Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov
`ESTTA1199407
`03/29/2022
`
`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
`
`SMA Solar Technology AG
`
`Granted to date
`of previous ex-
`tension
`
`Address
`
`04/06/2022
`
`SONNENALLEE 1
`NIESTETAL, 34266
`GERMANY
`
`Attorney informa-
`tion
`
`STEWART J. BELLUS
`COLLARD & ROE, P.C.
`1077 NORTHERN BLVD.
`ROSLYN, NY 11576
`UNITED STATES
`Primary email: sbellus@collardroe.com
`Secondary email(s): law@collardroe.com
`5163659802
`
`Docket no.
`
`036766
`
`Applicant information
`
`Application no.
`
`88200602
`
`Opposition filing
`date
`
`Applicant
`
`03/29/2022
`
`Sunnie, Inc.
`UNIT 2
`3646 KALSMAN DRIVE
`LOS ANGELES, CA 90016
`UNITED STATES
`
`Goods/services affected by opposition
`
`Publication date
`
`12/07/2021
`
`Opposition period
`ends
`
`04/06/2022
`
`Class 042. First Use: Nov 22, 2017 First Use In Commerce: Nov 22, 2017
`All goods and services in the class are opposed, namely: Software as a service (SAAS) services fea-
`turing software for solar installers and prospective solar customers, allowingthem to connect to their
`utility portaland get insights into their current electricity usage and provide information on the potential
`savings by moving to solar energy
`
`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.
`
`5870338
`
`Register
`
`Principal
`
`Registration date
`
`10/01/2019
`
`Application date
`
`08/17/2017
`
`Foreign priority
`date
`
`02/22/2017
`
`Word mark
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`SUNNY HIGHPOWER PEAK
`
`NONE
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Apparatus for conducting, switching, transforming, storing, regulating and con-
`trolling electricity; devices and instruments for measuring and analyzing electri-
`city, namely, voltage testers and clamp meters for measuring electricity; soft-
`ware for monitoring electricity usage; electric display panels, namely, flat pan-
`eldisplay screens for displaying electrical energy information; data processing
`apparatus, inverters
`
`U.S. registration
`no.
`
`6436403
`
`Register
`
`Principal
`
`Registration date
`
`08/03/2021
`
`Word mark
`
`Design mark
`
`SONNENALLEE
`
`Application date
`
`07/02/2020
`
`Foreign priority
`date
`
`01/22/2020
`
`Description of
`mark
`
`Goods/services
`
`NONE
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Downloadable electronic magazines and journals about the energy sector, in-
`cluding topics related to energy use, consumption, efficiency, production, and
`management such as building projects, technical implementations, mobility be-
`havior, e-mobility, political and social frameworks, sustainable lifestyle, environ-
`mental psychology, alternative energy sources, decentralized energy supply, di-
`gitalization, smart cities, climate change, wastemanagement, passionate energy
`pioneers;downloadable electronic publications, namely, books, magazines and
`journals about the energy sector, including topics related to energy use, con-
`sumption, efficiency, production, and management such as building projects,
`technical implementations, mobility behavior, e-mobility, political and social
`frameworks, sustainable lifestyle, environmental psychology,alternative energy
`sources, decentralized energy supply, digitalization, smart cities, climate
`change, waste management, passionate energy pioneers
`Class 016. First use: First Use: None First Use In Commerce: None
`Printed matter, namely, books, journalsand magazines about the energy sector,
`including topics related to energy use, consumption, efficiency, production,
`andmanagement such as building projects, technical implementations, mobility
`behavior, e-mobility, political and social frameworks, sustainable lifestyle, envir-
`onmental psychology, alternative energy sources, decentralized energy supply,
`digitalization, smart cities, climate change, waste management, passionate en-
`ergy pioneers; magazines and journals about theenergy sector, including topics
`relatedto energy use, consumption, efficiency,production, and management
`such as building projects, technical implementations, mobility behavior, e-
`
`

`

`mobility, political and social frameworks, sustainable lifestyle, environmental
`psychology, alternative energy sources, decentralized energy supply, digitaliza-
`tion, smart cities, climate change, waste management, passionate energy pion-
`eers; printed publications, namely, books, journals and magazines about the en-
`ergy sector, including topics related to energy use, consumption, efficiency, pro-
`duction, and managementsuch as building projects, technical implementations,
`mobility behavior, e-mobility, political and social frameworks, sustainable life-
`style, environmental psychology, alternative energy sources, decentralized en-
`ergy supply, digitalization,smart cities, climate change, waste management, pas-
`sionate energy pioneers
`Class 041. First use: First Use: None First Use In Commerce: None
`Publication of web magazines and web journals relating to the energy sector;
`publication of magazines and journals relating to the energy sector; electronic
`publishing of electronic publications relating to the energy sector; publishing and
`editing of printed matter relating to the energy sector; provision of online, non-
`downloadable electronic publicationsin the nature of books, magazines, journals
`about the energy sector, including topics related to energy use, consumption, ef-
`ficiency, production, and management such as building projects, technical imple-
`mentations, mobility behavior, e-mobility, political and social frameworks, sus-
`tainable lifestyle, environmental psychology, alternative energy sources, decent-
`ralized energy supply, digitalization, smart cities, climate change, waste man-
`agement, passionate energy pioneers; entertainment services, namely, a con-
`tinuing program about the energy sector, including topics related to energy use,
`consumption, efficiency, production, and management such as building projects,
`technical implementations, mobility behavior,e-mobility, political and social
`frameworks, sustainable lifestyle, environmental psychology, alternative energy
`sources, decentralized energy supply, digitalization, smart cities, climate
`change, waste management, passionate energy pioneers accessible by radio,
`television, satellite, audio, video and computer networks
`
`U.S. registration
`no.
`
`6451493
`
`Register
`
`Principal
`
`Registration date
`
`08/17/2021
`
`Word mark
`
`Design mark
`
`SUNNYCONNECT
`
`Application date
`
`04/20/2020
`
`Foreign priority
`date
`
`NONE
`
`Description of
`mark
`
`Goods/services
`
`NONE
`
`Class 035. First use: First Use: Nov 4, 2019 First Use In Commerce: Nov 4,
`2019
`Consulting services in the field of energy use management and energy effi-
`ciency; consulting services in the field of energy efficiency pertaining to solar
`and renewable energy; providing a website featuring a portal with customer-spe-
`cific information for tracking installation ofsolar and renewable energy systems
`fromproposal through completion
`
`

`

`U.S. registration
`no.
`
`2257897
`
`Register
`
`Principal
`
`Registration date
`
`06/29/1999
`
`Application date
`
`08/25/1997
`
`Foreign priority
`date
`
`NONE
`
`Word mark
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`SUNNY BOY
`
`NONE
`
`Class 009. First use: First Use: Jun 5, 1997 First Use In Commerce: Jun 5, 1997
`energy supplying devices, namely, transformers, inverters, battery storage
`devices, each including its own measuring and controlling devices; computer
`software, namely, evaluation software designed for inverter products and in
`photovoltaicinstallations
`Class 011. First use: First Use: Jun 5, 1997 First Use In Commerce: Jun 5, 1997
`solar-powered steam generators, solor-powered boilers for heating installations,
`and solar furnaces for heating installations
`
`U.S. registration
`no.
`
`2854219
`
`Register
`
`Principal
`
`Registration date
`
`06/15/2004
`
`Application date
`
`11/02/2000
`
`Foreign priority
`date
`
`NONE
`
`Word mark
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`SUNNY ISLAND
`
`NONE
`
`Class 009. First use: First Use: Jul 8, 1997 First Use In Commerce: Aug 14,
`2003
`ENERGY SUPPLYING DEVICES, NAMELY, TRANSFORMERS, INVERTERS,
`BATTERIES AND PHOTOVOLTAIC ELEMENTS AND CELLS FOR CONVERT-
`INGSOLAR ENERGY TO ELECTRICAL ENERGY, EACHINCLUDING ITS
`OWN MEASURING AND CONTROLLING DEVICE; AND COMPUTER SOFT-
`WARE, NAMELY, EVALUATION SOFTWARE DESIGNED FOR INVERTER
`PRODUCTS IN PHOTOVOLTAIC EQUIPMENT
`
`U.S. registration
`no.
`
`2996025
`
`Register
`
`Principal
`
`Registration date
`
`09/13/2005
`
`Word mark
`
`SUNNY PORTAL
`
`Application date
`
`02/25/2004
`
`Foreign priority
`date
`
`NONE
`
`

`

`Design mark
`
`Description of
`mark
`
`Goods/services
`
`NONE
`
`Class 038. First use: First Use: Jan 13, 2004 First Use In Commerce: Feb 25,
`2004
`Providing multiple user access to an Internet platform through a global computer
`network for presenting the performancedata of energy technology equipment,
`namely, DC-AC converters
`
`U.S. registration
`no.
`
`3121666
`
`Register
`
`Principal
`
`Registration date
`
`07/25/2006
`
`Word mark
`
`Design mark
`
`SUNNY CENTRAL
`
`Application date
`
`06/02/2004
`
`Foreign priority
`date
`
`NONE
`
`Description of
`mark
`
`Goods/services
`
`NONE
`
`Class 009. First use: First Use: 1998 First Use In Commerce: 2003
`Energy transformers; inverters
`
`U.S. registration
`no.
`
`3145703
`
`Register
`
`Principal
`
`Application date
`
`06/02/2005
`
`

`

`Registration date
`
`09/19/2006
`
`Word mark
`
`Design mark
`
`SUNNY DESIGN
`
`Foreign priority
`date
`
`03/22/2005
`
`Description of
`mark
`
`Goods/services
`
`NONE
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Software, namely software for the design of photovoltaic installations
`
`U.S. registration
`no.
`
`5382962
`
`Register
`
`Principal
`
`Registration date
`
`01/23/2018
`
`Application date
`
`01/18/2017
`
`Foreign priority
`date
`
`08/31/2016
`
`Word mark
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`SUNNY TRIPOWER CORE
`
`NONE
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Apparatus for conducting, switching, transforming, storing, regulating, con-
`trolling, measuring and analyzing electric current, namely, conductivity meters,
`voltage regulators for electric power, electrical controllers, electrical fuses, safety
`switches, cutout switches, switch boxes, meters and gauges for the analyzing of
`electric current; invertors; software, namely, downloadable computer software
`for controlling and managing of electricity, electricity consumption and invertors;
`electric luminescent display panels; data processing apparatus for use solely in
`the renewable energy field
`
`U.S. registration
`no.
`
`3587468
`
`Register
`
`Principal
`
`Registration date
`
`03/10/2009
`
`Word mark
`
`Design mark
`
`SUNNY TRIPOWER
`
`Application date
`
`07/04/2008
`
`Foreign priority
`date
`
`02/19/2008
`
`Description of
`mark
`
`NONE
`
`Goods/services
`
`Class 009. First use: First Use: None First Use In Commerce: None
`
`

`

`Inverters
`
`5557783
`
`U.S. registration
`no.
`
`Register
`
`Principal
`
`Registration date
`
`09/11/2018
`
`Application date
`
`08/17/2017
`
`Foreign priority
`date
`
`02/22/2017
`
`Word mark
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`SUNNY HIGHPOWER
`
`NONE
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Apparatus for conducting, switching, transforming, storing, regulating and con-
`trolling electricity; devices and instruments for measuring and analyzing electri-
`city, namely, voltage testers and clamp meters for measuring electricity; soft-
`ware for monitoring electricity usage; electric display panels, namely, flat pan-
`eldisplay screens for displaying electrical energy information; data processing
`apparatus, inverters
`
`U.S. registration
`no.
`
`4362880
`
`Register
`
`Principal
`
`Registration date
`
`07/09/2013
`
`Application date
`
`07/11/2012
`
`Foreign priority
`date
`
`NONE
`
`Word mark
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`SUNNY HOME MANAGER
`
`NONE
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Apparatus for the collating, transmission and evaluation of data from energy
`technology apparatus, namely, computer hardware and computer software for
`monitoring, regulating and controlling data relating to electrical power generation
`and power consumption and for wireless communication via a website portal ac-
`cessing the Internet, and for actuating and regulating electrical power generating
`equipment
`
`Application date
`
`07/11/2012
`
`Foreign priority
`date
`
`01/18/2012
`
`U.S. registration
`no.
`
`4412695
`
`Register
`
`Principal
`
`Registration date
`
`10/08/2013
`
`Word mark
`
`Design mark
`
`SUNNY MULTIGATE
`
`Description of
`mark
`
`NONE
`
`

`

`Goods/services
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Apparatus and instruments for conducting, switching, transforming, accumulat-
`ing, regulating and controlling electricity, namely, hardware and software for
`over-voltage protection in photo voltaic installations and for analyzing and sur-
`veying of energy supplies and voltage and current flows in photo voltaic installa-
`tions; apparatus and instruments for measuring and analyzing electricity,
`namely, conductivity meters, transformers, voltage regulators for electric power,
`electrical controllers; data process equipment,namely, hardware and software
`for communication in PV installations, for measuring and diagnosing data in
`photo voltaicinstallations, for collecting and transmitting data in photo voltaic in-
`stallations, for connecting photo voltaic installations with the Internet, for monit-
`oring the data of a solar plant or an invertor
`
`U.S. registration
`no.
`
`4650843
`
`Register
`
`Principal
`
`Registration date
`
`12/09/2014
`
`Word mark
`
`Design mark
`
`SUNNY
`
`Application date
`
`04/24/2013
`
`Foreign priority
`date
`
`10/26/2012
`
`Description of
`mark
`
`Goods/services
`
`NONE
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Apparatus and instruments for conducting, switching, transforming, storing, reg-
`ulating and controlling electric current; apparatus and instruments for measuring
`and analyzing electric current, namely, conductivity meters, voltage regulators
`for electric power, electrical controllers, electrical fuses, safety switches,cutout
`switches, switch boxes, meters and gauges for the analyzing of electric current;
`software, namely, downloadable computer software for controlling and man-
`aging of electricity, electricity consumption and inverters; electric luminescent
`display panels; data processing apparatus for use solely in the renewable en-
`ergy field.
`Class 038. First use: First Use: None First Use In Commerce: None
`Providing access to an Internet platform for the monitoring of photovoltaic install-
`ations; providing access to an Internet platform for the management and the
`presentation of the performance data of energy management tools
`Class 042. First use: First Use: None First Use In Commerce: None
`Design and maintenance of websites for others for the management and
`presentation of performance data of energy management tools
`
`U.S. registration
`no.
`
`4824412
`
`Register
`
`Principal
`
`Registration date
`
`10/06/2015
`
`Word mark
`
`SUNNY PLACES
`
`Application date
`
`07/30/2014
`
`Foreign priority
`date
`
`02/19/2014
`
`

`

`Design mark
`
`Description of
`mark
`
`Goods/services
`
`NONE
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Computer software for controlling and management of apparatus for the energy
`management; software for the presentation of data of apparatus for the energy
`management; software for providing multiple user access to an Internet platform
`regarding energy management
`Class 038. First use: First Use: None First Use In Commerce: None
`Providing multiple user access to an internet platform regarding energy manage-
`ment; telecommunication using internet platforms and internet gateways regard-
`ing energy management, namely, providing access to an internet platform for
`the monitoring of photovoltaic installations; providing access to an internet plat-
`form for the management and the presentation of the performance data of en-
`ergy management tools
`Class 042. First use: First Use: None First Use In Commerce: None
`Providing technological advice and consultancy in connection with energy man-
`agement, namely, consultation in the field of computer and technology used for
`energy generation
`
`Attachments
`
`79219095#TMSN.png( bytes )
`79291780#TMSN.png( bytes )
`88878979#TMSN.png( bytes )
`78373659#TMSN.png( bytes )
`78428799#TMSN.png( bytes )
`79013290#TMSN.png( bytes )
`79204390#TMSN.png( bytes )
`79057625#TMSN.png( bytes )
`79219096#TMSN.png( bytes )
`79119166#TMSN.png( bytes )
`79119165#TMSN.png( bytes )
`79131781#TMSN.png( bytes )
`79156913#TMSN.png( bytes )
`Notice of Opposition SMA Solar Technology AG 2022-03-29.pdf(26247 bytes )
`
`Signature
`
`/SJB/
`
`Name
`
`Date
`
`STEWART J. BELLUS
`
`03/29/2022
`
`

`

`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`-----------------------------------------------------------------------X
`SMA Solar Technology AG
`
`
`)
`)
`)
`)
`)
`)
`)
`)
` )
`)
`)
`)
`)
`-----------------------------------------------------------------------X
`
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`v.
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`
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`Sunnie, Inc.
`
`
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`
`
`
`
`
`
`
`
`
`
`
`
`Opposer,
`
`
`
`
`
`
`
`
`
`
`
`
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`Applicant
`
`
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`
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`
`
`Opposition No.
`Serial No. 88200602
`
`
`NOTICE OF OPPOSITION
`
`
`
`
`In the matter of an application for registration of the trademark SUNNIE for services in
`
`Class 42, filed on November 20, 2018 under Serial No. 88200602 by Sunnie, Inc. (“Applicant”),
`
`SMA Solar Technology AG (“Opposer”) believes it will be damaged by registration of said
`
`application and opposes same. The grounds for opposition are as follows:
`
`(BACKGROUND)
`
`1. Opposer is an AG (aktiengesellschaft) organized under the laws of Germany and located
`
`at Sonnenallee 1, Niestetal, Germany 34266.
`
`2. Opposer owns the following marks and registrations (OPPOSER’S MARKS”):
`
`
`
`
`
`1
`
`

`

`
`
`MARK
`
`SUNNY
`
`
`
`
`
`SUNNY PLACES
`
`
`
`
`
`
`
`SUNNY MULTIGATE
`
`
`
`
`
`
`
`4650843
`
`4824412
`
`4412695
`
`REGISTRATION NO.
`
`PRIORITY FILING DATE
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`October 26, 2012
`
` February 19, 2014
`
`January 18, 2012
`
`July 11, 2012
`
`February 22, 2017
`
`February 19, 2008
`
`August 31, 2016
`
`March 22, 2005
`
`June 2, 2004
`
`February 25, 2004
`
`November 2, 2000
`
`August 25, 1997
`
`April 20, 2020
`
`January 22, 2020
`
`February 22, 2017
`
`
`
`
`
`SUNNY HOME MANAGER
`
`4362880
`
`SUNNY HIGHPOWER
`
`SUNNY TRIPOWER
`
`
`
`
`
`5557783
`
`3587468
`
`SUNNY TRIPOWER CORE
`
`5382962
`
`SUNNY DESIGN
`
`
`
`SUNNY CENTRAL
`
`SUNNY PORTAL
`
`SUNNY ISLAND
`
`SUNNY BOY
`
`SUNNYCONNECT
`
`SONNENALLEE
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3145703
`
`3121666
`
`2996025
`
`2854219
`
`2257897
`
`6451493
`
`6436404
`
`SUNNY HIGHPOWER PEAK
`
`5870338
`
`
`3. Application No. 88200602 for the mark SUNNIE (“APPLICANT’S MARK”) was filed
`
`on November 20, 2018, based on use since November 22, 2017.
`
`4. Opposer’s rights in 13 out of 15 OPPOSER’S MARKS date back to its priority filing
`
`dates, which are before Applicant’s filng date, so OPPOSER has prior rights.
`
`
`
`
`
`
`
`2
`
`

`

`
`
`
`
`Count I (Likelihood of Confusion)
`
`5. Opposer incorporates by reference all the allegations contained in paragraphs 1-4 of this
`
`Notice of Opposition.
`
`6. The commercial impression of APPLICANT’S MARK is extremely similar to
`
`OPPOSER’S MARKS and contains the key element of OPPOSER’S MARKS “SUNNY.”
`
`7. Applicant’s services, as described in Application Serial Number 88200602 are identical
`
`or closely related to goods and services described in Opposer’s registrations for OPPOSER’S
`
`MARKS.
`
` 8. Due to similarities between Opposer’s and Applicant’s marks and the closely related
`
`services upon which those marks are used, there is a likelihood that consumers will be confused,
`
`mistaken and/or deceived into believing that Applicant’s services emanate from, or in some way
`
`are associated or connected with, or sponsored, authorized or warranted by Opposer, all to the
`
`detriment of Opposer, and Opposer will be damaged if a registration is granted to Applicant.
`
`Count II (Dilution by Blurring)
`
`9.
`
`Opposer incorporates by reference the allegations contained in paragraphs 1-8 of this
`
`Notice of Opposition.
`
`
`
`10. OPPOSER’S MARKS are famous and distinctive throughout the United States, and were
`
`famous and distinctive before Applicant’s filing of its mark. OPPOSER’S MARKS have been
`
`used and advertised extensively, and are widely recognized by consumers and in the trade as a
`
`designation of source for the goods of Opposer, and is therefore a famous and distinctive mark.
`
`
`
`3
`
`

`

`
`
`11.
`
`Applicant’s use of its mark is in violation of Section 43 (c) of the Lanham Act in that
`
`APPLICANT’S MARK is likely to cause dilution by blurring by creating a likelihood of
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`association with OPPOSER’S MARKS.
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`12. Applicant’s use of its mark will cause an association arising from the similarity
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`with OPPOSER’S MARKS that will cause dilution by blurring and impair the distinctiveness of
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`OPPOSER’S MARKS, all to the detriment of Opposer who will be damaged by Applicant’s use
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`of its mark.
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` WHEREFORE, Opposer requests that this opposition be sustained and that the requested
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`registration of APPLICANT’S MARK in Application Serial Number 88200602 be denied.
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`SMA Solar Technology AG
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`Stewart J. Bellus
`Sara M. Dorchak
`COLLARD & ROE, P.C.
`1077 Northern Boulevard
`Roslyn, New York 11576
`Telephone: (516) 365-9802
`Email: sbellus@collardroe.com
`sdorchak@collardroe.com
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`Attorneys for Opposer
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`Date: March 29, 2022
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`4
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the forgoing NOTICE OF
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`OPPOSITION has this 29th day of March, 2022 been sent by e-mail to the addresses on file at
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`the USPTO:
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`Vivek Vaidya
`Bend Law Group, PC
`2181 Greenwich St.
`San Francisco, CA 94123
`vivek@blgtrademarks.com
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`Stewart J. Bellus
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`5
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