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`ESTTA1320856
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`Filing date:
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`11/08/2023
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding no.
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`91287462
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`Party
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`Correspondence
`address
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`Defendant
`Korea Agro-Fisheries Trade Corporation and Korea Forest Service, Government
`Agency
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`G MATHEW LOMBARD
`LOMBARD & GELIEBTER LLP
`230 PARK AVE
`4 FLOOR WEST
`NEW YORK, NY 10169
`UNITED STATES
`Primary email: mlombard@lgtrademark.com
`Secondary email(s): ipdocket@lombardip.com, uspto@dockettrak.com
`917-779-9967
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`Submission
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`Filer's name
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`Filer's email
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`Signature
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`Date
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`Other Motions/Submissions
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`G. Mathew Lombard
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`mlombard@lgtrademark.com
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`/g mathew lombard/
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`11/08/2023
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`Attachments
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`Motion to Amend-Withdraw with Consent_Executed.pdf(286707 bytes )
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Opposition No. 91287462
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`Application Serial No. 79352283
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`WELLNESS PET, LLC
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`Opposer,
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`v.
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`KOREA AGRO-FISHERIES
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`—and—
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`KOREA FOREST SERVICE,
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`Applicants.
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`CONSENTED MOTION TO AMEND IDENTIFICATION
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`AND WITHDRAW OPPOSITION
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`Pursuant to TBMP § 514.02, 37 CFR § 2.133, with Opposer’s express consent, Applicant
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`moves to amend the identification of goods in Application No. 79352283 as shown below
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`(deleted goods shown in bold and strikethrough):
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`Preserved mushrooms; preserved truffles; preserved shiitake mushrooms; dried
`edible mushrooms; processed chestnuts; dried persimmons; dried fruits; dried
`fruit mixes; dried vegetables; preserved fruits; preserved vegetable in Class 29;
`and
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`Fresh potatoes; fresh mushrooms; roots for food for animal consumption; fresh
`truffles; fresh vegetables; fresh persimmons; fresh citrus fruit; fresh hazelnuts;
`fresh peanuts; fresh chestnuts; fresh watermelons; fresh fruit; fresh berries, fresh
`fruits; fresh almonds; fresh plums; mushroom spawn for propagation in Class 31.
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`Accordingly, the final, operative identification of goods in Application Serial No.
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`79352283 will read as follows:
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`Preserved mushrooms; preserved truffles; preserved shiitake mushrooms; dried
`edible mushrooms; processed chestnuts; dried persimmons; dried fruits; dried
`fruit mixes; dried vegetables; preserved fruits; preserved vegetable in Class 29;
`and
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`Fresh potatoes; fresh mushrooms; fresh truffles; fresh vegetables; fresh
`persimmons; fresh citrus fruit; fresh hazelnuts; fresh peanuts; fresh chestnuts;
`fresh watermelons; fresh fruit; fresh berries, fresh fruits; fresh almonds; fresh
`plums; mushroom spawn for propagation in Class 31.
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`Furthermore, pursuant to TBMP § 601.01, 37 CFR § 2.106(c), upon approval of the
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`proposed amendment by the Board, Opposer withdraws its Notice of Opposition.
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`The Parties indicate their consent to said amendment of the application and withdrawal of
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`the Notice of Opposition by signature of the parties’ counsel below.
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`As the amendment deletes a good from the original identification, the requested
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`amendment permissibly narrows the scope of the Class 31 recitation, and is therefore permitted.
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`No changes have been made to Class 29.
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`When a request to amend an application or registration that is the subject of a Board
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`inter partes proceeding is made with the consent of the other party, and the proposed
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`amendment is in accordance with the applicable rules and statutory provisions, the request
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`ordinarily will be approved by the Board. TBMP § 514.02.
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`When a consented motion to amend the application or registration that is the subject of a
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`Board inter partes proceeding is filed in lieu of an Answer (as is the case here), the parties
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`should not file a subsequent scheduling motion until the Board determines the motion to
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`amend. In such a situation, when a consented motion to amend is pending, the Board will not
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`issue a notice of default. Id; cf. TBMP § 312.01.
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`4880-7340-9167, v. 2
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`WHEREFORE, Applicants, with Opposer’s consent, request:
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`1.
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`2.
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`That the goods in the subject application be amended as indicated above; and
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`Once the amendment is approved by the Board, the instant opposition be
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`withdrawn pursuant to TBMP § 601.01 and 37 CFR § 2.106(c).
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`Dated: November 8, 2023
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`Respectfully submitted,
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`LOMBARD & GELIEBTER LLP
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`By: ____________________________
` G. Mathew Lombard
` 230 Park Avenue
` 4th Floor West
` New York, NY 10169
` 917.779.9967 (telephone)
` 646.349.5567 (facsimile)
` mlombard@lgtrademark.com
` Attorneys for Applicants
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`MCNEES WALLACE & NURICK LLC
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`By: ____/Lois B. Duquette/___________
` Lois B. Duquette
` 100 Pine Street
` Harrisburg, PA 17101
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` 717.232.8000 (telephone)
` 717.237.5300 (facsimile)
` lduquette@mcneeslaw.com
` Attorneys for Opposer
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`4880-7340-9167, v. 2
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`CERTIFICATE OF SERVICE
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`I hereby certify that the foregoing CONSENTED MOTION TO AMEND
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`IDENTIFICATION AND WITHDRAW OPPOSITION was served on counsel for
`Opposer by email, as required by C.F.R. § 2.119 and TBMP § 113.04, on
`November 8, 2023, at:
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`Lois B. Duquette, Esq.
`MCNEES WALLACE & NURICK LLC
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`100 Pine Street
`Harrisburg, Pennsylvania 17101
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`trademarks@mcneeslaw.com
`lduquette@mcneeslaw.com
`tgulick@mcneeslaw.com
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`By: ________________________
` G. Mathew Lombard
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