date
`
`03/02/2006
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 030. First use: First Use: 2001/05/02 First Use In Commerce: 2001/05/02
`BEVERAGES MADE OF COFFEE BEANS, HOT CHOCOLATE, PASTRIES,
`MUFFINS, CAKES, COOKIES, BISCUITS AND SANDWICHES
`
`U.S. Registration
`No.
`
`1266500
`
`Registration Date
`
`02/07/1984
`
`Application Date
`
`06/21/1982
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MC DOUBLE
`
`NONE
`
`Class 030. First use: First Use: 1977/06/30 First Use In Commerce: 1977/09/30
`a Sandwich for Consumption On or Off Premises
`
`U.S. Registration
`No.
`
`1315979
`
`Registration Date
`
`01/22/1985
`
`Application Date
`
`06/11/1982
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MCRIB
`
`NONE
`
`Class 030. First use: First Use: 1981/06/30 First Use In Commerce: 1981/06/30
`a Sandwich for Consumption On or Off the Premises
`
`

`

`U.S. Registration
`No.
`
`1369360
`
`Registration Date
`
`11/05/1985
`
`Application Date
`
`02/13/1984
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MCMUFFIN
`
`NONE
`
`Class 030. First use: First Use: 1983/05/00 First Use In Commerce: 1983/05/00
`BREAKFAST FOOD COMBINATION SANDWICH FORCONSUMPTION ON OR
`OFF THE PREMISES
`
`U.S. Registration
`No.
`
`4071074
`
`Registration Date
`
`12/13/2011
`
`Word Mark
`
`Design Mark
`
`MCNUGGET
`
`Application Date
`
`09/09/2009
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 029. First use: First Use: 2011/05/31 First Use In Commerce: 2011/05/31
`PRODUCTS MADE OF POULTRY
`
`U.S. Registration
`No.
`
`2678272
`
`Registration Date
`
`01/21/2003
`
`Application Date
`
`03/15/2002
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MCGRIDDLES
`
`NONE
`
`Class 030. First use: First Use: 2000/10/00 First Use In Commerce: 2000/10/00
`SANDWICHES CONSISTING OF HOT CAKES, BEEF, CHICKEN, PORK, AND
`EGG AND CHEESE PRODUCTS
`
`U.S. Registration
`No.
`
`2056279
`
`Registration Date
`
`04/22/1997
`
`Word Mark
`
`Design Mark
`
`MCDIRECT SHARES
`
`Application Date
`
`09/28/1995
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 036. First use: First Use: 1995/11/06 First Use In Commerce: 1995/11/06
`financial services, namely providing a direct company stock purchase plan
`
`U.S. Registration
`No.
`
`2684782
`
`Registration Date
`
`02/04/2003
`
`Application Date
`
`09/12/2001
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MCTEACHER'S NIGHT
`
`NONE
`
`Class 036. First use: First Use: 2001/11/15 First Use In Commerce: 2001/11/15
`CHARITABLE FUNDRAISING
`
`U.S. Registration
`No.
`
`4451381
`
`Registration Date
`
`12/17/2013
`
`Word Mark
`
`Design Mark
`
`MCPLAY
`
`Application Date
`
`05/06/2013
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`Attachments
`
`NONE
`
`Class 009. First use: First Use: 2013/05/01 First Use In Commerce: 2013/05/01
`Downloadable computer games
`
`73426936#TMSN.png( bytes )
`73145437#TMSN.png( bytes )
`75832321#TMSN.png( bytes )
`78827670#TMSN.png( bytes )
`77822521#TMSN.png( bytes )
`85924012#TMSN.png( bytes )
`Notice_of_Opposition_McRanchions.pdf(27172 bytes )
`
`Signature
`
`Name
`
`Date
`
`/John A. Cullis/
`
`John A. Cullis
`
`05/29/2018
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`In the Matter of:
`Application Serial No. 87/543,877
`
`Published in the Official Gazette
`on November 28, 2017
`
`
`McDONALD’S CORPORATION,
`
`
`
`
`
`Opposer,
`
`v.
`
`LEE H. SKOLNICK, an individual,
`
`
`
`
`
`Mark: McRanchions
`
`Opposition No.: __________________
`
`
`
`Applicant.
`
`
`
`
`
`
`
`NOTICE OF OPPOSITION
`
`Opposer, McDonald’s Corporation, a corporation organized and existing under the laws
`
`of the State of Delaware, with offices at 111 North Carpenter Street, Chicago, Illinois 60607-
`
`2101, believes that it will be damaged by registration of the mark McRanchions in International
`
`Class 42, as shown in Application Serial No. 87/543,877 filed by Applicant, Lee H. Skolnick, an
`
`individual, with a mailing address of 75 Broad Street, Suite 2700, New York, New York 10004,
`
`and hereby opposes the same and requests that registration to Applicant be refused.
`
`The grounds for this Notice of Opposition are as follows:
`
`1.
`
`Applicant seeks
`
`to
`
`register
`
`the mark McRanchions
`
`for “Architectural
`
`consultation; Architectural design; Architectural
`
`research; Architectural services,”
`
`in
`
`International Class 42. The application is an intent to use application filed under 15 U.S.C.
`
`§ 1051(b).
`
`

`

`2.
`
`Upon information and belief, Applicant is purposefully attempting to use the
`
`McRanchions mark to draw an association with McDonald’s famous family of “Mc” formative
`
`marks. In an effort to draw such an association, Applicant is quoted in several publications
`
`comparing the applied for mark, McRanchions, and the term “McMansions.” In one such article
`
`that Applicant authored for The East Hampton Star entitled “The Invasion of the McRanchions,”
`
`not only does Applicant make several references to the term McMansions, but he also describes
`
`this term to mean a style of home that is as “ubiquitous as fast-food restaurants.” Applicant’s
`
`comparison of the “Mc” formative McMansions mark to fast-food restaurants is a reference to
`
`the prevalence of both McDonald’s restaurants and a common house design. Moreover,
`
`Applicant’s article also makes a direct connection between “McMansions” and the applied for
`
`McRanchions mark, calling McMansions the “distant cousin” of McRanchions. By drawing this
`
`comparison between the McRanchions and McMansions marks, and also referencing a
`
`connection to fast food restaurants, Applicant is purposefully attempting to associate the
`
`McRanchions mark with McDonald’s famous family of “Mc” formative marks.
`
`3.
`
`4.
`
`This Notice of Opposition is being timely submitted.
`
`Since 1955, Opposer has been in the business of developing, operating,
`
`franchising, and servicing an extensive system of restaurants that prepare, package, and sell a
`
`wide variety of high quality, quickly-prepared, modestly-priced foods. Opposer has carried on
`
`this business in the United States and throughout the world. Opposer and its subsidiaries now
`
`operate or license thousands of restaurants throughout the world, including over 14,000
`
`restaurants in the United States.
`
`5.
`
`In connection with this business, Opposer has, for decades, extensively used its
`
`“Mc” family of marks, which includes the “Mc” formatives used with various generic or
`
` 2
`
`
`
`

`

`descriptive terms as trademarks and service marks in advertising, promoting, and selling a wide
`
`variety of food products and restaurant services. Opposer has also used its family of “Mc”
`
`formative marks on a wide variety of goods and services that are not food products or restaurant
`
`services, including, without limitation: men’s, women’s, and children’s clothing; chemical
`
`preparations; concentrated cleaners; computer services; barbershop services; mail order services;
`
`educational services; and charitable services.
`
`6.
`
`Opposer’s extensive advertising and promotion of its various goods and
`
`services under its family of “Mc” formative marks features the use of television and print
`
`advertising, radio, newspaper and magazine advertising, outdoor billboard and signage, Internet
`
`advertising, mobile advertising and direct mail, which are directed to and reach the public in both
`
`local and nationwide markets. In addition, Opposer uses its “Mc” formative family of marks on
`
`food product packaging and point-of-purchase advertising.
`
`7.
`
`Opposer owns numerous federal registrations for its family of “Mc” marks.
`
`These registrations include, but are not limited to, the following:
`
`MARK NAME
`
`REG. NO.
`
`REG. DATE
`
`GOODS/SERVICES
`
`1. Mc
`
`1,947,099
`
`01/09/1996
`
`Restaurant services
`
`2. McDONALD’S
`
`1,352,168
`
`07/30/1985
`
`Restaurant services
`
`3. McDONALD’S
`
`1,426,681
`
`01/27/1987
`
`Hamburger and cheeseburger
`sandwiches and special
`combination sandwiches featuring
`hamburgers and cheeseburgers
`
`4. McDONALD’S
`
`1,113,227
`
`02/13/1979
`
`Toys
`
` 3
`
`
`
`

`

`MARK NAME
`
`REG. NO.
`
`REG. DATE
`
`GOODS/SERVICES
`
`5. McDONALD’S
`
`1,440,655
`
`05/26/1987
`
`6. McDONALD’S
`
`2,399,953
`
`10/31/2000
`
`Men’s clothing, women’s clothing,
`and children’s clothing, namely, t-
`shirts, hats, shorts, athletic shirts,
`sweat shirts and jerseys
`
`Men’s, women’s and children’s
`clothing, namely, coats, jackets,
`shirts, ties, visors, and scarves
`
`7. McCAFE
`
`2,482,828
`
`08/28/2001
`
`Restaurant services
`
`8. McCAFE
`
`3,201,441
`
`01/23/2007
`
`9. McDOUBLE
`
`1,266,500
`
`02/07/1984
`
`10. McRIB
`
`1,315,979
`
`01/22/1985
`
`11. McMUFFIN
`
`1,369,360
`
`11/05/1985
`
`Beverages made of coffee,
`pastries, muffins, cakes, cookies,
`biscuits, and sandwiches
`
`A sandwich for consumption on or
`off premises
`
`A sandwich for consumption on or
`off premises
`
`Breakfast food combination
`sandwich
`
`12. McNUGGET
`
`4,071,074
`
`12/13/2011
`
`Products made of poultry
`
`13. McGRIDDLES
`
`2,678,272
`
`01/21/2003 Hot cakes
`
`14. McDIRECT SHARES
`
`2,056,279
`
`04/22/1997
`
`Financial services, namely,
`providing a direct company stock
`purchase plan
`
`15. McTEACHER’S NIGHT
`
`2,684,782
`
`02/04/2003
`
`Charitable fundraising
`
`16. McPLAY
`
`4,451,381
`
`12/17/2013 Downloadable computer games
`
`
`
`8.
`
`All of these registrations are valid, subsisting, and in full force and effect.
`
`Furthermore, Opposer has used these marks in association with their respective designated goods
`
`and services prior to July 26, 2017, the application date of Applicant’s McRanchions mark.
`
` 4
`
`
`
`

`

`9.
`
`Each of the aforesaid registrations is at least prima facie evidence of the validity
`
`of each registration, of Opposer’s ownership thereof, and of Opposer’s exclusive right to use
`
`such registered marks on the goods or services set forth in the registrations.
`
`10.
`
`Through Opposer’s
`
`extensive
`
`and
`
`continuous
`
`use
`
`of
`
`the
`
`name
`
`McDONALD’S, and its “Mc” formative marks, the public has come to recognize the marks
`
`combining the “Mc” prefix with a common word for a wide variety of goods and
`
`services as being uniquely associated with Opposer. Opposer has developed, at great effort
`
`and expense, exceedingly valuable goodwill with respect to the specific marks listed above, as
`
`well as for its entire “Mc” family of marks. Opposer’s “Mc” family of marks is famous and
`
`was famous long prior to the application date of Applicant’s subject application.
`
`11.
`
`Both the Trademark Trial and Appeal Board and the Federal Circuit have long
`
`recognized the validity of Opposer’s rights to its famous “Mc” family of marks. McDonald’s
`
`Corp. v. McClain, 37 U.S.P.Q. 2d 1274, 1276 (TTAB 1995) (“The family of [McDonald’s]
`
`marks has been recognized by this Board and by the courts”); McDonald’s Corp. v. McKinley, 13
`
`U.S.P.Q. 2d 1895, 1899 (TTAB 1989) (“In view of opposer’s extensive evidence of use and
`
`promotion of marks having a “Mc” or “Mac” portion, there can be no doubt that opposer has
`
`established that its marks comprise a family”); McDonald’s Corp. v. McSweet, LLC, 112
`
`U.S.P.Q. 2d 1268, 2014 WL 5282256 at *7 (TTAB 2014) (“Based on the record before us, . . .
`
`Opposer has established that, based on its use and promotion of its family of marks, Opposer
`
`continues to own a family of marks consisting of the prefix ‘MC’ combined either with a generic
`
`term or a descriptive term.”); McDonald’s Corp. v. McBagel’s, Inc., 649 F. Supp. 1268, 1272
`
`(S.D.N.Y. 1986) (showing no hesitation in finding that McDonald’s “owns a ‘family of marks’
`
`both registered and unregistered, whose common characteristic is the use of ‘Mc’ or ‘Mac’ as a
`
` 5
`
`
`
`

`

`formative”); J&J Snack Foods Corp. v. McDonald’s Corp., 932 F.2d 1460, 1463 (Fed. Cir.
`
`1991) (recognizing “McDonald’s specific family of marks wherein the prefix “Mc” is used with
`
`generic food names to create fanciful words.”).
`
`12.
`
`Despite Opposer’s long-standing prior rights in the name McDONALD’S and its
`
`“Mc” family of marks for restaurant services, food products, and a wide variety of other goods
`
`and services, on July 26, 2017, Applicant filed its application to register the McRanchions mark
`
`for “Architectural consultation; Architectural design; Architectural research; Architectural
`
`services,” in International Class 42. Moreover, in light of Opposer’s widespread advertising and
`
`promotion of its “Mc” formative marks, Applicant’s selection and use of the McRanchions mark,
`
`which incorporates the “Mc” prefix followed by the common word “ranchions,” a coined term
`
`for ranch-style mansions, suggests that Applicant intends to trade off the goodwill and
`
`recognition associated with Opposer’s trademarks.
`
`13.
`
`The mark proposed for registration by Applicant has as its principal distinctive
`
`element the “Mc” prefix, which is followed by a common word. Potential purchasers, upon
`
`seeing the dominant formative “Mc” in Applicant’s McRanchions mark, are likely to mistakenly
`
`believe that the services offered thereunder originated or are connected with, or are sponsored,
`
`licensed or approved by, Opposer. Thus, the registration and use by Applicant of the
`
`McRanchions mark in connection with its services, for all channels of trade and all types of
`
`prospective purchasers, is likely to cause confusion, mistake, or deception in violation of 15
`
`U.S.C. § 1052(d).
`
`14.
`
`Issuance of a registration to Applicant will also diminish and dilute the
`
`distinctive quality of Opposer’s rights in the name McDONALD’S, and its famous family of
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`“Mc” marks, and will blur and otherwise impair the distinctiveness of these marks in violation of
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`15 U.S.C. § 1125(c).
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`15.
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`If a registration is issued to Applicant for Applicant’s McRanchions mark, the
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`confusion with Opposer’s marks would result in damage and injury to Opposer and the public.
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`Registration of the McRanchions mark would also give Applicant an unqualified right to
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`wrongfully appropriate Opposer’s valuable goodwill and reputation associated with Opposer’s
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`marks; to benefit from the likely confusion among purchasers led to believe that Applicant’s
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`services are related in some fashion to Opposer; to dilute the distinctiveness of Opposer’s marks
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`and harm its goodwill and reputation associated with its marks; to tarnish Opposer’s good name
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`by offering services not subject to Opposer’s quality controls; and to restrict the natural growth
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`of Opposer’s “Mc” family of marks.
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`WHEREFORE, Opposer requests that this Opposition be sustained and Application
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`Serial No. 87/543,877 be refused registration.
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`The requisite filing fee of $400.00 and any additional fees related to this matter are being
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`charged to a MasterCard credit card concurrently with this filing.
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`Respectfully submitted,
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`McDONALD’S CORPORATION
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`By: /John A. Cullis/
`Robert E. Browne
`John A. Cullis
`Lawrence E. James, Jr
`Joshua W. Newman
`Reed Smith LLP
`10 South Wacker Drive, 40th Floor
`Chicago, IL 60606
`T: (312) 207-1000
`F: (312) 207-6400
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`Date: May 29, 2018
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`CERTIFICATE OF TRANSMISSION
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`I hereby certify that the foregoing NOTICE OF OPPOSITION is being electronically
`transmitted via the Electronic System for Trademark Trials and Appeals (“ESTTA”) at
`http://estta.uspto.gov/ on the date noted below:
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`Date: May 29, 2018
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`By:
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`/Mavis H. Benson/
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`CERTIFICATE OF SERVICE
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`I hereby certify that I served a courtesy copy of the foregoing NOTICE OF
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`OPPOSITION upon Applicant’s email of record as listed with the USPTO:
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`
`Lee H. Skolnick
`LHSA+DP
`75 Broad Street, Suite 2700
`New York, New York 10004
`mail@skolnick.com
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`on the date noted below:
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`Date: May 29, 2018
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`
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`By:
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`/John A. Cullis/
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