ESTTA Tracking number: ESTTA1447695
`Filing date: 07/08/2025
`
`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 Chapter 4 Corp.
`
`Granted to date 07/09/2025
`of previous ex-
`tension
`
`Address 62 KING STREET
`NEW YORK, NY 10014
`UNITED STATES
`
`Attorney informa- | LISA M. WILLIS
`
`tion CHAPTER 4 CORP.
`
`62 KING STREET
`
`NEW YORK, NY 10014
`
`UNITED STATES
`
`Primary email: ipdocket@supremenewyork.com
`Secondary email(s): lisa.willis@supremenewyork.com,
`samanta.bangaree@supremenewyork.com
`
`Docket no.
`
`Applicant information
`
`Application no. 97937110 Publication date 03/11/2025
`Opposition filing 07/08/2025 Opposition period | 07/09/2025
`date ends
`
`Applicant RYU, JAE RYONG
`
`14641 PERTHSHIRE RD
`HOUSTON, TX 77079
`UNITED STATES OF AMERICA
`
`Goods/services affected by opposition
`
`Class 0083. First Use: None First Use In Commerce: None
`
`All goods and services in the class are opposed, namely: Cosmetics; Cuticle removing preparations;
`Make-up; Shaving and after-shave preparations; Cosmetic preparations for body care; Cleansers for
`intimate personal hygiene purposes, non medicated; Non-medicated preparations for the care of skin,
`hair and scalp; Shampoos; Sunscreen preparations; Hand cleansers; Cosmetic preparations for skin
`care and skin treatment, namely, non-medicated scalp treatment cream; Non-medicated soaps for
`personal use; Perfumes and colognes; Hair masks; Hair wax; Hair conditioners; Beauty masks; Cot-
`ton wool for cosmetic purposes; Make-up removing milk, gels, lotions and creams; Tissues impreg-
`nated with make-up removing preparations
`
`Class 008. First Use: None First Use In Commerce: None
`
`All goods and services in the class are opposed, namely: Scissor blades; Foot files being pedicure
`implements; Razors; Razor blades; Hair-removing tweezers; Nonelectric eyebrow trimmers; Nail scis-
`sors; Nail clippers; Manual clippers; Hair cutting scissors; Electric razors; Electric curling irons; Elec-
`trically operated hair clippers; Electric epilators being depilatory appliances; Electric hair crimper; Hair
`
`
`
`
`
`
`
`
`
`straightening irons, electric; Electric hair curling irons; Knives being pocket knives, butter knives,
`razor knives; Hand implements for hair curling being electric hair curling irons
`
`Class 021. First Use: None First Use In Commerce: None
`
`All goods and services in the class are opposed, namely: Eye make-up applicators being applicator
`wands; Powder puffs; Cases for cosmetic face powder being powder compacts sold empty; Powder
`compacts, not of precious metal, sold empty; Powder compacts, empty; Combs; Brushes being ,
`namely, hair brushes, eyelash brushes, cosmetic brushes; Sponges being massage sponges, toiletry
`sponges, bath sponges, face sponges for applying makeup; Facial cleansing brushes; Facial cleans-
`ing sponges; Vaporizers for perfume sold empty; Brushes for applying make-up; Make-up brushes;
`Make-up sponges; Facial sponges for applying make-up; Cosmetic spatulas; Cosmetic palettes being
`makeup mixing palettes, sold empty; Fitted vanity cases; Cosmetic utensils in the nature of thread for
`eyebrow threading; Make-up removing appliances
`
`Class 025. First Use: None First Use In Commerce: None
`All goods and services in the class are opposed, namely: Working clothing, namely, barber cape, ap-
`rons, uniforms
`
`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 4504231 Application date 03/06/2013
`no.
`Register Principal
`Registration date | 04/01/2014 Foreign priority NONE
`date
`Word mark SUPREME
`Design mark
`Description of The mark consists of the word "Supreme" in white block letters against a red
`mark rectangular background.
`
`Goods/services Class 025. First use: First Use: Apr 1994 First Use In Commerce: Apr 1994
`
`Clothing, namely, shirts, t-shirts, long-sleeved shirts, under shirts, polo shirts,
`rugby shirts, jerseys, dress shirts, denim jeans, hooded sweat shirts, warm-up
`suits, [ snow suits, ] parkas, cardigans, pants, jean jackets, cargo pants, shorts,
`boxer shorts, tops, tank tops, sweat shirts, sweat jackets, sweat shorts, sweat
`pants, sweaters, vests, [ fleece vests, ] pullovers, jackets, coats, blazers, suits, [
`turtlenecks, reversible jackets, wind-resistant jackets, shell jackets, sports jack-
`ets, golf and ski jackets, heavy coats, over coats, top coats, ] swimwear, beach-
`wear, [ visors, ] headbands, [ ear muffs, ] thermal underwear, long underwear,
`underclothes, caps, hats, knit caps, headwear, scarves, bandanas, belts, [ neck-
`wear, ties, ] robes, gloves, boots, rainwear, footwear, shoes and sneakers
`
`U.S. registration 5763658 Application date 03/19/2014
`no.
`Register Principal
`Registration date | 05/28/2019 Foreign priority NONE
`date
`Word mark SUPREME
`Design mark
`Description of The mark consists of the word "Supreme" in white letters against a red rectangu-
`mark lar background.
`
`Goods/services Class 018. First use: First Use: Apr 1994 First Use In Commerce: Apr 1994
`
`
`
`
`
`
`
`
`
`Book, carry-on, gym, shoulder and tote bags; satchels; luggage; luggage tags;
`trunks; suitcases; bags sold empty; [ men's clutches; business card cases; call-
`ing and credit card cases; | key cases; leather key chains; billfolds; umbrellas
`
`U.S. registration 5066670 Application date 03/19/2014
`
`no.
`
`Register Principal
`
`Registration date | 10/25/2016 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`The mark consists of the word "Supreme" in white block letters against a red
`
`rectangular background.
`
`Goods/services
`
`Class 018. First use: First Use: Apr 1994 First Use In Commerce: Apr 1994
`
`All-purpose sports and athletic bags; duffel and travel bags; fanny packs and
`waist packs; backpacks; knapsacks; wallets
`
`U.S. registration 6048267 Application date 05/22/2018
`
`no.
`
`Register Principal
`
`Registration date | 05/05/2020 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`Class 009. First use: First Use: Apr 2007 First Use In Commerce: Apr 2007
`Eyewear; sunglasses; sports eyewear; cases for eyewear, sunglasses and
`sports eyewear; sports goggles; cases for mobile phones; cell phone back-
`plates; cell phone cases; cell phone covers; portable satellite radios
`
`U.S. registration 5775727 Application date 03/19/2014
`
`no.
`
`Register Principal
`
`Registration date | 06/11/2019 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`Class 018. First use: First Use: Apr 1994 First Use In Commerce: Apr 1994
`
`Book, carry-on, gym, shoulder and tote bags; satchels; luggage; luggage tags;
`trunks; suitcases; bags sold empty[ ; men's clutches; business card cases; call-
`ing and credit card cases; key cases; ] leather key chains; billfolds; umbrellas
`
`U.S. registration 6146273 Application date 01/29/2020
`no.
`
`Register Principal
`
`Registration date | 09/08/2020 Foreign priority NONE
`
`date
`
`
`
`
`
`
`
`
`
`Word mark
`
`SUPREME
`
`Design mark
`
`Description of
`mark
`
`The mark consists of the word "Supreme” in white letters against a red rectangu-
`
`lar background.
`
`Goods/services
`
`Class 016. First use: First Use: May 1994 First Use In Commerce: May 1994
`
`stickers
`U.S. registration 4240456 Application date 09/16/2011
`no.
`Register Principal
`Registration date | 11/13/2012 Foreign priority NONE
`date
`Word mark SUPREME
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`Class 028. First use: First Use: Mar 1996 First Use In Commerce: Mar 1996
`
`skateboard decks
`
`U.S. registration 5801848 Application date 05/22/2018
`
`no.
`
`Register Principal
`
`Registration date | 07/09/2019 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`The mark consists of the word "Supreme" in white block letters against a red
`
`rectangular background.
`
`Goods/services
`
`Class 009. First use: First Use: Apr 2007 First Use In Commerce: Apr 2007
`
`Eyewear; sunglasses; sports eyewear; cases for eyewear, sunglasses and
`sports eyewear; sports goggles; cases for mobile phones; cell phone back-
`plates; [ cell phone cases; cell phone covers; ] cell phone straps; portable satel-
`
`lite radios
`U.S. registration 7194248 Application date 09/09/2022
`no.
`Register Principal
`Registration date | 10/17/2023 Foreign priority NONE
`date
`Word mark SUPREME
`Design mark
`
`Description of
`mark
`
`The mark consists of the word "Supreme" in white letters against a red rectangu-
`
`lar background.
`
`Goods/services
`
`Class 034. First use: First Use: Dec 31, 2004 First Use In Commerce: Dec 31,
`
`2004
`
`Ashtrays; Lighters for smokers; Holders for cigarette lighters
`
`U.S. registration
`no.
`
`5135326
`
`Application date
`
`07/13/2015
`
`
`
`
`
`
`
`
`
`Register Principal
`
`Registration date | 02/07/2017 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`Class 035. First use: First Use: Apr 1994 First Use In Commerce: Apr 1994
`
`Retail stores, on-line ordering services and on-line retail store services, and re-
`tail store services available through computer communications, featuring cloth-
`ing, footwear, headwear, bags, wallets and skateboard decks
`
`U.S. registration 5592852 Application date 10/19/2016
`
`no.
`
`Register Principal
`
`Registration date | 10/30/2018 Foreign priority NONE
`date
`
`Word mark SUP
`
`Design mark
`
`Description of
`mark
`
`The mark consists of a red square containing the verbiage "SUP" in white let-
`ters.
`
`Goods/services
`
`Class 025. First use: First Use: Mar 1, 2006 First Use In Commerce: Mar 1,
`2006
`
`Clothing, namely, shirts, t-shirts, tank tops, sweat shirts, long-sleeved shirts, un-
`der shirts, denim jeans, hooded sweat shirts, boxer shorts, tops, sweat jackets,
`
`sweat shorts, sweat pants, sweaters, long underwear, underclothes, caps, hats,
`knit caps, headwear, footwear, shoes and sneakers
`
`U.S. registration 5135327 Application date 07/13/2015
`
`no.
`
`Register Principal
`
`Registration date | 02/07/2017 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`The mark consists of the word "Supreme” in white block letters against a red
`rectangular background.
`
`Goods/services
`
`Class 035. First use: First Use: Apr 1994 First Use In Commerce: Apr 1994
`
`Retail stores, on-line ordering services and on-line retail store services, and re-
`tail store services available through computer communications, featuring cloth-
`ing, footwear, headwear, bags, wallets and skateboard decks
`
`U.S. registration 6043450 Application date 11/19/2018
`
`no.
`
`Register Principal
`
`Registration date | 04/28/2020 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`
`The mark consists of the word "Supreme” in white block letters against a red
`
`
`
`
`
`
`
`
`
`mark
`
`rectangular background.
`
`Goods/services
`
`Class 018. First use: First Use: Apr 1994 First Use In Commerce: Apr 1994
`
`Book, carry-on, gym, shoulder and tote bags; luggage; luggage tags; trunks be-
`ing luggage and suitcases; suitcases; toiletry bags sold empty; toiletry and van-
`ity cases sold empty; tool bags sold empty; business card cases; calling and
`credit card cases; billfolds; umbrellas
`
`U.S. registration 6921701 Application date 09/24/2021
`
`no.
`
`Register Principal
`
`Registration date | 12/13/2022 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`The mark consists of the word "Supreme" in white letters against a red rectangu-
`lar background.
`
`Goods/services
`
`Class 021. First use: First Use: 2009 First Use In Commerce: 2009
`
`Valet trays for household purposes; thermal insulated containers for food
`orA beverages; flasks; dishes; bowls; incense burners; petA drinking bowls;
`mugs; drinking glasswareA , namely, drinking glasses and cups; water
`bottlesA sold empty; bottle openers
`
`U.S. registration 4157110 Application date 09/16/2011
`
`no.
`
`Register Principal
`
`Registration date | 06/12/2012 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`Class 025. First use: First Use: Apr 1994 First Use In Commerce: Apr 1994
`
`Clothing, namely, shirts, t-shirts, long-sleeved shirts, under shirts, polo shirts,
`rugby shirts, jerseys, dress shirts, denim jeans, hooded sweat shirts, warm-up
`suits, [ snow suits, ] parkas, cardigans, pants, jean jackets, cargo pants, shorts,
`boxer shorts, tops, tank tops, sweat shirts, sweat jackets, sweat shorts, sweat
`pants, sweaters, vests, [ fleece vests, | pullovers, jackets, coats, blazers, suits, |
`turtlenecks, reversible jackets, wind-resistant jackets, shell jackets, sports jack-
`ets, golf and ski jackets, heavy coats, over coats, top coats, | swimwear, beach-
`wear, [ visors, | headbands, [ ear muffs, ] thermal underwear, long underwear,
`underclothes, caps, hats, knit caps, headwear, scarves, bandanas, belts, [ neck-
`wear, ties, ] robes, gloves, boots, rainwear, footwear, shoes and sneakers
`
`U.S. registration 7196096 Application date 10/26/2022
`
`no.
`
`Register Principal
`
`Registration date | 10/17/2023 Foreign priority NONE
`date
`
`Word mark SUPR
`
`Design mark
`
`Description of
`
`The mark consists of the word "SUPR" in white letters against a red rectangular
`
`
`
`
`
`
`
`
`
`mark
`
`background.
`
`Goods/services
`
`Class 034. First use: First Use: Jun 7, 2018 First Use In Commerce: Jun 7, 2018
`Lighters for smokers
`
`U.S. registration 4554309 Application date 03/06/2013
`
`no.
`
`Register Principal
`
`Registration date | 06/24/2014 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`The mark consists of the word "Supreme" in white block letters against a red
`rectangular background.
`
`Goods/services
`
`Class 028. First use: First Use: Mar 1996 First Use In Commerce: Mar 1996
`skateboard decks
`
`U.S. registration 6621685 Application date 03/08/2021
`
`no.
`
`Register Principal
`
`Registration date | 01/18/2022 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`The mark consists of the word "Supreme” in white letters against a red rectangu-
`lar background.
`
`Goods/services
`
`Class 014. First use: First Use: 1998 First Use In Commerce: 1998
`
`Jewelry, namely, necklaces, rings, earrings and watches; Key chains; Stop-
`watches; Pins being jewelry; Ornamental lapel pins
`
`U.S. registration 5066669 Application date 03/19/2014
`
`no.
`
`Register Principal
`
`Registration date | 10/25/2016 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Description of
`mark
`
`Goods/services
`
`Class 018. First use: First Use: Apr 1994 First Use In Commerce: Apr 1994
`
`All-purpose sports and athletic bags; duffel and travel bags; fanny packs and
`waist packs; backpacks; knapsacks; wallets
`
`Attachments
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`2025.7.8 Notice of Opposition against SUPERME in classes 3 8 21 and 2
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`5.pdf(520456 bytes )
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`Exhibits for U.S. Opposition against SUPERME in class 3, 8, 21, 25.pd
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`(2679531 bytes )
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`Signature /Lisa M. Willis/
`Name Lisa M. Willis
`Date 07/08/2025
`
`
`
`
`
`
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`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`CHAPTER 4 CORP. d/b/a SUPREME,
`
`Opposer,
`Opposition No.
`
`V.
`
`JAE RYONG RYU,
`Applicant.
`
`Mark:
`Serial No.: 97/937,110
`Filing Date: May 15, 2023
`
`NOTICE OF OPPOSITION
`
`Chapter 4 Corp. d/b/a Supreme, a New York corporation with an address of 62 King
`
`Street, New York, New York 10014 (the “Opposer” and/or “Supreme”), believes that it would be
`
`damaged by the registration of the mark (“Applicant’s Mark™) filed with the
`United States Patent and Trademark Office (the “USPTO”) under Serial No. 97/937,110 in the
`name of Jae Ryong Ryu, an individual with United States citizenship, and an address of 14641
`Perthshire Road, Houston, Texas 77079 (“Applicant”), and hereby seeks to oppose said
`
`application. As grounds for the opposition, Opposer hereby alleges:
`
`OPPOSER’S MARKS
`
`1. Opposer owns the famous SUPREME word mark, the SUPREME Box Logo
`
`mark (), the SUP word mark, SUP Box Logo mark (m ) and the SUPR Box Logo
`
`
`
`
`
`
`
`
`(M) (collectively, the “SUPREME Marks”) for use in connection with various goods and
`services, including bags, apparel and a wide variety of accessories.
`
`2. Opposer owns exclusive federal and common law rights for the SUPREME
`Marks, including various registrations and applications for the SUPREME Marks with the
`USPTO. See Exhibit A. Opposer also owns hundreds of trademark registrations worldwide for
`the SUPREME Marks.
`
`3. Opposer has use in commerce of its SUPREME Marks beginning at least as early
`as April 1994. The first Supreme retail store opened in April 1994 in New York, which offered a
`host of clothing, bags, skateboards and related products and accessories. Also, many of
`Opposer’s U.S. trademark registrations include the date of first use in commerce as of April
`1994.
`
`OPPOSER’S PRIOR USE
`
`4. Long prior to Applicant’s filing date or any first use date Applicant may claim,
`Opposer has used its famous SUPREME Marks in connection with a variety of accessories,
`
`including makeup, combs, knives, electric razors and work wear. See Figure 1.
`
`Figure 1. Examples of Opposer’s accessories.
`
`
`
`
`
`
`
`
`5. Opposer also has collaborated with third parties to create and sell clothing bearing
`the SUPREME Marks. For example, SUPREME x Louis Vuitton (2017); SUPREME x Bruce
`Lee (2013); SUPREME x Budweiser (2009); SUPREME x The North Face (2008 - ongoing).
`
`See also Figure 2.
`
`SUPREME
`
`Figure 2. SUPREME x Louis Vuitton; and SUPREME x Bruce Lee.
`6. By reason of Opposer’s extensive use of the SUPREME Marks, the public closely
`associates the famous marks with Opposer and its high-quality SUPREME branded products,
`
`which include boundless categories of items.
`
`OPPOSER’S FAMOUS SUPREME BRAND
`
`7. Founded in New York in April 1994 as a “downtown” clothing and skateboard
`store, Opposer immediately established itself as a brand known for its quality, style and
`authenticity; and as a style guide for youth customers all over the world under the acclaimed
`streetwear brand “SUPREME”.
`
`8. Over 31 years, Opposer has expanded from its New York City origins into a
`global brand, working with generations of prominent artists, photographers, designers, and
`
`characters, all of whom have helped perpetuate the brand's unique identity. See Exhibit B.
`
`
`
`
`
`
`
`
`0. Vogue.com has referred to Supreme as a “Fashion Superpower” and GQ
`Magazine UK discussed the “brand’s world domination.” The following are some quotes about
`the Opposer’s fame:
`
`o Supreme, an underground streetwear brand with 11 stores and a cult following, is now
`worth more than teen retailer Abercrombie & Fitch Co. ANF -4.42%, which has about
`
`900 stores around the globe. - The Wall Street Journal, 2017
`
`o [Retail] [p]rices are hardly astronomical (jeans are about $130; hoodies, $170), but
`
`Supreme cultivates the same covetous frenzy that might greet a new $9,000 Hermes
`
`Birkin bag. - The New York Times, 2012
`
`10. The Council of Fashion Designers of America, Inc., the preeminent fashion and
`accessory designer trade association, awarded Supreme the 2018 Menswear Designer of the Year
`award. See Exhibit C.
`
`11. To commemorate the 20" anniversary of the SUPREME brand in April 2014,
`Supreme released the SUPREME Box Logo t-shirt which was first offered for sale and sold
`
`when Supreme opened its doors. See Figure 3.
`
`Figure 3. Supreme 20" Anniversary t-shirt
`
`
`
`
`
`
`
`
`12. SUPREME was recognized as “The Most Popular Brand on Grailed”.
`Complex.com reported on the ranking and stated that “Supreme is number 1 (again). No
`surprises at the top of the list.” See Exhibit D.
`
`13. The Museum of Modern Art in New York City entered the original t-shirt design
`bearing the SUPREME Box Logo as depicted in Figure 3 into its 2017 “Items: Is Fashion
`Modern?” exhibition which “explores the present, past—and sometimes the future—of 111
`items of clothing and accessories that have had a strong impact on the world in the 20th and 21st
`centuries—and continue to hold currency today.” See Exhibit E.
`
`14. In Spring 2018, the Thyssen-Bornemisza Museum in Spain displayed a co-
`branded SUPREME and Louis Vuitton skateboard case in a Louis Vuitton "7Time Capsule"
`exhibition. See Exhibit F.
`
`15. Opposer is known for its “seemingly infinite collaborations” (according to
`Vogue.com) that expand far beyond traditional categories. According to Sotheby’s, “Artists such
`as Rammellzee, Mark Gonzales and Dash Snow would quickly become both friends and
`collaborators with Supreme, providing both inspiration and artwork for the store and products.”
`These collaborations have resulted in skate decks that are “highly coveted and collectible” and
`each “represents a moment in the brand’s quarter-century timeline.” See Exhibits B and G.
`
`16. Opposer collaborated with The New York Post for a wraparound cover page,
`which sold out in record timing. See Figure 4. Jesse Angelo, the New York Post’s publisher told
`the New York Times, “We knew that this would be a collector’s item....Supreme is such a cool
`brand and we have so much affinity, to the design kinship of the logos, to being bold, and never
`shy, and New York-based.” The New York Times released its article stating that “A dramatic
`cover ad on the New York Post for the street wear company Supreme turned today’s tabloid into
`
`an impossible to find commodity.” See Exhibit H.
`
`
`
`
`
`
`
`
`Figure 4. New York Post and Opposer’s collaboration
`
`17. Opposer exclusively sells its goods and accessories under the SUPREME Marks
`directly to consumers in numerous countries worldwide through its retail website at
`<www.supreme.com>, as well as Opposer’s retail stores in the U.S., France, Japan, UK, Italy,
`Germany, South Korea and China.
`
`18. A number of factors contribute to the fame of the SUPREME Marks, including,
`among others: (1) the consistent and exclusive of use of the SUPREME Marks over nearly the
`past 31 years in the United States and throughout the world, including in connection with
`apparel, bags, accessories, skateboard decks, streetwear-related products and other merchandise;
`(2) unsolicited media attention about the SUPREME brand; and (3) the worldwide sales of
`SUPREME branded goods in the hundreds of millions of U.S. dollars.
`
`19. By reason of Opposer’s extensive use of the SUPREME Marks, these marks have
`become famous and are an asset of substantial value to Opposer as a symbol of Opposer, its
`
`quality goods and services, and goodwill.
`
`APPLICANT’S MARK
`
`20. Upon information and belief, on May 15, 2023, Applicant filed with the USPTO
`
`Application Serial No. 97/937,110 for Applicant’s Mark, which covers “Cosmetics; Cuticle
`
`
`
`
`
`
`
`
`removing preparations; Make-up; Shaving and after-shave preparations; Cosmetic preparations
`for body care; Cleansers for intimate personal hygiene purposes, non medicated; Non-medicated
`preparations for the care of skin, hair and scalp; Shampoos; Sunscreen preparations; Hand
`cleansers; Cosmetic preparations for skin care and skin treatment, namely, non-medicated scalp
`treatment cream; Non-medicated soaps for personal use; Perfumes and colognes; Hair masks;
`Hair wax; Hair conditioners; Beauty masks; Cotton wool for cosmetic purposes; Make-up
`removing milk, gels, lotions and creams; Tissues impregnated with make-up removing
`preparations” in International Class 3, “Scissor blades; Foot files being pedicure implements;
`Razors; Razor blades; Hair-removing tweezers; Nonelectric eyebrow trimmers; Nail scissors;
`Nail clippers; Manual clippers; Hair cutting scissors; Electric razors; Electric curling irons;
`Electrically operated hair clippers; Electric epilators being depilatory appliances; Electric hair
`crimper; Hair straightening irons, electric; Electric hair curling irons; Knives being pocket
`knives, butter knives, razor knives; Hand implements for hair curling being electric hair curling
`irons” in International Class 8, “Eye make-up applicators being applicator wands; Powder puffs;
`Cases for cosmetic face powder being powder compacts sold empty; Powder compacts, not of
`precious metal, sold empty; Powder compacts, empty; Combs; Brushes being , namely, hair
`brushes, eyelash brushes, cosmetic brushes; Sponges being massage sponges, toiletry sponges,
`bath sponges, face sponges for applying makeup; Facial cleansing brushes; Facial cleansing
`sponges; Vaporizers for perfume sold empty; Brushes for applying make-up; Make-up brushes;
`Make-up sponges; Facial sponges for applying make-up; Cosmetic spatulas; Cosmetic palettes
`being makeup mixing palettes, sold empty; Fitted vanity cases; Cosmetic utensils in the nature of
`thread for eyebrow threading; Make-up removing appliances” in International Class 21 and
`“Working clothing, namely, barber cape, aprons, uniforms” in International Class 25, based on
`
`intent to use in commerce (the “Application”). See Exhibit 1.
`
`
`
`
`
`
`
`
`21. Upon information and belief, Applicant’s Mark, is highly similar to Opposer’s
`word mark SUPREME.
`22. The only difference between the spelling of the parties’ marks is that Applicant’s
`
`Mark reverses the letters “er” in Opposer’s SUPREME mark. See comparison below:
`Supreme
`
`Superme
`23. Upon information and belief, Applicant’s Mark is a deliberate effort to associate
`Applicant’s goods with Opposer’s well-known SUPREME brand.
`24, The goods covered by the Application are identical and/or closely related to the
`
`goods offered under Opposer’s SUPREME Marks.
`
`DAMAGE TO OPPOSER
`
`25. If Applicant were permitted to obtain a registration for Applicant’s Mark, it would
`cause damage and injury to Opposer’s business reputation and goodwill and would injure and
`impair Opposer’s senior rights in its SUPREME Marks.
`
`26. Applicant’s Mark so resembles Opposer’s SUPREME Marks, as to be likely,
`when applied to Applicant’s goods, to cause confusion, or to cause mistake, or deception with
`the SUPREME Marks.
`
`217. The aforesaid confusion, mistake and deception will generate the erroneous
`impression that Applicant’s goods originate with Opposer or that Applicant’s goods are
`authorized, licensed or endorsed by, or are connected or associated in some way with Opposer or
`the SUPREME Marks. Thus, any fault found with Applicant or Applicant’s goods would
`adversely reflect upon and damage the SUPREME Marks and the valuable goodwill associated
`
`therewith.
`
`
`
`
`
`
`
`
`28. Applicant’s Mark, when applied to Applicant’s goods, will dilute the distinctive
`quality of the SUPREME Marks, which have been famous since prior to the filing date of the
`Application or any alleged date of use in commerce of the Applicant’s Mark.
`
`29. For the above reasons, Opposer will be damaged by the registration of
`Applicant’s Mark.
`
`30. Opposer reserves all rights to amend this Notice of Opposition.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Opposer prays that this opposition be sustained, and that registration of
`Application Serial No. 97/937,110 be denied; and for such other and further relief as the Board
`
`deems just and proper.
`
`Respectfully submitted,
`
`Dated: July 8, 2025 Lisa M. Willis
`Head of Legal for
`Chapter 4 Corp. d/b/a Supreme
`
`
`
`
`
`
`
`
`EXHIBIT A
`
`
`
`
`
`
`
`
`Enited States of Ameyy,
`
`CUnited States Patent and Trademark Office Q
`
`Supreme
`
`Reg. No. 4,554,309 CHAPTER 4 CORP. (NEW YORK CORPORATION), DBA SUPREME
`; 121 WOOSTER STREET, 2F
`Registered June 24, 2014 NEw YORK. NY 10012
`
`Int. Cl.: 28 FOR: SKATEBOARD DECKS, IN CLASS 28 (U.S. CLS. 22, 23, 38 AND 50).
`FIRST USE 3-0-1996; IN COMMERCE 3-0-1996.
`
`TRADEMARK
`OWNER OF US. REG. NOS. 4,157,110 AND 4,240.456.
`
`PRINCIPAL REGISTER
`
`THE COLOR(S) RED AND WHITE IS/ARE CLAIMED AS A FEATURE OF THE MARK.
`
`THE MARK CONSISTS OF THE WORD "SUPREME" IN WHITE BLOCK LETTERS AGAINST
`A RED RECTANGULAR BACKGROUND.
`
`SEC. 2(F).
`SER. NO. 85-868.116, FILED 3-6-2013.
`
`SHAILA LEWIS, EXAMINING ATTORNEY
`
`Deputy Director of the United States
`Patent and Trademark Office
`
`
`
`
`
`
`
`
`Enited States of Ay,
`
`Enited States Patent and Trabemark Office ‘?
`
`Supreme
`
`Reg. No. 5 ,066,670 Chapter 4 Corp. (NEW YORK CORPORATION), DBA Supreme,
`121 Wooster Street, 2F
`
`Registered Oct. 25, 2016 New York, NY 10012
`
`Int. CL: 18 CLASS 18: All-purpose sports and athletic bags; duffel and travel bags; fanny packs and
`b waist packs; backpacks; knapsacks; wallets
`
`Trademark FIRST USE 4-00-1994; IN COMMERCE 4-00-1994
`Pl'il‘lcipal Registel‘ The color(s) red and white is/are claimed as a feature of the mark.
`
`The mark consists of the word "Supreme" in white letters against a red rectangular
`background.
`
`OWNER OF U.S. REG. NO. 4157110, 4240456
`
`SER. NO. 86-225,910, FILED 03-19-2014
`LINDA B ORNDORFF, EXAMINING ATTORNEY
`
`sty % Ze
`
`Director of the United States
`Patent and Trademark Office
`
`
`
`
`
`
`
`
`@fi'\tfll
`
`States of gme“,
`
`Cnited States Patent and Trademark Office [a
`
`Supreme
`
`Reg. No. 4,504,231
`Registered Apr. 1, 2014
`
`Int. CL.: 25
`
`TRADEMARK
`PRINCIPAL REGISTER
`
`Rotregiite. B Bl
`
`Deputy Director of the United States
`Patent and Trademark Office
`
`CHAPTER 4 CORP. (NEW YORK CORPORATION), DBA SUPREME
`121 WOOSTER STREET, 2F
`NEW YORK. NY 10012
`
`FOR: CLOTHING, NAMELY, SHIRTS, T-SHIRTS, LONG-SLEEVED SHIRTS, UNDER SHIRTS,
`POLO SHIRTS, RUGBY SHIRTS, JERSEYS, DRESS SHIRTS, DENIM JTEANS, HOODED
`SWEAT SHIRTS. WARM-UP SUITS, SNOW SUITS, PARKAS. CARDIGANS. PANTS. JEAN
`JACKETS, CARGO PANTS, SHORTS, BOXER SHORTS, TOPS, TANK TOPS, SWEAT SHIRTS,
`SWEAT JACKETS, SWEAT SHORTS, SWEAT PANTS. SWEATERS, VESTS, FLEECE VESTS,
`PULLOVERS, JACKETS, COATS, BLAZERS, SUITS, TURTLENECKS, REVERSIBLE
`JACKETS, WIND-RESISTANT JACKETS, SHELL JACKETS, SPORTS JACKETS, GOLF AND
`SKI JACKETS, HEAVY COATS, OVER COATS, TOP COATS, SWIMWEAR, BEACHWEAR,
`VISORS, HEADBANDS, EAR MUFFS, THERMAL UNDERWEAR, LONG UNDERWEAR,
`UNDERCLOTHES, CAPS, HATS, KNIT CAPS, HEADWEAR, SCARVES, BANDANAS, BELTS,
`NECKWEAR, TIES, ROBES, GLOVES, BOOTS. RAINWEAR, FOOTWEAR, SHOES AND
`SNEAKERS, IN CLASS 25 (U.S. CLS. 22 AND 39).
`
`FIRST USE 4-0-1994; IN COMMERCE 4-0-1994.
`OWNER OF U.S. REG. NOS. 4,157,110 AND 4,240.456.
`THE COLOR(S) RED AND WHITE IS/ARE CLAIMED AS A FEATURE OF THE MARK.
`
`THE MARK CONSISTS OF THE WORD "SUPREME" IN WHITE BLOCK LETTERS AGAINST
`A RED RECTANGULAR BACKGROUND.
`
`SER. NO. 85-868.093, FILED 3-6-2013.
`
`SHAILA LEWIS. EXAMINING ATTORNEY
`
`
`
`
`
`
`
`
`nited States of Apypy
`
`Enited States Patent and Trabemark Office (?
`
`Supreme
`
`Reg. No. 5,135,327
`Registered Feb. 07, 2017
`Int. Cl.: 35
`
`Service Mark
`
`Principal Register
`
`Director of the United States
`Patent and Trademark Office
`
`Chapter 4 Corp. (NEW YORK CORPORATION), DBA Supreme ,
`121 Wooster Street, 2F
`New York, NY 10012
`
`CLASS 35: Retail stores, on-line ordering services and on-line retail store services, and retail
`store services available through computer communications, featuring clothing, footwear,
`headwear, bags, wallets and skateboard decks
`
`FIRST USE 4-00-1994; IN COMMERCE 4-00-1994
`The color(s) red and white is/are claimed as a feature of the mark.
`
`The mark consists of the word "Supreme" in white block letters against a red rectangular
`background.
`
`OWNER OF U.S. REG. NO. 4157110, 4504231, 4240456
`
`SER. NO. 86-691,492, FILED 07-13-2015
`KAREN DINDAYAL, EXAMINING ATTORNEY
`
`
`
`
`
`
`
`
`Enited States of Jp,.
`
`Tnited States Patent and Trademark Office Ic‘?
`
`SUPREME
`
`Reg_ No. S ,066’669 Chapter 4 Corp. NEW YORK CORPORATION), DBA Supreme ,
`121 Wooster Street, 2F
`
`Registered Oct. 25,2016 New York, NY 10012
`
`I . CLASS 18: All-purpose sports and athletic bags; duffel and travel bags; fanny packs and
`nt. ClL.: 18 . , \ )
`waist packs; backpacks; knapsacks; wallets
`
`Trademark FIRST USE 4-00-1994; IN COMMERCE 4-00-1994
`
`Principal Register THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY
`PARTICULAR FONT STYLE, SIZE OR COLOR
`
`OWNER OF U.S. REG. NO. 4157110, 4240456
`
`SER. NO. 86-225,879, FILED 03-19-2014
`LINDA B ORNDORFF, EXAMINING ATTORNEY
`
`Director of the United States
`Patent and Trademark Office
`
`
`
`
`
`
`
`
`pited States of gmer
`
`WUnited States Patent and Trademark Office ‘?
`Reg. No. 5 ,135,326 Chapter 4 Corp. (NEW YORK CORPORATION), DBA Supreme ,
`
`121 Wooster Street, 2F
`
`Registered Feb. 07, 2017 New York, NY 10012
`
`. CLASS 35: Retail stores, on-line ordering services and on-line retail store services, and retail
`Int. Cl.: 35 . . co . !
`
`store services available through computer communications, featuring clothing, footwear,
`headwear, bags, wallets and skateboard decks
`
`Service Mark
`FIRST USE 4-00-1994; IN COMMERCE 4-00-1994
`
`Principal Register
`THE MARK CONSISTS OF STANDARD CHARACTE