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ESTTA Tracking number:
`
`ESTTA1398419
`
`Filing date:
`
`11/26/2024
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding no.
`
`91275238
`
`Party
`
`Correspondence
`address
`
`Submission
`
`Filer's name
`
`Filer's email
`
`Signature
`
`Date
`
`Plaintiff
`Bold Strategies, Inc.
`
`RYAN S. HILBERT
`HOLLEY & MENKER, PA
`PO BOX 331937
`ATLANTIC BEACH, FL 32233
`UNITED STATES
`Primary email: rhilbert@holleymenker.com
`Secondary email(s): gholley@holleymenker.com, eastdock-
`et@holleymenker.com, westdocket@holleymenker.com
`904-247-2620
`
`Stipulated/Consent Motion to Extend
`
`Ryan S. Hilbert
`
`ryanhilbert@yahoo.com, eastdocket@holleymenker.com, maindock-
`et@holleymenker.com
`
`/Ryan S. Hilbert/
`
`11/26/2024
`
`Attachments
`
`2024-11-26 Joint Status and Motion to Extend.pdf(113590 bytes )
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE
`TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`Bold Strategies, Inc,
`
`
`
`
`
`
`
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`Disobey.GG Limited,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Opposer,
`
`
`
`
`
`
`
`
`
`
`Applicant.
`
`
`
`
`
`
`
`
`
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Opposition No. 91275238
`
`Application Serial No.:
`90129347
`
`
`
`JOINT MOTION TO SUSPEND PROCEEDING
`
`Pursuant to TBMP § 510, the parties, by and through their respective counsel, hereby
`
`
`
`respectfully request that all subsequent deadlines in the above proceeding be suspended for an
`
`additional ninety (90) days to allow the parties to continue their settlement efforts. Good cause
`
`exists for this request.
`
`
`
`On September 30, 2024, the parties submitted their most recent “Consent Motion for
`
`Suspension for Settlement.” [TTABVUE 31.] On October 9, 2024, the Board issued an Order
`
`granting the parties’ Motion. [TTABVUE 32.] In doing so, the Board also required that any further
`
`extensions or suspensions include a showing of good cause. As stated above, the parties believe
`
`that good cause exists for this request.
`
`
`
`Over the last couple of years, the parties, which are located in the U.S. and the U.K.,
`
`respectively, have exchanged numerous communications via both email and video call and have
`
`exchanged no fewer than four drafts of a settlement agreement. The most recent of these was sent
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`by Opposer to Applicant on November 21, 2024.
`
`The parties continue to believe that a settlement can be reached. They simply need more
`
`time to try to do so. The reason the parties are requesting ninety (90) days instead of sixty (60)
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`days is because of the various scheduling issues that typically arise during the holiday season.
`
`
`
`1
`
`

`

`Should the Board agree to the parties’ request, the new schedule will appear as follows:
`
`
`
`Current
`
`Schedule
`
`Proposed
`
`Schedule
`
`Initial Disclosures Due
`
`12/02/2024
`
`03/02/2025
`
`Expert Disclosures Due
`
`04/01/2025
`
`06/30/2025
`
`Discovery Closes
`
`05/01/2025
`
`07/30/2025
`
`Pretrial Disclosures Due for Party in Position of Plaintiff in
`Original Claim
`
`06/15/2025
`
`09/13/2025
`
`30-day Trial Period Ends for Party in Position of Plaintiff in
`Original Claim
`
`07/30/2025
`
`10/28/2025
`
`Pretrial Disclosures Due for Party in Position of Defendant
`in Original Claim and in Position of Plaintiff in
`Counterclaim
`
`08/14/2025
`
`11/12/2025
`
`30-day Trial Period Ends for Party in Position of Defendant
`in Original Claim, and in Position of Plaintiff in
`Counterclaim
`
`09/28/2025
`
`12/27/2025
`
`Pretrial Disclosures Due for Rebuttal of Party in Position of
`Plaintiff in Original Claim and in Position of Defendant in
`Counterclaim
`
`10/13/2025
`
`01/11/2026
`
`30-day Trial Period Ends for Rebuttal of Party in Position of
`Plaintiff in Original Claim, and in Position of Defendant in
`Counterclaim
`
`11/27/2025
`
`02/25/2026
`
`Pretrial Disclosures Due for Rebuttal of Party in Position of
`Plaintiff in Counterclaim
`
`12/12/2025
`
`03/12/2026
`
`15-day Trial Period Ends for Rebuttal of Party in Position of
`Plaintiff in Counterclaim
`
`01/11/2026
`
`04/11/2026
`
`
`
`2
`
`

`

`Opening Brief for Party in Position of Plaintiff in Original
`Claim Due
`
`03/12/2026
`
`06/10/2026
`
`Combined Brief for Party in Position of Defendant in
`Original Claim and Opening Brief as Plaintiff in
`Counterclaim Due
`
`04/11/2026
`
`07/10/2026
`
`Combined Rebuttal Brief for Party in Position of Plaintiff in
`Original Claim and Brief as Defendant in Counterclaim Due
`
`05/11/2026
`
`08/09/2026
`
`Rebuttal Brief for Party in Position of Plaintiff in
`Counterclaim Due
`
`05/26/2026
`
`08/24/2026
`
`Request for Oral Hearing (optional) Due
`
`06/05/2026
`
`09/03/2026
`
`
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`Based on the foregoing, and so that the parties can continue towards a resolution without
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`further burdening the Board, the parties now respectfully request a further ninety (90) day
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`suspension of the deadlines in the proceeding.
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`
`
`
`
`
`
`Respectfully submitted,
`
`
`Date: November 26, 2024
`
`
`HOLLEY & MENKER PA
`
`By: /Ryan S. Hilbert/
`Ryan S. Hilbert
`PO Box 331937
`Atlantic Beach, FL 32233
`Phone: (888) 750-4407
`rhilbert@holleymenker.com
`eastdocket@holleymenker.com
`
`Attorney for Opposer
`
`
`
`
`
`
`
`
`EPSTEIN DRANGEL LLP
`
`By: /William C. Wright/
`William C. Wright
`60 East 42nd Street, Suite 2520
`New York, NY 10165
`Phone: 212-292-5390
`mail@ipcounselors.com
`
`Attorneys for Applicant
`
`
`
`3
`
`

`

`CERTIFICATE OF ELECTRONIC SERVICE
`
`I hereby certify that a true and complete copy of the foregoing, JOINT MOTION TO
`
`SUSPEND PROCEEDING, has been served on the attorneys for Applicant via e-mail on
`November 26, 2024, to:
`
`
`EPSTEIN DRANGEL LLP
`William C. Wright
`60 East 42nd Street, Suite 2520
`New York, NY 10165
`Phone: 212-292-5390
`
`mail@ipcounselors.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Ryan S. Hilbert/
`
`4
`
`
`
`
`
`
`
`

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