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Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
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`ESTTA Tracking number:
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`ESTTA1167688
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`Filing date:
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`10/22/2021
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
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`91271685
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`Party
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`Correspondence
`Address
`
`Defendant
`Shenzhen Hande Hall Technology Co., Ltd.
`
`DI LI
`DI LI LAW, P.C.
`17700 CASTLETON ST.
`STE 353
`CITY OF INDUSTRY, CA 91748
`UNITED STATES
`Primary Email: di@dililaw.com
`Secondary Email(s): maggie@dililaw.com, anja@dililaw.com
`6267234849
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`Submission
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`Filer's Name
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`Filer's email
`
`Signature
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`Date
`
`Answer
`
`Di Li
`
`di@dililaw.com, maggie@dililaw.com, anja@dililaw.com
`
`/Di Li/
`
`10/22/2021
`
`Attachments
`
`10222021 Answer to Notice of Opposition.pdf(111746 bytes )
`
`

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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`For the trademark “BOOSTHINK” (Application No. 90205340);
`Published in the Official Gazette on August 24, 2021
`________________________________________________
`LENOVO (SINGAPORE) PTE. LTD.,
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`LENOVO PC INTERNATIONAL LIMITED
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`Opposer,
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`v.
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`SHENZHEN HANDE HALL TECHNOLOGY CO., LTD., )
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`Applicant.
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`________________________________________________)
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`Opposition No. 91271685
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`ANSWER TO NOTICE OF OPPOSITION
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`SHENZHEN HANDE HALL TECHNOLOGY CO., LTD., (“Applicant”), by its attorney,
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`hereby answers the Notice of Opposition of LENOVO (SINGAPORE) PTE. LTD. and LENOVO
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`PC INTERNATIONAL LIMITED (“Opposers”) and admits, denies, and alleges as follows:
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`1.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 1 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`2.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 2 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`3.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 3 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`1
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`

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`4.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 4 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`5.
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`6.
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`Applicant admits the allegations of Opposer’s Paragraph No. 5.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 6 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`7.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 7 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`8.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 8 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`9.
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`Paragraph No. 9 represents conclusions of law to which no answer is required. To
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`the extent that an answer is required, Applicant is without knowledge sufficient to form a belief as
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`to the allegations of Opposer’s Paragraph No. 9 and therefore denies the same and leaves Opposer
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`to its proofs with respect thereto.
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`10.
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`Paragraph No. 10 represents conclusions of law to which no answer is required. To
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`the extent that an answer is required, Applicant is without knowledge sufficient to form a belief as
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`to the allegations of Opposer’s Paragraph No. 10 and therefore denies the same and leaves Opposer
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`to its proofs with respect thereto.
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`11.
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`Applicant admits the allegations of Opposer’s Paragraph No. 11.
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`12.
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`Applicant admits the allegations of Opposer’s Paragraph No. 12.
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`2
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`13.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 13 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`14. Applicant admits the allegations of Opposer’s Paragraph No. 14.
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`15. Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 15 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`16.
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`Paragraphs 1 – 16 are responded to as set forth above.
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`17.
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`Applicant denies the allegations of Opposer’s Paragraph No. 17.
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`18.
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`Applicant admits the allegations of Opposer’s Paragraph No. 18.
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`19.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 19 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`20.
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`Applicant is without knowledge sufficient to form a belief as to the allegations of
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`Opposer’s Paragraph No. 20 and therefore denies the same and leaves Opposer to its proofs with
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`respect thereto.
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`21.
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`Paragraph No. 21 represents conclusions of law to which no answer is required. To
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`the extent that an answer is required, Applicant is without knowledge sufficient to form a belief as
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`to the allegations of Opposer’s Paragraph No. 21 and therefore denies the same and leaves Opposer
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`to its proofs with respect thereto.
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`22.
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`Paragraph No. 22 represents conclusions of law to which no answer is required. To
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`the extent that an answer is required, Applicant is without knowledge sufficient to form a belief as
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`
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`3
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`

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`to the allegations of Opposer’s Paragraph No. 22 and therefore denies the same and leaves Opposer
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`to its proofs with respect thereto.
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`23.
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`Paragraph No. 23 represents conclusions of law to which no answer is required. To
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`the extent that an answer is required, Applicant is without knowledge sufficient to form a belief as
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`to the allegations of Opposer’s Paragraph No. 23 and therefore denies the same and leaves Opposer
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`to its proofs with respect thereto.
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`
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`WHEREFORE, having fully answered the Notice of Opposition herein, Applicant
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`respectfully requests that the Trademark Trial and Appeal Board (“Board”):
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`Dismiss the Opposer’s Notice of Opposition in all respects and with prejudice;
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`Award Applicant such other relief that the Board deems justice and equitable.
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`1.
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`2.
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`Dated: October 22, 2021 By: /Di Li/
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`Di Li, Esq.
` Di Li Law, Professional Corporation
` 17700 Castleton St. Ste 353
` City of Industry, CA 91748
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` di@dililaw.com
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` trademarks@dililaw.com
` (626) 723-4849
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` Attorney for Applicant,
`SHENZHEN HANDE HALL
` TECHNOLOGYCO., LTD.
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`4
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`

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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and complete copy of the foregoing Applicant’s verified Answer to
`Notice of Opposition has been served with Opposer’s Attorneys by forwarding said copy on
`October 22, 2021 via email to:
`
`ELIZABETH BAUMHART
`TAFT STETTINIUS & HOLLISTER LLP
`ONE INDIANA SQUARE, SUITE 3500
`INDIANAPOLIS, IN 46204
`NEW YORK, NY 10151
`Primary Email: ebaumhart@taftlaw.com
`Secondary Email(s): pbautista@taftlaw.com, awilcox@taftlaw.com, docket@taftlaw.com
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`Attorneys of Petitioner
`
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`Dated: October 22, 2021
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`By: /Di Li/
`
`Di Li, Esq.
`California Bar No. 294173
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`Di Li Law, Professional Corporation
`17700 Castleton St. Ste 353
`City of Industry, CA 91748
`di@dililaw.com
`trademarks@dililaw.com
`(626)723-4849
`
`Attorney of Applicant,
`SHENZHEN HANDE HALL
`TECHNOLOGY CO., LTD
`
`
`5
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`

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