ESTTA Tracking number:
`
`Filing date:
`
`ESTTA1436993
`05/21/2025
`
`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
`
`Entity
`
`Address
`
`RDSTR IP 2 AB
`
`Aktiebolag
`
`FRIHAMNEN 16 A
`GOTEBORG, 41755
`SWEDEN
`
`Incorporated or
`registered in
`
`SE
`
`Attorney informa-
`tion
`
`JAMES F KEENAN JR.
`BERNSTEIN SHUR
`100 MIDDLE STREET
`PORTLAND, ME 04104
`UNITED STATES
`Primary email: jkeenan@bernsteinshur.com
`Secondary email(s): dpaulick@bernsteinshur.com
`2072287207
`
`Docket no.
`
`Applicant information
`
`Application no.
`
`98758801
`
`Opposition filing
`date
`
`Applicant
`
`05/21/2025
`
`Publication date
`
`04/29/2025
`
`Opposition period
`ends
`
`05/29/2025
`
`Wang, Pengcheng
`SHANGHAI MANSION, LINGANG DISTRICT
`WEIHAI, SHANDONG, 264200
`China
`
`Goods/services affected by opposition
`
`Class 025. First Use: Sep 3, 2024 First Use In Commerce: Sep 3, 2024
`All goods and services in the class are opposed, namely: Athletic jackets; Athletic pants; Athletic tops
`and bottoms for skiing; Athletic uniforms; Shirts and short-sleeved shirts; Short-sleeved or long-
`sleeved t-shirts; Ski and snowboard shoes and parts thereof; Ski bibs; Ski jackets; Ski pants; Ski
`suits; Ski wear; Snowboard jackets; Snowboard pants; Winter coats
`
`Grounds for opposition
`
`Priority and likelihood of confusion
`
`Trademark Act Section 2(d)
`
`Marks cited by opposer as basis for opposition
`
`U.S. application
`no.
`
`90333343
`
`Application date
`
`11/20/2020
`
`Registration date
`
`NONE
`
`Foreign priority
`date
`
`NONE
`
`

`

`Word mark
`
`Design mark
`
`DOPE
`
`Description of
`mark
`
`Goods/services
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Equipment used for skiing and snowboarding, namely, ski and snowboard hel-
`mets, ski and snowboard goggles; ski and snowboard gloves for protection
`against accidents; Downloadable communication software for providing access
`to the internet; Downloadable computer software for administration of computer
`networks; Downloadable computer software for accessing social networks;
`Downloadable software and downloadable mobile applications for accessing in-
`ternet forums, message boards, chat rooms, social networks and for providing
`online messaging; Downloadable interactive computer software for enabling the
`exchange of information in the fields of skiing, snowboarding, winter sports and
`travel; Downloadable computer software for providing ski, snowboard and winter
`sports travel information; Downloadable electronic publications in the nature of
`newsletters in the fields of skiing, snowboarding, winter sports and travel; Down-
`loadable podcasts and video podcasts in the fields of skiing, snowboarding,
`winter sports and travel
`Class 025. First use: First Use: None First Use In Commerce: None
`Ski and Snowboard outwear, namely thermal pants and jackets, shell jackets
`and pants, and water resistant and waterproof jackets and pants; Ski and Snow-
`board clothing, namely, tops and bottoms; Ski and snowboard apparel, namely,
`headwear, footwear, neck tube scarves, balaclavas and gloves; Ski and Snow-
`board apparel, namely, underwear, thermal underwear and sweat-absorbent un-
`derwear
`Class 028. First use: First Use: None First Use In Commerce: None
`Equipment used for skiing and snowboarding, namely, cases, backpacks and
`bags specially adapted for carrying skis and snowboards; Skis; Snowboards;
`Knee guards for athletic use in skiing and snowboarding; Elbow guards for ath-
`letic use in skiing and snowboarding; Protective padding for skiing and snow-
`boarding
`Class 035. First use: First Use: None First Use In Commerce: None
`Retail store services and online retail store services featuring clothing, footwear,
`headgear, clothing for skiing, clothing for snowboarding, neck tube scarves, ski
`balaclavas, gloves, ski gloves, helmets for use in sports, ski helmets, snowboard
`helmets, snow goggles, snowboard goggles, scooter goggles, goggles for
`sports, gloves for protection against accidents, sunglasses, ear phones, bags,
`sports packs, kit bags, backpacks, rucksacks, toiletry bags, pocket wallets, key
`cases, umbrellas, sporting articles, sporting equipment, protective padding for
`skiing and snowboarding and cases adapted for sporting articles
`
`U.S. registration
`no.
`
`4595333
`
`Register
`
`Principal
`
`Registration date
`
`09/02/2014
`
`Application date
`
`05/13/2013
`
`Foreign priority
`date
`
`NONE
`
`

`

`Word mark
`
`Design mark
`
`DOPEST
`
`Description of
`mark
`
`Goods/services
`
`Class 025. First use: First Use: Jul 15, 2009 First Use In Commerce: Jan 1,
`2010
`Hats; Jackets; Pants; Shirts; Shoes; Shorts; Sweaters
`
`U.S. registration
`no.
`
`4918788
`
`Register
`
`Principal
`
`Registration date
`
`03/15/2016
`
`Word mark
`
`Design mark
`
`DOPE
`
`Application date
`
`05/28/2014
`
`Foreign priority
`date
`
`NONE
`
`Description of
`mark
`
`Goods/services
`
`Class 025. First use: First Use: Dec 2008 First Use In Commerce: Dec 2008
`Athletic apparel, namely, pants; Boxer shorts; Crew neck sweaters; Gym suits;
`Jogging suits; Socks; Sweaters; Swim trunks; Swim wear for gentlemen; V-neck
`sweaters; Women's clothing, namely, shirts, skirts
`
`U.S. registration
`no.
`
`6822934
`
`Register
`
`Principal
`
`Registration date
`
`08/23/2022
`
`Word mark
`
`DOPE
`
`Application date
`
`11/20/2020
`
`Foreign priority
`date
`
`

`

`Design mark
`
`Description of
`mark
`
`Goods/services
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Helmets for use in sports; ski helmets; snowboard helmets; snow scooter hel-
`mets; helmets for bicycles; sport bags adapted and specially shaped to contain
`protective helmets; visors for helmets; face-protection shields for protective hel-
`mets; snow goggles; snowboard goggles; scooter goggles; goggles for sports;
`gloves for protection against accidents; sunglasses; covers for sunglasses; ear
`phones
`Class 018. First use: First Use: None First Use In Commerce: None
`Weekend, travelling and sports bags; Sports packs; Kit bags; Rucksacks; Toi-
`letry bags sold empty; Pocket wallets; Key cases; Umbrellas
`Class 025. First use: First Use: None First Use In Commerce: None
`Clothing for skiing and hiking, namely, ski jackets and ski pants, water resistant
`and waterproof jackets and pants; clothing for snowboarding, namely, snow-
`boarding jackets and snowboarding pants, water resistant and waterproof jack-
`ets and pants; tops being clothing; undershirts; sports jerseys; pants; jackets be-
`ing clothing; outer clothing, namely, jackets, coats, tops as clothing; shorts; swim
`shorts; swim wear; long johns; sweat-absorbent underwear; underwear; socks;
`stockings; stockings for skiing; footwear; shoes; snowboard shoes; scooter
`shoes; headwear; caps being headwear; caps with visors; sports headwear,
`namely, beanies, hats and caps other than helmets; headbands; neckerchiefs;
`neck tube scarves; balaclavas; ski balaclavas; gloves; ski gloves; fingerless
`gloves; garters; belts being clothing
`Class 028. First use: First Use: None First Use In Commerce: None
`Sporting articles and equipment, namely, cases adapted for sporting articles,
`cases, backpacks and bags specially adapted for carrying skis and snowboard;
`ski bags; skis; ski sticks; snowboards; skateboards; knee guards for athletic use;
`elbow guards for athletic use
`
`U.S. registration
`no.
`
`4403067
`
`Application date
`
`02/05/2013
`
`

`

`Register
`
`Principal
`
`Registration date
`
`09/17/2013
`
`Word mark
`
`Design mark
`
`DOPE
`
`Foreign priority
`date
`
`NONE
`
`Description of
`mark
`
`Goods/services
`
`U.S. application
`no.
`
`Class 025. First use: First Use: Jul 27, 2007 First Use In Commerce: Jul 27,
`2007
`Hats
`
`90333369
`
`Application date
`
`11/20/2020
`
`Registration date
`
`NONE
`
`Word mark
`
`Design mark
`
`DOPE SNOW
`
`Foreign priority
`date
`
`NONE
`
`Description of
`mark
`
`Goods/services
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Helmets for use in sports; Ski helmets; Snowboard helmets; Snow scooter hel-
`mets; Helmets for bicycles; Sport bags specially adapted to contain protective
`helmets; Visors for helmets; Protective face-protection shields for protective hel-
`mets; Snow goggles; Snowboard goggles; Goggles for sports; Gloves for protec-
`tion against accidents; Sunglasses; Cases for sunglasses; Ear phones; Down-
`loadable communication software for providing access to the internet; Down-
`loadable computer software for administration of computer networks; Download-
`able computer software for accessing social networks; Downloadable software
`and downloadable mobile applications for accessing internet forums, message
`boards, chat rooms, social networks and for providing online messaging; Down-
`loadable interactive computer software for enabling the exchange of information
`in the fields of skiing, snowboarding, winter sports and travel; Downloadable
`computer software for providing ski, snowboard and winter sports travel informa-
`tion; Downloadable electronic publications in the nature of newsletters in the
`fields of skiing, snowboarding, winter sports and travel; Downloadable podcasts
`and video podcasts in the fields of skiing, snowboarding, winter sports and travel
`Class 025. First use: First Use: None First Use In Commerce: None
`Clothing, namely, tops, bottoms, headwear and footwear; Sportswear clothing,
`
`

`

`namely, tops, bottoms, headwear and footwear; Clothing for skiing, namely ski
`jackets and ski pants; Clothing for snowboarding, namely snowboard jackets
`and snowboard pants; Tops as clothing; Undershirts; Sports jerseys; Pants;
`Jackets; Outerwear, namely thermal pants and jackets, shell jackets and pants,
`and water resistant and waterproof jackets and pants; Shorts; Swim shorts;
`Swim wear; Long Johns; Sweat-absorbent underwear; Underwear; Socks;
`Stockings; Stockings for skiing; Footwear; Shoes; Snowboard shoes; Scooter
`shoes; Caps being headwear; Caps with visors; Headgear, namely sports
`headgear other than helmets; Headbands as clothing; Neckerchiefs; Neck tube
`scarves; Balaclavas; Ski balaclavas; Gloves; Ski gloves; Fingerless gloves;
`Garters; Belts being clothing
`Class 028. First use: First Use: None First Use In Commerce: None
`Sporting articles and equipment, namely, cases, backpacks and bags specially
`adapted for carrying skis, snowboards and sporting articles; Ski bags; Skis; Ski
`sticks; Snowboards; Skateboards; Knee guards for athletic use; Elbow guards
`for athletic use; Protective padding for skiing and snowboarding
`Class 035. First use: First Use: None First Use In Commerce: None
`Retail store services and online retail store services featuring clothing, footwear,
`headgear, clothing for skiing, clothing for snowboarding, neck tube scarves, ski
`balaclavas, gloves, ski gloves, helmets for use in sports, ski helmets, snowboard
`helmets, snow goggles, snowboard goggles, scooter goggles, goggles for
`sports, gloves for protection against accidents, sunglasses, ear phones, bags,
`sports packs, kit bags, rucksacks, toiletry bags, pocket wallets, key cases, um-
`brellas, sporting articles, sporting equipment, protective padding for skiing and
`snowboarding and cases adapted for sporting articles
`
`U.S. registration
`no.
`
`4547955
`
`Register
`
`Principal
`
`Registration date
`
`06/10/2014
`
`Word mark
`
`Design mark
`
`DOPE
`
`Application date
`
`07/19/2011
`
`Foreign priority
`date
`
`NONE
`
`Description of
`mark
`
`Goods/services
`
`U.S. application
`no.
`
`Class 025. First use: First Use: Dec 2008 First Use In Commerce: Dec 2008
`Coats for men and women; Headwear; Jackets; Shirts; Shorts; Wind resistant
`jackets
`
`90333365
`
`Application date
`
`11/20/2020
`
`Registration date
`
`NONE
`
`Word mark
`
`DOPE
`
`Foreign priority
`date
`
`NONE
`
`

`

`Design mark
`
`Description of
`mark
`
`Goods/services
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Equipment used for skiing and snowboarding, namely, ski and snowboard hel-
`mets, ski and snowboard goggles; ski and snowboard gloves for protection
`against accidents; Downloadable communication software for providing access
`to the internet; Downloadable computer software for administration of computer
`networks; Downloadable computer software for accessing social networks;
`Downloadable software and downloadable mobile applications for accessing in-
`ternet forums, message boards, chat rooms, social networks and for providing
`online messaging; Downloadable interactive computer software for enabling the
`exchange of information in the fields of skiing, snowboarding, winter sports and
`travel; Downloadable computer software for providing ski, snowboard and winter
`sports travel information; Downloadable electronic publications in the nature of
`newsletters in the fields of skiing, snowboarding, winter sports and travel; Down-
`loadable podcasts and video podcasts in the fields of skiing, snowboarding,
`winter sports and travel
`Class 025. First use: First Use: None First Use In Commerce: None
`Ski and Snowboard outwear, namely thermal pants and jackets, shell jackets
`and pants, and water resistant and waterproof jackets and pants; Ski and Snow-
`board clothing, namely, tops and bottoms; Ski and snowboard apparel, namely,
`headwear, footwear, neck tube scarves, balaclavas and gloves; Ski and Snow-
`board apparel, namely, underwear, thermal underwear and sweat-absorbent un-
`derwear
`Class 028. First use: First Use: None First Use In Commerce: None
`Equipment used for skiing and snowboarding, namely, cases, backpacks and
`bags specially adapted for carrying skis and snowboards; Skis; Snowboards;
`Knee guards for athletic use in skiing and snowboarding; Elbow guards for ath-
`letic use in skiing and snowboarding; Protective padding for skiing and snow-
`boarding
`Class 035. First use: First Use: None First Use In Commerce: None
`Retail store services and online retail store services featuring clothing, footwear,
`headgear, clothing for skiing, clothing for snowboarding, neck tube scarves, ski
`balaclavas, gloves, ski gloves, helmets for use in sports, ski helmets, snowboard
`helmets, snow goggles, snowboard goggles, scooter goggles, goggles for
`sports, gloves for protection against accidents, sunglasses, ear phones, bags,
`sports packs, kit bags, backpacks, rucksacks, toiletry bags, pocket wallets, key
`cases, umbrellas, sporting articles, sporting equipment, protective padding for
`skiing and snowboarding and cases adapted for sporting articles
`
`Attachments
`
`90333343#TMSN.png( bytes )
`
`

`

`85930325#TMSN.png( bytes )
`86293042#TMSN.png( bytes )
`79300325#TMSN.png( bytes )
`85841683#TMSN.png( bytes )
`90333369#TMSN.png( bytes )
`85375315#TMSN.png( bytes )
`90333365#TMSN.png( bytes )
`20250521 - Notice of Opposition - OUTDOPE - 98758801.pdf(603688 bytes )
`
`Signature
`
`/James F. Keenan/
`
`Name
`
`Date
`
`James F. Keenan, Jr
`
`05/21/2025
`
`

`

`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`In the Matter of
`
`
`
`
`Mark:
`
`
`Appl. Ser. No.:
`
`Appl. Date:
`
`
`
`
`
`OUTDOPE
`
`98/758,801
`
`September 19, 2024
`
`
`
`------------------------------------------------------:
`
`
`
`
`
`
`:
`RDSTR IP 2 AB,
`
`
`
`:
`
`
`
`
`
`
`:
`Opposer,
`
`:
`:
`:
`
`
`
`vs.
`
`
`:
`
`
`
`
`
`
`:
`
`
`
`Pengcheng Wang,
`:
`
`
`
`
`
`
`:
`
`Applicant.
`
`
`
`:
`
`
`
`
`
`
`------------------------------------------------------:
`
`
`NOTICE OF OPPOSITION
`
`
`
`Opposer, RDSTR IP 2 AB, is a Swedish Aktiebolag with an address of Frihamnen 16 A
`
`Goteborg, Sweden 41755.
`
`To the best of Opposer’s knowledge, Applicant, Pengcheng Wang, is an individual with
`
`an address of Shanghai Mansion, Lingang District, Weihai, Shandong China 264200.
`
`Opposer believes it will be damaged by the registration of the above-identified trademark
`
`and hereby opposes the same.
`
`The grounds for opposition are as follows:
`
`Grounds for Opposition – Priority and Likelihood of Confusion
`
`1. To the best of Opposer’s knowledge, Applicant is the current owner of U.S. Appl.
`
`Ser. No. 98/758,801 for the following trademark (the “‘801 Application”):
`
`
`
`
`
`1
`
`

`

`
`
` A
`
`Trademark
`
`OUTDOPE
`
`App. No. /
`App. Date
`98/758,801
`September 19, 2024
`
`Goods/Services
`
`025: Athletic jackets; Athletic pants; Athletic
`tops and bottoms for skiing; Athletic uniforms;
`Shirts and short-sleeved shirts; Short-sleeved or
`long-sleeved t-shirts; Ski and snowboard shoes
`and parts thereof; Ski bibs; Ski jackets; Ski
`pants; Ski suits; Ski wear; Snowboard jackets;
`Snowboard pants; Winter coats
`
` copy of the TSDR details from the U.S. Patent and Trademark Office for the ‘801 Application
`
`is attached as Exhibit A.
`
`2. Opposer owns numerous applications and registrations for the trademarks DOPE and
`
`the term DOPE combined with other terms and/or designs, including without limitation, the
`
`following (collectively, “Opposer’s Trademarks”):
`
`Trademark
`
`DOPE
`
`Reg. No.
`Reg. Date
`4918788
`March 15, 2016
`
`
`App No.
`App. Date
`86293042
`May 28, 2014
`
`
`DOPE
`
`DOPE
`
`4403067
`September 17, 2013
`
`85841683
`February 5, 2013
`
`4547955
`June 10, 2014
`
`
`85375315
`July 19, 2011
`
`
`
`
`2
`
`Goods/Services
`
`025: Athletic apparel,
`namely, pants; Boxer
`shorts; Crew neck
`sweaters; Gym suits;
`Jogging suits; Socks;
`Sweaters; Swim trunks;
`Swim wear for
`gentlemen; V-neck
`sweaters; Women's
`clothing, namely, shirts,
`skirts
`
`025: Hats
`
`
`025: Coats for men and
`women; Headwear;
`Jackets; Shirts; Shorts;
`Wind resistant jackets
`
`
`

`

`
`
`
`
`DOPEST
`
`4595333
`September 2, 2014
`
`85930325
`May 13, 2013
`
`
`6822934
`August 23, 2022
`
`79300325
`November 20, 2020
`
`
`
`025: Hats; Jackets; Pants;
`Shirts; Shoes; Shorts;
`Sweaters
`
`009: Helmets for use in
`sports; ski helmets;
`snowboard helmets; snow
`scooter helmets; helmets
`for bicycles; sport bags
`adapted and specially
`shaped to contain
`protective helmets; visors
`for helmets; face-
`protection shields for
`protective helmets; snow
`goggles; snowboard
`goggles; scooter goggles;
`goggles for sports; gloves
`for protection against
`accidents; sunglasses;
`covers for sunglasses; ear
`phones
`
`018: Weekend, travelling
`and sports bags; Sports
`packs; Kit bags;
`Rucksacks; Toiletry bags
`sold empty; Pocket
`wallets; Key cases;
`Umbrellas
`
`025: Clothing for skiing
`and hiking, namely, ski
`jackets and ski pants,
`water resistant and
`waterproof jackets and
`pants; clothing for
`snowboarding, namely,
`snowboarding jackets and
`snowboarding pants,
`water resistant and
`waterproof jackets and
`pants; tops being
`clothing; undershirts;
`
`3
`
`

`

`
`
`
`
`sports jerseys; pants;
`jackets being clothing;
`outer clothing; shorts;
`swim shorts; swim wear;
`long johns; sweat-
`absorbent underwear;
`underwear; socks;
`stockings; stockings for
`skiing; footwear; shoes;
`snowboard shoes; scooter
`shoes; headgear; caps
`being headwear; caps
`with visors; sports
`headgear, namely,
`beanies, hats and caps
`other than helmets;
`headbands; neckerchiefs;
`neck tube scarves;
`balaclavas; ski balaclavas;
`gloves; ski gloves;
`fingerless gloves; garters;
`belts being clothing
`
`028: Sporting articles and
`equipment, namely, cases
`adapted for sporting
`articles, cases, backpacks
`and bags specially
`adapted for carrying skis
`and snowboard; ski bags;
`skis; ski sticks;
`snowboards; skateboards;
`knee guards for athletic
`use; elbow guards for
`athletic use
`
`
`009: Helmets for use in
`sports; Ski helmets;
`Snowboard helmets;
`Snow scooter helmets;
`Helmets for bicycles;
`Sport bags specially
`adapted to contain
`
`DOPE
`SNOW
`
`N/A
`
`90333369
`November 20, 2020
`
`4
`
`

`

`
`
`
`
`protective helmets; Visors
`for helmets; Protective
`face-protection shields for
`protective helmets; Snow
`goggles; Snowboard
`goggles; Goggles for
`sports; Gloves for
`protection against
`accidents; Sunglasses;
`Cases for sunglasses; Ear
`phones; Downloadable
`communication software
`for providing access to
`the internet;
`Downloadable computer
`software for
`administration of
`computer networks;
`Downloadable computer
`software for accessing
`social networks;
`Downloadable software
`and downloadable mobile
`applications for accessing
`internet forums, message
`boards, chat rooms, social
`networks and for
`providing online
`messaging;
`Downloadable interactive
`computer software for
`enabling the exchange of
`information in the fields
`of skiing, snowboarding,
`winter sports and travel;
`Downloadable computer
`software for providing
`ski, snowboard and winter
`sports travel information;
`Downloadable electronic
`publications in the nature
`of newsletters in the fields
`of skiing, snowboarding,
`winter sports and travel;
`
`5
`
`

`

`
`
`
`
`Downloadable podcasts
`and video podcasts in the
`fields of skiing,
`snowboarding, winter
`sports and travel
`
`025: Clothing, namely,
`tops, bottoms, headwear
`and footwear; Sportswear
`clothing, namely, tops,
`bottoms, headwear and
`footwear; Clothing for
`skiing, namely ski jackets
`and ski pants; Clothing
`for snowboarding, namely
`snowboard jackets and
`snowboard pants; Tops as
`clothing; Undershirts;
`Sports jerseys; Pants;
`Jackets; Outerwear,
`namely thermal pants and
`jackets, shell jackets and
`pants, and water resistant
`and waterproof jackets
`and pants; Shorts; Swim
`shorts; Swim wear; Long
`Johns; Sweat-absorbent
`underwear; Underwear;
`Socks; Stockings;
`Stockings for skiing;
`Footwear; Shoes;
`Snowboard shoes;
`Scooter shoes; Caps being
`headwear; Caps with
`visors; Headgear, namely
`sports headgear other than
`helmets; Headbands as
`clothing; Neckerchiefs;
`Neck tube scarves;
`Balaclavas; Ski
`balaclavas; Gloves; Ski
`gloves; Fingerless gloves;
`Garters; Belts being
`clothing
`
`6
`
`

`

`
`
`
`
`
`028: Sporting articles and
`equipment, namely, cases,
`backpacks and bags
`specially adapted for
`carrying skis, snowboards
`and sporting articles; Ski
`bags; Skis; Ski sticks;
`Snowboards;
`Skateboards; Knee guards
`for athletic use; Elbow
`guards for athletic use;
`Protective padding for
`skiing and snowboarding
`
` 035: Retail store services
`and online retail store
`services featuring
`clothing, footwear,
`headgear, clothing for
`skiing, clothing for
`snowboarding, neck tube
`scarves, ski balaclavas,
`gloves, ski gloves,
`helmets for use in sports,
`ski helmets, snowboard
`helmets, snow goggles,
`snowboard goggles,
`scooter goggles, goggles
`for sports, gloves for
`protection against
`accidents, sunglasses, ear
`phones, bags, sports
`packs, kit bags,
`rucksacks, toiletry bags,
`pocket wallets, key cases,
`umbrellas, sporting
`articles, sporting
`equipment, protective
`padding for skiing and
`snowboarding and cases
`adapted for sporting
`articles
`
`
`7
`
`

`

`
`
`
`
`N/A
`
`90333365
`November 20, 2020
`
`
`
`009: Equipment used for
`skiing and snowboarding,
`namely, ski and
`snowboard helmets, ski
`and snowboard goggles;
`ski and snowboard gloves
`for protection against
`accidents; Downloadable
`communication software
`for providing access to
`the internet;
`Downloadable computer
`software for
`administration of
`computer networks;
`Downloadable computer
`software for accessing
`social networks;
`Downloadable software
`and downloadable mobile
`applications for accessing
`internet forums, message
`boards, chat rooms, social
`networks and for
`providing online
`messaging;
`Downloadable interactive
`computer software for
`enabling the exchange of
`information in the fields
`of skiing, snowboarding,
`winter sports and travel;
`Downloadable computer
`software for providing
`ski, snowboard and winter
`sports travel information;
`Downloadable electronic
`publications in the nature
`of newsletters in the fields
`of skiing, snowboarding,
`winter sports and travel;
`Downloadable podcasts
`and video podcasts in the
`fields of skiing,
`
`8
`
`

`

`
`
`
`
`snowboarding, winter
`sports and travel
`
`025: Ski and Snowboard
`outwear, namely thermal
`pants and jackets, shell
`jackets and pants, and
`water resistant and
`waterproof jackets and
`pants; Ski and Snowboard
`clothing, namely, tops
`and bottoms; Ski and
`snowboard apparel,
`namely, headwear,
`footwear, neck tube
`scarves, balaclavas and
`gloves; Ski and
`Snowboard apparel,
`namely, underwear,
`thermal underwear and
`sweat-absorbent
`underwear
`
`028: Equipment used for
`skiing and snowboarding,
`namely, cases, backpacks
`and bags specially
`adapted for carrying skis
`and snowboards; Skis;
`Snowboards; Knee guards
`for athletic use in skiing
`and snowboarding; Elbow
`guards for athletic use in
`skiing and snowboarding;
`Protective padding for
`skiing and snowboarding
`
`035: Retail store services
`and online retail store
`services featuring
`clothing, footwear,
`headgear, clothing for
`skiing, clothing for
`snowboarding, neck tube
`
`9
`
`

`

`
`
`
`
`scarves, ski balaclavas,
`gloves, ski gloves,
`helmets for use in sports,
`ski helmets, snowboard
`helmets, snow goggles,
`snowboard goggles,
`scooter goggles, goggles
`for sports, gloves for
`protection against
`accidents, sunglasses, ear
`phones, bags, sports
`packs, kit bags,
`backpacks, rucksacks,
`toiletry bags, pocket
`wallets, key cases,
`umbrellas, sporting
`articles, sporting
`equipment, protective
`padding for skiing and
`snowboarding and cases
`adapted for sporting
`articles
`
`009: Equipment used for
`skiing and snowboarding,
`namely, ski and
`snowboard helmets, ski
`and snowboard goggles;
`ski and snowboard gloves
`for protection against
`accidents; Downloadable
`communication software
`for providing access to
`the internet;
`Downloadable computer
`software for
`administration of
`computer networks;
`Downloadable computer
`software for accessing
`social networks;
`Downloadable software
`and downloadable mobile
`applications for accessing
`
`DOPE
`
`N/A
`
`90333343
`November 20, 2020
`
`10
`
`

`

`
`
`
`
`internet forums, message
`boards, chat rooms, social
`networks and for
`providing online
`messaging;
`Downloadable interactive
`computer software for
`enabling the exchange of
`information in the fields
`of skiing, snowboarding,
`winter sports and travel;
`Downloadable computer
`software for providing
`ski, snowboard and winter
`sports travel information;
`Downloadable electronic
`publications in the nature
`of newsletters in the fields
`of skiing, snowboarding,
`winter sports and travel;
`Downloadable podcasts
`and video podcasts in the
`fields of skiing,
`snowboarding, winter
`sports and travel
`
`025: Ski and Snowboard
`outwear, namely thermal
`pants and jackets, shell
`jackets and pants, and
`water resistant and
`waterproof jackets and
`pants; Ski and Snowboard
`clothing, namely, tops
`and bottoms; Ski and
`snowboard apparel,
`namely, headwear,
`footwear, neck tube
`scarves, balaclavas and
`gloves; Ski and
`Snowboard apparel,
`namely, underwear,
`thermal underwear and
`sweat-absorbent
`
`11
`
`

`

`
`
`
`
`underwear
`
`028: Equipment used for
`skiing and snowboarding,
`namely, cases, backpacks
`and bags specially
`adapted for carrying skis
`and snowboards; Skis;
`Snowboards; Knee guards
`for athletic use in skiing
`and snowboarding; Elbow
`guards for athletic use in
`skiing and snowboarding;
`Protective padding for
`skiing and snowboarding
`
`035: Retail store services
`and online retail store
`services featuring
`clothing, footwear,
`headgear, clothing for
`skiing, clothing for
`snowboarding, neck tube
`scarves, ski balaclavas,
`gloves, ski gloves,
`helmets for use in sports,
`ski helmets, snowboard
`helmets, snow goggles,
`snowboard goggles,
`scooter goggles, goggles
`for sports, gloves for
`protection against
`accidents, sunglasses, ear
`phones, bags, sports
`packs, kit bags,
`backpacks, rucksacks,
`toiletry bags, pocket
`wallets, key cases,
`umbrellas, sporting
`articles, sporting
`equipment, protective
`padding for skiing and
`snowboarding and cases
`adapted for sporting
`
`12
`
`

`

`
`
`
`
`articles
`
`
`True and correct copies of the Certificates of Registrations (as applicable) and TSDR details
`
`from the U.S. Patent and Trademark Office showing the current status and title of Opposer’s
`
`Trademarks are attached hereto as Exhibit B.
`
`3. Upon information and belief, Opposer’s earliest filing date and/or earliest dates of
`
`first use of Opposer’s Trademarks precede the earliest priority date Applicant can claim in
`
`relation to the ‘801 Application.
`
`4. The ‘801 Application seeks to register an identical or substantially similar trademark
`
`as Opposer’s Trademarks in association with identical or substantially similar goods to the goods
`
`covered by Opposer’s Trademarks.
`
`5. Accordingly, consumers are likely to confuse Applicant’s trademark as reflected in
`
`the ‘801 Application with Opposer’s Trademarks and/or otherwise perceive the two parties as
`
`being related to, endorsed by or associated with one another.
`
`6. Further, the registration of the ‘801 Application will dilute and weaken Opposer’s
`
`Trademarks.
`
`7. If Applicant is granted the registration herein opposed, it would thereby obtain a
`
`prima facie exclusive right to use Applicant’s trademark as reflected in the ‘801 Application in
`
`connection with the covered goods. Such registration would damage and injure Opposer.
`
`
`
`13
`
`

`

`
`
`8. Accordingly, in light of Opposer’s prior rights in Opposer’s Trademarks, Applicant is
`
`not entitled to registration of the ‘801 Application, and Opposer will be damaged by the
`
`registration of the ‘801 Application and opposes same.
`
`Relief Requested
`
`Opposer respectfully requests this opposition be sustained and that:
`
`(i)
`
`(ii)
`
`U.S. Appl. Ser. No. 98/758,801 be refused registration; and
`
`the Trademark Trial and Appeal Board award Opposer such other and
`
`Date: May 21, 2025
`
`further relief as it deems just.
`
`Respectfully submitted by:
`
`/James F. Keenan, Jr./
`James F. Keenan, Jr.,
`Bernstein, Shur, Sawyer & Nelson
`100 Middle Street
`Portland, Maine 04104
`Telephone:
`(207) 774-1200
`Facsimile:
`(207) 774-1127
`Email:
` jkeenan@bernsteinshur.com
`Attorney for Opposer
`
`
`
`14
`
`

`

`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`vs.
`
`
`
`
`
`Pengcheng Wang,
`
`
`In the Matter of
`
`
`
`
`Mark:
`
`
`Appl. Ser. No.:
`
`Appl. Date:
`
`
`
`
`
`OUTDOPE
`
`98758801
`
`September 19, 2024
`
`
`
`------------------------------------------------------:
`
`
`
`
`
`
`:
`RDSTR IP 2 AB,
`
`
`
`:
`
`
`
`
`
`
`:
`Opposer,
`
`:
`:
`:
`
`
`
`:
`
`
`
`:
`
`
`
`:
`
`
`
`:
`
`Applicant.
`
`
`
`:
`
`
`
`
`
`
`------------------------------------------------------:
`
`
`
`CERTIFICATE OF TRANSMITTAL
`
` I
`
` hereby certify that a true copy of the foregoing NOTICE OF OPPOSITION is being filed
`electronically with the TTAB via ESTTA on this day, May 21, 2025.
`
`
`/James F. Keenan, Jr./
`James F. Keenan, Jr.
`
`
`
`
`15
`
`

`

`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`EXHIBIT A
`EXHIBIT A
`
`See Attached
`See Attached
`
`EXHIBIT B
`EXHIBIT B
`
`

`

`Generated on: This page was generated by TSDR on 2025-05-19 13:32:25 EDT
`
`Mark: OUTDOPE
`
`US Serial Number: 98758801
`
`Filed as TEAS
`Plus:
`
`Yes
`
`Register: Principal
`
`Mark Type: Trademark
`
`TM5 Common Status
`Descriptor:
`
`Application Filing
`Date:
`
`Sep. 19, 2024
`
`Currently TEAS
`Plus:
`
`Yes
`
`LIVE/APPLICATION/Published for Opposition
`
`A pending trademark application has been examined by the Office and has
`been published in a way that provides an opportunity for the public to oppose
`its registration.
`
`Status: Application has been published for opposition. The opposition period begins on the date of publication.
`
`Status Date: Apr. 29, 2025
`
`Publication Date:Apr. 29, 2025
` 
`
`Mark Literal
`Elements:
`
`OUTDOPE
`
`Mark Information
`
`Standard Character
`Claim:
`
`Mark Drawing
`Type:
`
`Yes. The mark consists of standard characters without claim to any particular font style, size, or color.
`
`4 - STANDARD CHARACTER MARK
`
`Goods and Services
`
`Note:
`The following symbols indicate that the registrant/owner has amended the goods/services:
`Brackets [..] indicate deleted goods/services;
`Double parenthesis ((..)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and
`Asterisks *..* identify additional (new) wording in the goods/services.
`
`For: Athletic jackets; Athletic pants; Athletic tops and bottoms for skiing; Athletic uniforms; Shirts and short-sleeved shirts; Short-sleeved or
`long-sleeved t-shirts; Ski and snowboard shoes and parts thereof; Ski bibs; Ski jackets; Ski pants; Ski suits; Ski wear; Snowboard
`jackets; Snowboard pants; Winter coats
`
`International
`Class(es):
`
`025 - Primary Class
`
`Class Status: ACTIVE
`
`First Use: Sep. 03, 2024
`
`U.S Class(es): 022, 039
`
`Use in Commerce: Sep. 03, 2024
`
`Basis Information (Case Level)
`
`Filed Use: Yes
`
`Filed ITU: No
`
`Filed 44D: No
`
`Filed 44E: No
`
`Filed 66A: No
`
`Currently Use: Yes
`
`Currently ITU: No
`
`Currently 44D: No
`
`Currently 44E: No
`
`Currently 66A: No
`
`Filed No Basis: No
`
`Currently No Basis: No
`
`Current Owner(s) Information
`
`Owner Name: Wang, Pengcheng
`
`

`

`Owner Address: Shanghai Mansion, Lingang District
`Weihai, Shandong CHINA 264200
`
`Legal Entity Type: INDIVIDUAL
`
`Citizenship: CHINA
`
`Attorney/Correspon