ESTTA Tracking number:
`Filing date:
`
`ESTTA1469893
`10/15/2025
`
`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
`of previous ex-
`
`10/15/2025
`
`tion
`
`tension
`
`Address 62 KING STREET
`NEW YORK, NY 10014
`UNITED STATES
`
`Attorney informa- | JEFFREY CHERY
`
`COWAN, LIEBOWITZ & LATMAN, P.C.
`
`114 W 47TH STREET
`
`NEW YORK, NY 10036
`
`UNITED STATES
`
`Primary email: trademark@cll.com
`
`Secondary email(s): Irm@cll.com, jyc@cll.com, dxc@cll.com
`(212) 790-9200
`
`Docket no.
`
`Applicant information
`
`Application no.
`
`97447045 Publication date 06/17/2025
`
`Opposition filing
`date
`
`10/15/2025 Opposition period | 10/15/2025
`
`ends
`
`Applicant
`
`Crocs Lighter, Inc.
`
`350 RANGER AVE STE C
`BREA, CA 92821
`
`UNITED STATES OF AMERICA
`
`Goods/services affected by opposition
`
`and candles
`
`Class 011. First Use: None First Use In Commerce: None
`All goods and services in the class are opposed, namely: Utility lighters for lighting grills, fireplaces
`
`Grounds for opposition
`
`Priority and likelihood of confusion
`
`Trademark Act Section 2(d)
`
`Dilution by blurring
`
`Trademark Act Sections 2 and 43(c)
`
`Other
`
`priority and likelihood of confusion based on
`common law; see attached pleading
`
`Marks cited by opposer as basis for opposition
`
`| 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
`
`upreme
`
`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 6043450 Application date 11/19/2018
`
`no.
`
`Register Principal
`
`Registration date | 04/28/2020 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Supreme
`
`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
`
`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 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
`mark
`
`! it
`
`The mark consists of the word "SUPR" in white letters against a red rectangular
`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 5775727 Application date 03/19/2014
`
`no.
`
`Register Principal
`
`Registration date | 06/11/2019 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`SUPREME
`
`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 5066669 Application date 03/19/2014
`
`no.
`
`Register Principal
`
`Registration date | 10/25/2016 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`
`
`
`
`
`
`
`
`Design mark
`
`SUPREME
`
`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
`
`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 4554309 Application date 03/06/2013
`
`no.
`
`Register Principal
`
`Registration date | 06/24/2014 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`
`
`
`
`
`
`
`
`Design mark
`
`Supreme
`
`Description of
`mark
`
`The mark consists of the word "Supreme" in white block letters against a red
`rectangular background.
`
`Goods/services
`
`skateboard decks
`
`Class 028. First use: First Use: Mar 1996 First Use In Commerce: Mar 1996
`
`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
`
`Supreme
`
`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 7194248 Application date 09/09/2022
`no.
`Register Principal
`Registration date | 10/17/2023 Foreign priority NONE
`date
`Word mark SUPREME
`Design mark
`
`Supreme
`
`Description of
`mark
`
`lar background.
`
`The mark consists of the word "Supreme" in white letters against a red rectangu-
`
`Goods/services
`
`2004
`
`Class 034. First use: First Use: Dec 31, 2004 First Use In Commerce: Dec 31,
`
`Ashtrays; Lighters for smokers; Holders for cigarette lighters
`
`U.S. registration
`no.
`
`4504231
`
`Application date
`
`03/06/2013
`
`Register
`
`Principal
`
`
`
`
`
`
`
`
`
`Registration date | 04/01/2014 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Supreme
`
`Description of
`mark
`
`The mark consists of the word "Supreme" in white block letters against a red
`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 4157110 Application date 09/16/2011
`
`no.
`
`Register Principal
`
`Registration date | 06/12/2012 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`SUPREME
`
`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, [ heck-
`wear, ties, ] robes, gloves, boots, rainwear, footwear, shoes and sneakers
`
`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
`
`SUPREME
`
`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 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
`
`Supreme
`
`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 5763658 Application date 03/19/2014
`no.
`Register Principal
`Registration date | 05/28/2019 Foreign priority NONE
`date
`Word mark SUPREME
`
`
`
`
`
`
`
`
`
`Design mark
`
`upreme
`
`Description of
`mark
`
`The mark consists of the word "Supreme" in white letters against a red rectangu-
`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 6921701 Application date 09/24/2021
`
`no.
`
`Register Principal
`
`Registration date | 12/13/2022 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Supreme
`
`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 5135326 Application date 07/13/2015
`
`no.
`
`Register Principal
`
`Registration date | 02/07/2017 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`SUPREME
`
`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 6621685 Application date 03/08/2021
`
`no.
`
`Register Principal
`
`Registration date | 01/18/2022 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Supreme
`
`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 5135327 Application date 07/13/2015
`
`no.
`
`Register Principal
`
`Registration date | 02/07/2017 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`Design mark
`
`Supreme
`
`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 4240456 Application date 09/16/2011
`
`no.
`
`Register Principal
`
`Registration date | 11/13/2012 Foreign priority NONE
`date
`
`Word mark SUPREME
`
`
`
`
`
`
`
`
`
`Design mark
`
`SUPREME
`
`Description of
`mark
`
`Goods/services Class 028. First use: First Use: Mar 1996 First Use In Commerce: Mar 1996
`skateboard decks
`
`U.S. application/ registration | NONE Application date NONE
`
`no.
`
`Register NONE
`
`Registration date NONE
`
`Mark marks comprising the word SUPREME, including, without limitation, in
`distinctive stylizations, alone and with other design elements
`
`Goods/services apparel, bags, lighters for smokers, torch lighters, charcoal grills, and
`portable stoves, and a wide variety of accessories
`
`Attachments 86225910#TMSN.jpg
`88199285#TMSN.jpg
`97648909#TMSN.jpg
`86225786#TMSN.jpg
`86225879#TMSN.jpg
`87208480#TMSN.jpg
`85868116#TMSN.jpg
`88777646#TMSN.jpg
`9758564 7#TMSN.jpg
`85868093#TMSN.jpg
`85424627#TMSN.jpg
`87932224#TMSN.jpg
`87932218#TMSN.jpg
`86225846#TMSN.jpg
`97043300#TMSN.jpg
`86691471#TMSN.jpg
`90565348#TMSN.jpg( bytes
`
`86691492#TMSN.jpg( bytes
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`85424722#TMSN.jpg( bytes
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`Notice of Opposition against SUPREME in class 11.pdf(2162898 bytes )
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`)
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`)
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`)
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`P D e o e e L
`
`Signature /Jeffrey Chery/
`
`Name Jeffrey Chery
`
`Date 10/15/2025
`
`
`
`
`
`
`
`
`
`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.
`
`CROCS LIGHTER, INC.,
`Applicant.
`
`Mark: SUPREME
`Serial No.: 97/447,045
`Filing Date: ~ June 7, 2022
`
`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 standard character mark SUPREME (“Applicant’s Mark™)
`filed with the United States Patent and Trademark Office (the “USPTO”) under Serial No.
`97/447,045 in the name of Crocs Lighter, Inc., a corporation organized under the laws of
`California, with an address of 350 Ranger Avenue, Ste C, Brea, California 92821 (“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 and SUPREME Box Logo
`
`mark () (collectively, the “SUPREME Marks”) for use in connection with various
`goods and services, including apparel, bags, and a wide variety of accessories.
`
`33477/100/7026395.2
`
`
`
`
`
`
`
`
`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. Notably Opposer owns Registration No. 7194248 covering “Ashtrays; Lighters for
`smokers; Holders for cigarette lighters” in International Class 34. See Exhibit A. Opposer also
`owns hundreds of trademark registrations worldwide for the SUPREME Marks.
`
`3. Opposer has used 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. Prior to Applicant’s filing date, or any first use date Applicant may later claim,
`Opposer has used its famous SUPREME marks in connection with a wide variety of accessories,
`
`including lighters for smokers, torch lighters, charcoal grills, and portable stoves. 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
`
`33477/100/7026395.2
`
`
`
`
`
`
`
`
`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:
`
`33477/100/7026395.2
`
`
`
`
`
`
`
`
`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.
`
`home shop mnews fall/winter 2018 preview lcokbook random about stores
`
`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.
`
`33477/100/7026395.2
`
`
`
`
`
`
`
`
`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.
`
`33477/100/7026395.2
`
`
`
`
`
`
`
`
`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.
`
`33477/100/7026395.2
`
`
`
`
`
`
`
`
`APPLICANT’S MARK
`
`20. Upon information and belief, on June 7, 2022, Applicant filed with the USPTO
`Application Serial No. 97/447,045 for Applicant’s Mark, which covers “Utility lighters for
`lighting grills, fireplaces and candles” in International Class 11, based on intent to use in
`commerce (the “Application”). See Exhibit I.
`
`21. Applicant’s Mark is identical to Opposer’s SUPREME word mark and
`incorporates the textual element of Opposer’s SUPREME Box Logo mark in its entirety.
`
`22. The goods covered by the Application are identical and/or closely related to the
`goods offered under Opposer’s SUPREME Marks.
`
`DAMAGE TO OPPOSER
`
`23. 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.
`
`24, 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.
`
`25. 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.
`
`33477/100/7026395.2
`
`
`
`
`
`
`
`
`26. Applicant’s Mark is likely to be confused with Opposer’s SUPREME Marks
`based on both Opposer’s prior registered and common law rights in Opposer’s SURPEME
`Marks.
`
`27. 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.
`
`28. For the above reasons, Opposer will be damaged by the registration of
`Applicant’s Mark.
`
`29. 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. 97/447,045 be denied; and for such other and further relief as the Board
`
`deems just and proper.
`Dated: October 15, 2025
`
`Respectfully submitted,
`COWAN, LIEBOWITZ & LATMAN, P.C.
`Attorneys for Opposer
`
`/Jeffrey Chery/
`
`Jeffrey Chery
`
`Dasha Chestukhin
`
`114 West 47th Street
`
`New York, NY 10036-1525
`
`33477/100/7026395.2
`
`
`
`
`
`
`
`
`EXHIBIT A
`
`
`
`
`
`
`
`
`r@“fifil
`
`Ginited Siates Patent and Trabemark Office IC&
`
`Supreme
`
`Reg. No. 4,554,309
`Registered June 24, 2014
`Int. CL: 28
`
`TRADEMARK
`PRINCIPAL REGISTER
`
`Titlcpunte & oo
`
`Tiepiilh Blhawtis o the 1 Alisl Riidse
`Pairn sl Drosdase® § Wl
`
`CHAFIRE CURE (NEW YURK COBPUHES T TR THEA 510 PRERI:
`
`LD WS TR R TREERT. 25
`
`MEW SUIRE WY 3
`
`FURL SEAT EARD DECKS, IS CLASS ZHI % CE8 33 30, 36 AN Mg
`PIRST LESE Aanb TR, 10 DN HA S Sani AT
`
`TIWRER CIF LUS, BGa O 4 AT 0 AN 4 240 4506
`
`S CuE) R DA WY ARl CT AT A & DA Rl o T A RE
`
`TNE MERE CERES SIS0 THEWREL“SUPRESI B WIRTE RO K LR TERS ATaATN |
`& REL BECTANHULAR BACKUROLNTY
`
`|
`RLE NEE MEBEET 16 PTG 20l
`
`AHALLA LEWIS EXAMINIRG AT TORNEY
`
`
`
`
`
`
`
`
`(@“fig‘g States of gnwr
`
`Wnited States Patent and Trabemark Office f?
`
`Supreme
`
`Reg. No. 5,066,670
`Registered Oct. 25, 2016
`Int. Cl.: 18
`
`Trademark
`
`Principal Register
`
`T'csutty K Zow
`
`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 18: All-purpose sports and athletic bags; duffel and travel bags; fanny packs and
`waist packs; backpacks; knapsacks; wallets
`
`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 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
`
`
`
`
`
`
`
`
`wnited States of Jm,
`
`Tnited States Patent and Trademark Office rtf&
`
`Supreme
`
`Reg, No. 4,504,231
`Registered Apr. 1, 2004
`Int. CL: 15
`
`TRADEMARK
`PRINCIFAL REGISTER
`
`Tigpiils Eliiiatis o Al 1 uiterl Bldke
`Paiuni smel Tralemisek 4 i
`
`EIIAIFTRE S OB ENEW VU CYRR M TR THEA %10 PN
`P20 W RIS TR S TREITT. &1
`SEW YORE NV L2
`
`PO CLOTTT NG, NAMLLY, SHIRTS, TS0 s LOSGAL Y E R SIS, LS nlblETY
`FHD SITIMES, WECHY STIRTS, TERALYS [SHESS NIRRT, THMIM JEARS, JEairspn)
`SWEA] SHIRES, WARMAP S8 TS, SNOW SULTS, POREAS, CARINCANS, PANTS. J5AN
`IACKE T, Tt BasTS, SIS BUSTRSUORE TS, TS, LARE O SWIEAT SIRETS,
`EWENT AUKETS SWEATSHOR TS SWEAT NS SWEATERS VESTS, FLEFCE VESES
`FlLLOVERS MAUETTS Cunls BASERS. BUITS TURTLEMIURS, KEVERSIENE
`TACKETS, WINILRESETAN T JAUKETS, MLl IO IS, SroRES WWCRETS, (ei.E ARD
`SR1JAUKLTS, IHEAVY CEMATS, DVTH COES, T COATS, SWIMWEAH: HEATTIWLAT
`VIsOES, HEADRAMNIS. FAR MUTES THERMAL LNTERWEAR. LU THDEEW AR
`UINIHERCLOTIE S, CAPS, TATS, KNETCATS, TIEATRY CAR, SCARVES, HAMDANAS, OELTS, .
`SUCKWAR, TIES, ROEES, GLIVES. BOCTS, RAINWEAIL FERITWEAR SHIIES ANT
`SRS, I CLASH 35 1108, O 22 ANTI Y
`
`PIRAT USE delhe imd, TN CORTRIDERCE. & Pt
`OB L B s o 1370 100k | Bl 8 S
`TREE CALUHRE b MEL AME WITTTE PSOARD CLARNINEY A% & 0 EATTIRE (0 THLE MAKE
`
`DG B IATLR LRSS TSl T I WO sl e ES ™ 1 W T L LTI RS Al
`A BREDHRECTARTILLA R BACK RGN
`
`WK PAE AS-RORIE L) ad=2inn
`
`AATEA RIS CRAMINI S AT GRS Y
`
`
`
`
`
`
`
`
`‘tfl] States of ngr
`
`WEnited States Patent and Teabemark Office Cf?
`
`Supreme
`
`Reg. No. 5,135,327
`Registered Feb. 07, 2017
`Int. Cl.: 35
`
`Service Mark
`
`Principal Register
`
`T'csutty K Zow
`
`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
`
`
`
`
`
`
`
`
`'@“fifll States of Jmp,.
`
`EHnited States Patent and Trabemark Office Ic(?
`
`Reg. No. 5,066,669
`Registered Oct. 25, 2016
`Int. Cl.: 18
`
`Trademark
`
`Principal Register
`
`T'csutty K Zow
`
`Director of the United States
`Patent and Trademark Otfice
`
`SUPREME
`
`Chapter 4 Corp. (NEW YORK CORPORATION), DBA Supreme ,
`121 Wooster Street, 2F
`New York, NY 10012
`
`CLASS 18: All-purpose sports and athletic bags; duffel and travel bags; fanny packs and
`waist packs; backpacks; knapsacks; wallets
`
`FIRST USE 4-00-1994; IN COMMERCE 4-00-1994
`
`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
`
`
`
`
`
`
`
`
`nited States of Amp,
`
`EHnited States Patent and Trabemark Office Ic(?
`
`SUPREME
`
`Reg. No. 5,135,326
`Registered Feb. 07, 2017
`Int. Cl.: 35
`
`Service Mark
`
`Principal Register
`
`T'csutty K Zow
`
`Director of the United States
`Patent and Trademark Otfice
`
`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 MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY
`PARTICULAR FONT STYLE, SIZE OR COLOR
`
`OWNER OF U.S. REG. NO. 4157110, 4504231, 4240456
`
`SER. NO. 86-691,471, FILED 07-13-2015
`KAREN DINDAYAL, EXAMINING ATTORNEY
`
`
`
`
`
`
`
`
`@x“tgb States of ngr
`
`Anited States Patent and Trabemark Difice a
`
`SUPREME
`
`Reg. No. 4,240,456 CHAPTER 4 CORP. (NEW YORK CORPORATION), DA SUPREMI
`. . , 121 WOOSTER STREET, 21
`Registered Nov. 13, 2012 niw YORK, NY 10012
`
`Int. Cl.: 28 FOR: SKATEBOARD DECKS, IN CLASS 28 (1S, C1S. 22, 23, 38 AND 50),
`
`FIRST USE 3-0-1996; IN COMMERCE 3-0-1996.
`TRADEMARK
`
`THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM 10O ANY PAR-
`PRINCIPAL REGISTER TICULAR FONT STYLE. SIZL OR COLOR.
`
`SEC2(F).
`
`SER.NOL 85-424. 722 FILED 9-16-2011.
`
`STEVEN JACKSON, EXAMINING ATTORNEY
`
`Director of the United Seates resnsnd Tradeesoh O
`
`
`
`
`
`
`
`
`@g\'\tffl
`
`Wnited States Patent and Trabemark Office I[a
`
`SUPREME
`
`Reg. No. 4,157,110
`Registered June 12,2012
`Int. Cl.: 25
`
`TRADEMARK
`
`PRINCIPAL REGISTER
`
`Director of the United Seates resnsnd Tradeesoh O
`
`CHAPTLER 4 CORP A(NEW YORK CORPORATION), DBA SUPREML:
`121 WOOSTER STRELET, 21
`NEW YORK. NY 10012
`
`FOR: CLOTHING, NAMELY, STURTS,T-SHIRTS, LONG-SLEEVED SRS, UNDER SHIRTS,
`POLO SHIRTS, RUGHY SHIRTS. JERSEYS, DRESS SHIRTS, DENIM JEANS, HOODED
`SWEAT STHRTS, WARM-UP SUTTS. SNOW SUITS, PARKAS, CARDIGANS, PANTS, JEAN
`JACKETS, CARGOPANTS. SHORTS, BOXER SHORTS, TOPS.UTANK TOPS, SWEAT SHIRTS,
`SWEATJACKETS, SWEAT SHORTS, SWEAT PANTS. SWEATERS, VESTS, FLEECE VESTS,
`PULLOVERS, JACKETS, COATS, BLAZERS, SUTTS) TURTLENECKS, REVERSIBLE
`JACKETS, WIND-RESISTANTJACKETS. SHELL JACKETS, SPORTS JACKETS, GOLEF AND
`SKEJACKETS, HEAVY COATS, OVER COATS, TOP COATS, SWIMWEAR, BEACHWEAR,
`VISORS. HEADBANDS. FAR MUFEFS. 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 (LS, CLS, 22 AND 39),
`
`FIRST USE 4-0-1994; IN COMMIRCI 4-0-1994.
`
`THE MARK CONSISTS OF STANDARID CHARACTERS WITHOUT CLAIM TO ANY PAR-
`TICULAR FONT, STYLE, SIZ1. OR COLOR.
`
`SER.NO, 85-424.627, VILED 9-16-2011.
`
`STEVEN JACKSON, EXAMINING ATTORNLEY
`
`
`
`
`
`
`
`
`pited States of Qmer
`
`WUnited States Patent and Trademark Office C‘—?
`
`Supreme
`
`Reg. No. 5,763,658
`Registered May 28, 2019
`Int. Cl.: 18
`
`Trademark
`
`Principal Register
`
`bt b
`
`Director of the United Siates
`Patent and Trademark Office
`
`Chapter 4 Corp. (NEW YORK CORPORATION), DBA Supreme
`62 King Street
`New York, NEW YORK 10014
`
`CLASS 18: Book, carry-on, gym, shoulder and tote bags; satchels; luggage; luggage tags;
`trunks; suitcases; bags sold empty; men's clutches; business card cases; calling and credit card
`cases; key cases; leather key chains; billfolds; umbrellas
`
`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 letters against a red rectangular
`background.
`
`OWNER OF U.S. REG. NO. 4157110, 4240456
`
`SER. NO. 86-225,846, FILED 03-19-2014
`
`
`
`
`
`
`
`
`pited States of @mer
`
`WUnited States Patent and Trademark Office [Q
`
`SUPREME
`
`Chapter 4 Corp. (NEW YORK CORPORATION), DBA Supreme
`62 King Street
`Registered Jun. 11’ 2019 New York, NEW YORK 10014
`Int. CL: 18 CLASS 18: Book, carry-on, gym, shoulder and tote bags; satchels; luggage; luggage tags;
`
`trunks; suitcases; bags sold empty; men's clutches; business card cases; calling and credit card
`cases; key cases; leather key chains; billfolds; umbrellas
`
`Trademark
`
`.. . FIRS