Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
`ESTTA1161149
`09/22/2021
`
`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
`
`Granted to Date
`of previous ex-
`tension
`
`Address
`
`Correspondence
`information
`
`PepsiCo, Inc.
`
`10/13/2021
`
`700 ANDERSON HILL ROAD
`PURCHASE, NY 10577
`UNITED STATES
`
`PAUL A. LEE
`SENIOR TRADEMARK COUNSEL
`PEPSICO, INC.
`700 ANDERSON HILL ROAD
`PURCHASE, NY 10577
`UNITED STATES
`Primary Email: trademarks@pepsico.com
`Secondary Email(s): Paul.Lee@pepsico.com, donna.j.sanders@pepsico.com
`No phone number provided.
`
`Applicant Information
`
`Application No.
`
`90273875
`
`Publication date
`
`06/15/2021
`
`Opposition Filing
`Date
`
`Applicant
`
`09/22/2021
`
`Opposition Peri-
`od Ends
`
`10/13/2021
`
`SANTOS SOLUTIONS LTD.
`95 LUCERNE AVENUE
`BURE PARK, BICESTER, OX263EQ
`UNITED KINGDOM
`
`Goods/Services Affected by Opposition
`
`Class 021. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are opposed, namely: Drinking glasses, namely, tumblers; Kitchen
`accessories, namely, tumblers for use as drinking glasses, drinking straws,brushes for cleaning drink-
`ware and drinking straws; Kitchen accessories, namely, kits featuring tumblers for use as drinking
`glasses, drinking straws, brushes for cleaning drinkware and drinking straws
`
`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.
`
`820362
`
`Registration Date
`
`12/13/1966
`
`Application Date
`
`04/15/1966
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MOUNTAIN DEW
`
`NONE
`
`Class 032. First use: First Use: 1948/09/24 First Use In Commerce: 1948/10/10
`SOFT DRINKS, AND CONCENTRATES USED IN THE PREPARATION
`THEREOF
`
`U.S. Registration
`No.
`
`3674349
`
`Registration Date
`
`08/25/2009
`
`Word Mark
`
`Design Mark
`
`MTN DEW
`
`Application Date
`
`10/06/2008
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 032. First use: First Use: 2009/01/00 First Use In Commerce: 2009/01/00
`Concentrates, syrups or powders used inthe preparation of soft drinks; Soft
`drinks
`
`U.S. Registration
`No.
`
`1200615
`
`Registration Date
`
`07/06/1982
`
`Application Date
`
`04/06/1981
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`DEW
`
`NONE
`
`Class 032. First use: First Use: 1980/11/12 First Use In Commerce: 1980/11/12
`Soft Drinks
`
`U.S. Registration
`No.
`
`1932027
`
`Registration Date
`
`10/31/1995
`
`Word Mark
`
`Design Mark
`
`DO THE DEW
`
`Application Date
`
`08/23/1993
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 032. First use: First Use: 1995/03/00 First Use In Commerce: 1995/03/00
`soft drinks
`
`U.S. Registration
`No.
`
`3687364
`
`Registration Date
`
`09/22/2009
`
`Word Mark
`
`Design Mark
`
`DEW
`
`Application Date
`
`11/12/2008
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`The mark consists of the word "DEW" in stylized slanted red letters.
`
`Class 032. First use: First Use: 2009/01/01 First Use In Commerce: 2009/01/01
`Soft drinks
`
`U.S. Registration
`No.
`
`3674407
`
`Registration Date
`
`08/25/2009
`
`Word Mark
`
`MTN DEW
`
`Application Date
`
`11/12/2008
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Design Mark
`
`Description of
`Mark
`
`The mark consists of the word "MTN" in stylized slanted dark green letters
`stacked on top of the word "DEW" in stylizedslanted red letters, which words are
`then outlined in white, further outlined in light green and further outlined in dark
`green.
`
`Goods/Services
`
`Class 032. First use: First Use: 2009/01/00 First Use In Commerce: 2009/01/00
`Soft drinks
`
`U.S. Registration
`No.
`
`4146652
`
`Registration Date
`
`05/22/2012
`
`Word Mark
`
`Design Mark
`
`DEW
`
`Application Date
`
`10/06/2011
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 035. First use: First Use: 2005/06/30 First Use In Commerce: 2005/06/30
`Promotional sponsorship of sporting events and competitions
`
`U.S. Registration
`No.
`
`4993451
`
`Registration Date
`
`07/05/2016
`
`Application Date
`
`12/14/2015
`
`Foreign Priority
`Date
`
`NONE
`
`

`

`Word Mark
`
`Design Mark
`
`DEW TOUR
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 041. First use: First Use: 2005/06/09 First Use In Commerce: 2005/06/09
`Entertainment services, namely, organizing and conducting a wide variety of
`sports exhibitions and competitions; Entertainment services in the nature of an
`ongoing television series featuring a wide variety of sports exhibitions and com-
`petitions
`
`U.S. Registration
`No.
`
`2732061
`
`Registration Date
`
`07/01/2003
`
`Application Date
`
`02/13/2002
`
`Foreign Priority
`Date
`
`NONE
`
`Word Mark
`
`Design Mark
`
`Description of
`Mark
`
`Goods/Services
`
`MOUNTAIN DEW VERTICAL CHALLENGE
`
`NONE
`
`Class 041. First use: First Use: 1989/11/00 First Use In Commerce: 1989/11/00
`ORGANIZING SPORTING EVENTS, NAMELY, SKIAND SNOWBOARD
`RACES
`
`U.S. Registration
`No.
`
`2986575
`
`Registration Date
`
`08/16/2005
`
`Word Mark
`
`Design Mark
`
`MOUNTAIN DEW
`
`Application Date
`
`02/19/2004
`
`Foreign Priority
`Date
`
`NONE
`
`Description of
`Mark
`
`Goods/Services
`
`NONE
`
`Class 025. First use: First Use: 2004/07/00 First Use In Commerce: 2004/07/00
`CLOTHING, NAMELY, T-SHIRTS [, SWEATSHIRTS ]
`
`

`

`Attachments
`
`77586029#TMSN.png( bytes )
`77612532#TMSN.png( bytes )
`77612574#TMSN.png( bytes )
`85441015#TMSN.png( bytes )
`86848705#TMSN.png( bytes )
`78976202#TMSN.png( bytes )
`Notice of Opposition re DEW LIFE by Santos Solutions pl sig.pdf(384451 bytes )
`
`Signature
`
`Name
`
`Date
`
`/Paul A. Lee/
`
`PAUL A. LEE
`
`09/22/2021
`
`

`

`
`
`
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`: June 15, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`IN THE MATTER OF APPLICATION
`Mark
`
`
`: DEW LIFE Stylized
`Applicant
`
`: Santos Solutions Ltd.
`Serial No.
`
`: 90/273,875
`Filed
`
`
`: October 23, 2020
`Published in
`the Official Gazette
`
`____________________________________x
`
`
`
`
`
`
`:
`PEPSICO, INC.,
`
`
`
`:
`
`
`
`
`
`
`:
`
`
`Opposer,
`
`
`:
`
`
`
`
`
`
`:
`
`v.
`
`
`
`
`:
`
`
`
`
`
`
`:
`SANTOS SOLUTIONS LTD.,
`
`:
`
`
`
`
`
`
`:
`
`
`Applicant.
`
`
`:
`____________________________________x
`
`
`NOTICE OF OPPOSITION
`
`
`
`Opposer, PepsiCo, Inc. (“PepsiCo” or “Opposer”), a North Carolina corporation having a
`
`place of business at 700 Anderson Hill Road, Purchase, New York 10577 believes that it will be
`
`damaged by the registration of Application Serial No. 90/273,875, filed on October 23, 2020, in
`
`the name of Santos Solutions Ltd. (hereinafter “Applicant”), based on an intent-to-use the
`
`alleged stylized mark DEW LIFE for “Drinking glasses, namely, tumblers; Kitchen accessories,
`
`namely, tumblers for use as drinking glasses, drinking straws, brushes for cleaning drinkware
`
`and drinking straws; Kitchen accessories, namely, kits featuring tumblers for use as drinking
`
`glasses, drinking straws, brushes for cleaning drinkware and drinking straws” in International
`
`Class 21, and having been previously granted an extension of time to oppose, hereby opposes the
`
`foregoing application.
`
`The specific grounds for this opposition are as follows:
`
`
`
`1
`
`

`

`
`
`
`
`
`
`1.
`
`PepsiCo, through its predecessors in interest, has been engaged in the beverage
`
`business for over 100 years and has become well and favorably known to members of the public,
`
`plus members of the beverage industry, for quality beverage products and related goods and
`
`services. It owns a portfolio of brands that identify carbonated soft drinks, juices and juice
`
`drinks, ready-to-drink teas, isotonic sports drinks, energy drinks, bottled water and enhanced
`
`waters, and related products and services.
`
`2.
`
`Since at least as early as 1948, 1980 and 2009, respectively, and continuing
`
`through to the present, PepsiCo has used, on its own or through predecessors in interest, the
`
`marks MOUNTAIN DEW, DEW and MTN DEW in connection with marketing, advertising,
`
`promoting, distributing and selling various beverages and other products and services. The
`
`marks are also used in connection with advertising, marketing, sales and promotional services to
`
`authorized bottlers, independent distributors and retailers. Such marketing, promotion, and
`
`advertising includes some of the most-recognized commercials and ads, e.g., the “DO THE
`
`DEW” nationwide advertising campaign.
`
`3.
`
`Since long prior to the filing date of the application-at-issue for DEW LIFE,
`
`DEW, MTN DEW and MOUNTAIN DEW have been identified with Opposer and have
`
`appeared on a tremendous amount of product packaging, advertising, in-store display racks,
`
`signage, point-of purchase material, etc.
`
`4.
`
`Opposer’s DEW, MTN DEW and MOUNTAIN DEW products are marketed and
`
`sold in enormous quantities on a nationwide basis, supported by many millions of dollars of
`
`advertising and promotion each year. Opposer’s products are sold in almost every supermarket
`
`in the United States as well as in mass merchandise stores, numerous convenience stores,
`
`vending machines, and other outlets.
`
`
`
`2
`
`

`

`
`
`
`
`
`
`5.
`
`The vast commercial acceptance and success of many of Opposer’s DEW, MTN
`
`DEW and MOUNTAIN DEW products for well over 70 years is due in large measure to
`
`substantial advertising and marketing efforts by PepsiCo. Opposer has, by virtue of extensive
`
`usage, advertising and promotion, built up a very high level of consumer and trade recognition
`
`symbolized by its marks DEW, MTN DEW, MOUNTAIN DEW and variants. Opposer’s sales
`
`of its beverage products marketed under the DEW, MTN DEW and MOUNTAIN DEW marks,
`
`have exceeded hundreds of millions of dollars each year, over the past several years alone.
`
`6.
`
`PepsiCo’s use of the marks DEW, MTN DEW and MOUNTAIN DEW also
`
`extends beyond beverages, per se, to include other products and services. For example, over the
`
`years, PepsiCo has been marketing and selling clothing, drinking vessels, sauces, and
`
`entertainment services under the marks. Since 1989 and continuing to the present, PepsiCo has
`
`also been organizing, marketing and promoting sporting events, such as ski and snowboarding
`
`races, in connection with its marks DEW, MTN DEW, MOUNTAIN DEW and variants such as
`
`MOUNTAIN DEW VERTICAL CHALLENGE and the DEW TOUR. Likewise, PepsiCo,
`
`under its marks MOUNTAIN DEW, MTN DEW and/or DEW, has been a sponsor of NASCAR
`
`racing teams and events for well over 20 years.
`
`7.
`
`PepsiCo also owns and operates a website at MOUNTAINDEW.COM, which is
`
`operational twenty-four hours a day, seven days a week, through which PepsiCo advertises,
`
`markets and promotes its beverage products under the marks DEW, MTN DEW, MOUNTAIN
`
`DEW and variants. PepsiCo also promotes its beverages products through such programs as
`
`DEW TOUR for action sports tour and MTN DEW DEWnited States collectible editions.
`
`8.
`
`As a result of such extensive and continuous advertising, sale, use and promotion
`
`of soft drinks and other products and services under or in connection with PepsiCo’s marks
`
`
`
`3
`
`

`

`
`
`
`
`
`
`DEW, MTN DEW and MOUNTAIN DEW for over 70 years, these marks have not only
`
`acquired substantial public and consumer recognition throughout the United States, but also
`
`enjoy valuable goodwill, and have become famous, solely signifying Opposer as the source of
`
`products and services of high quality.
`
`9.
`
`In addition to its prior common law rights in the marks DEW, MTN DEW,
`
`MOUNTAIN DEW, and variants, Opposer is also the owner of numerous live United States
`
`trademark and service mark applications and registrations, each of which incorporate the
`
`designation DEW, MTN DEW, MOUNTAIN DEW, or variants, including, but not limited to,
`
`the following:
`
`MARK
`
`MOUNTAIN DEW
`
`REG. NO. REG. DATE FIRST
`USE DATE
`Dec. 13, 1966 09/24/1948
`
`820,362
`
`MTN DEW
`
`3,674,349
`
`Aug. 25, 2009 01/00/2009
`
`IDENTIFICATION OF
`GOODS
`Soft drinks, and concentrates
`used in the preparation thereof,
`in Class 32
`
`Concentrates, syrups or
`powders used in the
`preparation of soft drinks; Soft
`drinks, in Class 32
`
`DEW
`
`1,200,615
`
`July 6, 1982
`
`11/12/1980
`
`Soft drinks, in Class 32
`
`DO THE DEW
`
`1,932,027
`
`Oct. 31, 1995
`
`03/00/1995
`
`Soft drinks, in Class 32
`
`DEW (stylized)
`
`3,687,364
`
`Sept. 22, 2009 01/01/2009
`
`Soft drinks, in Class 32
`
`3,674,407
`
`Aug. 25, 2009 01/00/2009
`
`Soft drinks, in Class 32
`
`4,146,652 May 22, 2012 06/30/2005
`
`Promotional sponsorship of
`sporting events and
`competitions, in Class 35
`
`Entertainment services,
`namely, organizing and
`conducting a wide variety of
`sports exhibitions and
`competitions; Entertainment
`services in the nature of an
`ongoing television series
`
`MTN DEW (stylized)
`
`DEW
`
`DEW TOUR
`
`4,993,451
`
`July 5, 2016
`
`06/09/2005
`
`
`
`4
`
`

`

`
`
`
`
`
`
`featuring a wide variety of
`sports exhibitions and
`competitions, in Class 41
`
`MOUNTAIN DEW
`VERTICAL
`CHALLENGE
`MOUNTAIN DEW
`
`2,732,061
`
`July 1, 2003
`
`11/00/1989 Organizing sporting events,
`namely, ski and snowboard
`races, in Class 41
`
`2,986,575
`
`Aug. 16, 2005 7/00/2004
`
`Clothing, namely, t-shirts, in
`Class 25
`
`
`
`10.
`
`Opposer’s registrations for these marks are valid, subsisting, in full force and
`
`effect, uncancelled and unrevoked, and serve as evidence of PepsiCo’s exclusive right to use
`
`such marks in commerce on or in connection with the goods or services identified in the
`
`registrations, as provided by Section 33(a) of the United States Trademark (Lanham) Act, 15
`
`U.S.C. § 1115(a). Further, many of Opposer’s registrations for the aforesaid marks have become
`
`incontestable pursuant to Section 15 of the Lanham Act, 15 U.S.C. § 1065. Hereinafter
`
`PepsiCo’s foregoing marks, including those registered and/or used in commerce, are referred to
`
`individually and/or collectively as the “DEW Marks”.
`
`11.
`
`Use of the DEW Marks has been continuous and they have not been abandoned.
`
`As a result of the long, extensive and widespread use, advertising, promotion and registration of
`
`the DEW Marks on and in association with PepsiCo’s various goods and services, including, but
`
`not limited to, beverages, soft drinks, energy drinks, clothing, organizing, marketing and
`
`promoting sporting events, sponsoring sporting events, entertainment services and live musical
`
`performances, and other marketing efforts, consumers have become accustomed to associating
`
`marks consisting of or containing the term “DEW” or variants with a single source, that is,
`
`PepsiCo.
`
`
`
`5
`
`

`

`
`
`
`
`
`
`12.
`
`In view of such usage, the DEW Marks, including DEW, MTN DEW and
`
`MOUNTAIN DEW, have become famous and one of the most renowned brands in the United
`
`States, representing assets of inestimable value to PepsiCo.
`
`13.
`
`On information and belief, on October 23, 2020, Applicant, having an address at
`
`95 Lucerne Avenue, Bure Park, Bicester, United Kingdom OX263EQ, filed U.S. Application
`
`Serial No. 90/273,875 for the stylized mark DEW LIFE for “Drinking glasses, namely, tumblers;
`
`Kitchen accessories, namely, tumblers for use as drinking glasses, drinking straws, brushes for
`
`cleaning drinkware and drinking straws; Kitchen accessories, namely, kits featuring tumblers for
`
`use as drinking glasses, drinking straws, brushes for cleaning drinkware and drinking straws” in
`
`International Class 21, (hereinafter, the “Application-in-Opposition” or the “DEW LIFE Mark”,
`
`unless otherwise specified).
`
`14.
`
`Upon information and belief, at the time Applicant filed its application for the
`
`DEW LIFE Mark, it was or should have been fully aware of Opposer’s well-known and famous
`
`DEW Marks and its rights therein. Applicant was at least on constructive notice of Opposer’s
`
`rights in and to the DEW Marks by its prior federal registrations therefor.
`
`15.
`
` Registration of Applicant’s alleged mark DEW LIFE, which is the subject of the
`
`Application-in-Opposition, is barred by the provisions of Section 2(d) of the Trademark Act of
`
`1946 because the said mark consists of elements that so resemble Opposer’s DEW Marks,
`
`including, but not limited to, DEW and variants, which have been in prior use and are also the
`
`subject of prior registrations and previously filed applications to register marks in the United
`
`States Patent and Trademark Office, as to be likely, when used in connection with the alleged
`
`goods of the Applicant to cause confusion, mistake or deception.
`
`
`
`6
`
`

`

`
`
`
`
`
`
`16.
`
`PepsiCo has priority over Applicant because PepsiCo’s use, application filing
`
`dates and/or registration dates for the DEW Marks precede the Applicant’s filing date for its
`
`Application-in-Opposition, any alleged date of first use in commerce, and/or any other purported
`
`filing date of applications or registrations for Applicant’s alleged DEW LIFE Mark.
`
`17.
`
`Applicant’s alleged DEW LIFE Mark, which is the subject of the Application-in-
`
`Opposition, and PepsiCo’s DEW Marks, including, but not limited to, DEW and variants, are
`
`similar. Indeed, the element “DEW” in Applicant’s purported mark is identical to PepsiCo’s
`
`mark DEW. On information and belief, the goods in connection with which Applicant’s alleged
`
`mark is used, intended to be used or applied for and the goods and services in connection with
`
`which Opposer’s DEW Marks are registered and/or used are similar and/or related. Further, the
`
`Application-in-Opposition contains no limitations on marketing channels or customers such that
`
`the channels of trade and target markets for Applicant’s goods will overlap with those for
`
`PepsiCo’s goods and services that are marketed and sold in connection with the DEW Marks.
`
`18.
`
`Accordingly, Applicant’s claimed DEW LIFE Mark, which is the subject of the
`
`Application-in-Opposition, so resembles PepsiCo’s foregoing and previously used and/or
`
`registered DEW Marks as to be likely to cause confusion, to cause mistake or to deceive with
`
`consequent injury to Opposer. The likelihood of confusion, mistake or deception that would also
`
`arise from concurrent use and registration of the applied-for mark with Opposer’s use and
`
`registration of its DEW Marks, including but not limited to DEW and variants, is that (a) persons
`
`are likely to believe that Applicant’s goods have their source in PepsiCo, or (b) that Applicant
`
`and its goods are a version of Opposer’s marks or are in some way legitimately connected,
`
`associated or affiliated with, sponsored, approved, endorsed or licensed by Opposer when, in
`
`fact, they are not.
`
`
`
`7
`
`

`

`
`
`
`
`
`
`19.
`
`In view of the foregoing, registration of Applicant’s alleged DEW LIFE Mark is
`
`barred by the provisions of Section 2(d) of the Trademark Act of 1946, 15 U.S.C. § 1052(d),
`
`because the said Application-in-Opposition consists of a mark which, when used in connection
`
`with the alleged goods of Applicant, are likely to cause confusion, mistake or deception.
`
`20.
`
`Further and as detailed above, PepsiCo has invested considerable effort and
`
`resources in developing, using, advertising, and promoting beverages and other products and
`
`services in connection with its inherently distinctive DEW Marks, including, DEW, MTN DEW
`
`and MOUNTAIN DEW, in the United States, and over an extensive period of time, which has
`
`resulted in tremendous volumes of commercial impressions. Sales of and revenue generated by
`
`such products and services under or in connection with the DEW Marks due to such marketing
`
`efforts have been several billions of dollars annually over each of the last five years alone. In
`
`view of such substantial usage, exposure and sales, the DEW Marks have become famous,
`
`widely recognized by the general consuming public of the United States as a designation of
`
`source of the goods of PepsiCo and became famous long prior to the filing date of Applicant’s
`
`Application-in-Opposition and/or any claimed priority date by Applicant of the alleged DEW
`
`LIFE Mark shown in U.S. Application Serial No. 90/273,875. Registration and use of
`
`Applicant’s claimed DEW LIFE Mark would likely dilute Opposer’s famous and inherently
`
`distinctive DEW Marks, including DEW, MTN DEW and MOUNTAIN DEW, in violation of 15
`
`U.S.C. § 1125(c). Accordingly, the applied-for DEW LIFE Mark is not entitled to registration
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`under 15 U.S.C. § 1052(f) and Section 13 of the Lanham Act, 15 U.S.C. § 1063.
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`21.
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`PepsiCo will be damaged by the issuance of the registration sought by Applicant
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`within the meaning of 15 U.S.C. §1063 because such registration would support and assist
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`Applicant in the confusing, misleading, deceptive, false association and/or dilutive use of DEW
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`8
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`LIFE and, would give color of exclusive statutory rights to Applicant, over which PepsiCo has
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`no control, in violation and derogation of the prior and superior rights of Opposer.
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`WHEREFORE, Opposer prays that this opposition be sustained in its favor, that
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`registration be denied to Applicant on its Application Serial No. 90/273,875 and that the Board
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`grant all further relief to Opposer that is necessary and just in these circumstances.
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`Respectfully submitted,
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`PEPSICO, INC.
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`By:
`Paul A. Lee
`Attorney for Opposer
`700 Anderson Hill Road
`Purchase, NY 10577
`(914) 253-3443
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`Dated: September 22, 2021
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`9
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