Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA Tracking number:
`
`ESTTA1062074
`
`Filing date:
`
`06/15/2020
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Petition for Cancellation
`
`Notice is hereby given that the following party has filed a petition to cancel the registration indicated below.
`
`Petitioner Information
`
`Name
`Entity
`Address
`
`Volkswagen Aktiengesellschaft
`joint stock company
`Berliner Ring 2
`Wolfsburg, 38440
`GERMANY
`
`Citizenship
`
`Germany
`
`Attorney informa-
`tion
`
`Barth Xavier deRosa
`Belzer PC
`2905 Bull Street
`2905 Bull Street
`Savannah, GA 31405
`UNITED STATES
`bderosa@belzerlaw.com, rwomack@belzerlaw.com, paralegal@belzerlaw.com
`2024085955
`
`Registration Subject to Cancellation
`
`Registration No.
`International Re-
`gistration No.
`Registrant
`
`4540993
`NONE
`
`Registration date
`International Re-
`gistration Date
`
`06/03/2014
`NONE
`
`Alibaba Group Holding Limited
`P.O. Box 847
`Fourth Floor, One Capital Place
`Grand Cayman
`CAYMAN ISLANDS
`
`Goods/Services Subject to Cancellation
`
`Class 009. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are subject to cancellation, namely: Scientific, nautical, surveying,
`photographic,cinematographic, optical, weighing, measuring, signaling,checking, life-saving and
`teaching apparatus and instruments, namely, telephones, punch clocks, time recording devices,
`namely, time clocks, scales and balances,graduated rulers, electronic pocket translators, neon
`signs,electronic notice boards, transparency projection apparatus,kilometer recorders in the nature of
`odometers for vehicles,telescopes, mechanisms for counter operated apparatus,namely, point-
`of-saleterminals, fire extinguishers,acoustic alarms, namely, smoke and fire alarms, batter-
`ies,exposed files, namely, exposed camera film; apparatus and instruments for conducting, switching,
`transforming accumulating, regulating or controlling electricity, namely,electric wires; electric
`switches; electroplating apparatus,namely, electroplating machines, electricwelding apparat-
`us,namely, torches; electrified fences, namely, electric fences;apparatus for recording, transmission
`or reproduction of sound or images; blankmagnetic data carriers and recording discs; mechanisms
`for coin-operated apparatus; cash registers, calculating machines, data processing equipment and
`
`

`

`computers; notebook computers;laptop computers;portable computers; handheld computers;personal
`digital assistants; portable media players; mobile telephones; smart phones; digital cameras; com-
`puter workstations comprised of computers and computermonitors;servers, namely, computer serv-
`ers; computer and telecommunications networking computer hardware; computer network adaptors,
`switches, routers and hubs; wireless and wired modems and computerequipment, namely, wireless
`cards;laptop holders in the nature of protective sleeves and carrying cases, computer bags;fire extin-
`guishing apparatus;computer hardware; computer software and downloadable software for use in
`connection with the provision of an interactive website,namely, for use by third parties to post inform-
`ation, create electronic productcatalogs,respond to requests and place and fulfill orders for products,
`services and business opportunities via local and global computer networks, for use in document
`management,for searching, browsing and receiving transmissions of text,electronic documents,
`graphics and audiovisual information on local remote area,global computer networks, on intranets or
`directories of information available on computer networks, for use in software development and web
`authoring,for use in exchanging information via global computer networks and online from a computer
`database and the internet, for business use for financial management,financialplanning, business
`management, customerrelationship management (CRM), inventory management, sales force man-
`agement, planning and management of personal and business finances, and marketing information
`management,data mining, high-speed massive ecommerce data processing,and datacustomization
`all in the field of e-commerce;computer programs and computer software in the field of business for
`use in financial management, financial planning, business management, customer relationship man-
`agement (CRM), inventory management, sales force management, planning and management of
`personal and business finances, and marketing information management, all in the field of e-
`commerce; telecommunications apparatus devices,namely, VOIP phones, electronic facsimile appar-
`atus,portable digital electronic device for sending and receiving electronicmails, and instant mes-
`saging communication tool in the nature of portable telecommunication instant messaging devices;
`mobile phone handsets, namely, mobile phones; mobile phone accessories devices, namely, battery
`chargers, cases, covers,ear phones and devices for hands free use of mobile phones; all of the fore-
`going products excluding any products related to restaurants, bars, lounges, cafés, catering, food
`service, hotels, lodging,temporary accommodations, conferences, banquet facilities,beach clubs, or
`spas, any products related to music or entertainment sold or provided in connection with restaurants,
`bars, lounges, cafes, catering, food service,hotels, lodging, temporary accommodations, confer-
`ences,banquet facilities, beach clubs, or spas, and any products related to the production, presenta-
`tion, or provision of live entertainment
`Class 035. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are subject to cancellation, namely: Advertising; business man-
`agement; business administration;providing office functions; database management; market research
`and business consulting services; business consultancy services relating to facilitating the transaction
`of businessvia local and global computer networks by locating and providing referrals for the delivery
`of a wide variety of business and consumer products and services; providing of business information
`of goods and services of others via local and global computer networks;business consultancy ser-
`vices in the field of global computer web sites, namely, e-commerce websites, where third parties can
`offer and source goods and services, place,determine the status of and fulfill trade leadsand or-
`ders,enter into contracts and transact business; providing computerized online ordering services fea-
`turing a widevariety of consumer, business and industrial products;advertising of goods and services
`of others via local and global computer networks; international import and export agency services;
`rental of advertising space on communication media; online trading services in the nature ofonline
`auctioneering services via the Internet and providing online business evaluation relating
`thereto;online retail store services, namely, an e-commerce website featuring a wide variety of con-
`sumer goods of others;business consultancy services in the field of operating an electronic market-
`place for the buyers and sellers of goods and/or services on a global computer network; business ad-
`ministration and management assistance for others in the field of facilitating business transaction via
`local and global computer networks; corporate business management consultancy services; market-
`ing and promotion services;publication of publicity materials; dissemination of advertising materials,
`updating of advertising materials,compilation of advertisements for use as web pages on the Internet;
`rental of advertising space; computer data processing; providing information concerning commercial
`sales on e-commerce websites; providing business information, promotional information services,
`namely, promoting the goods of others by providing information regarding discounts, coupons, re-
`bates, vouchers and special offers for the goods of others; telephone answering ser-
`vice;auctioneering provided onthe Internet; personnel management; commercial sales information,
`
`

`

`business information, advertising and commercial information, all in the field of e-commerce,through
`a global computer network and via the Internet; presentation of goods, namely, the goods of others,
`on communication media for retail purposes;the bringing together, for the benefit of others, of a vari-
`ety of goods, enabling customers to conveniently view and purchase those goods from a general
`merchandise Internet web site specializing in the marketing of the sale of good sand services of oth-
`ers; retail and wholesale store services featuring telephones, mobile phonehandsets, mobile phone
`accessories, electronic and telecommunications goods,computer hardware and computer software,
`batteries, battery chargers, apparatus andinstruments for recording,receiving, transmitting and/or re-
`producing data,information, pictures, images and/or sound, precious metals,precious stones, magnet-
`icand non-magnetically encoded cards, picture frames, textiles, laces and embroidery,buttons, rib-
`bons, pins and needles, artificial flowers,carpets, rugs, games and electronic toys, chemicals used in
`industry, science, photography and agriculture, paints,varnishes and lacquers, cleaning and bleach-
`ing preparations,fuels,pharmaceutical, veterinary and sanitarypreparations,ironmongery and small
`items of metal hardware, machines and machine tools, cutlery, razors and hand
`tools,computers,calculating machines, electrical, photographic,cinematographic and optical apparat-
`us and instruments,surgicaland medical apparatus and instruments, apparatus for lighting, heating,
`steam generating, refrigerating,drying, ventilating, water supply and sanitary purposes,vehicles, fire-
`arms, fireworks, silverware, horological and chromometric instruments, musical instruments,
`magazine,picture, typewriters and office requisites, packaging materials, rubber and plasticsfor man-
`ufacture use, packing and insulating materials, mirrors, ropes, string, nets,tents, yarns and threads
`for textile use, coat hangers,dressmaker's articles, bed and table covers; playthings,floral products,
`tobacco, smokers' articles and matches;direct mail advertising; buying and selling agency ser-
`vices,namely, purchasing a wide variety of consumer, business and industrial products and services
`for others; selection and procurement of goods, namely, purchasing of a wide variety of consumer,
`business and industrial products and services for individuals and businesses; catalog and online or-
`dering services featuring the general consumer goods of others;secretarial services; providing statist-
`ical information; organization of exhibitions for commercial or advertising purposes; business ser-
`vices, namely, the compilation and rental of marketing mailing lists; businessinvestigation;business
`administration consultation services in the field of processing of sales made on the Internet; business
`networking services and personnel placement; import-export agencies; subscriptions to newspapers;
`document reproduction; transcription services, namely,conference call, message and stenographic
`transcription; rental of office equipment; customer relationship management; business management
`services relating toelectronic commerce; tax information services; and art gallery services; all ofthe
`foregoing services excluding any services related to or provided in connection with, restaurants, bars,
`lounges,cafés, catering, food service, hotels, lodging, temporary accommodations, conferences,
`banquet facilities, beach clubs, spas, or the production, presentation, or provision of live entertain-
`ment
`Class 038. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are subject to cancellation, namely: Telecommunications access
`services; provision of telecommunication access to computer database and to the Internet and
`providing online communications links which transfer the user to other local andglobal web
`pages;telecommunications services, namely, the electronic transmission of data and documents;
`providing telecommunications connections to the Internet or databases; provision of telecommunica-
`tion access to the worldwide web; communication by computer terminals; communication by fiber op-
`tic networks; electronic transmission of messages and images by computer; facsimile transmission;
`message sending; paging services; rental ofmodems; transmission of data by electronic means; rent-
`al of telecommunication equipment; electronic message sending, receiving and forwarding services;
`transmission and delivery of data by electronicmeans; electronic transmission and delivery of mail
`messages, still picture and/or moving picture information, namely, characters, messages, tele-
`grams,information and data by electronic, telephone, telegraph,cable, computer and satellite means;
`transmission, broadcast and reception of data whether in compressed or uncompressed form and
`whether in real or delayed time; electronic messaging services, telephone, video and web conferen-
`cingservices and order transmission services; video conferencing services; providing an electronic
`bulletin board that enables users to perform a real-time interactive talk between a computer terminal
`and an electronic bulletin board containing still picture and moving picture information and voice in-
`formation concerning business and e-commerce; providing electronic bulletin boards and message
`boardsfor transmission of messages among users concerning business and e-commerce-commerce;
`providing an online discussion forums for transmission of messages among computer users concern-
`ing business and ecommerce; electronic transmission of information in the field of on-line shopping
`
`

`

`and general retail services; news agency services for electronic transmission;providing access to
`computer databases on the global computer network; providing chat room services or transmission of
`messages among computer users concerningbusiness and e-commerce; providing multiple user ac-
`cess to global computer information networks; communication services, namely, text and numeric
`wireless digital messaging services; transmission of information and data communications for assist-
`ing decision making; transmission of information through video communication systems; web confer-
`encing services; providing electronic bulletin boards for the posting and transmission of messages-
`among and between computer users concerning consumer products,services and business leads
`and opportunities; providing an online interactive bulletin board forthe posting,promotion, sale and re-
`sale of items via a global computer network; providing electronic mail and electronicmail forwarding
`services; audio and video communication via computers and computer networks, and via a global
`communications network; providing computer accessto online interactive bulletin boards and data-
`bases; all of the foregoing services excluding any services related to orprovided in connection with,
`restaurants, bars, lounges,cafés, catering, food service, hotels, lodging, temporary accommoda-
`tions, conferences, banquet facilities, beach clubs, spas, or the production, presentation, or provision
`of live entertainment
`Class 042. First Use: 0 First Use In Commerce: 0
`All goods and services in the class are subject to cancellation, namely: Design and development of
`computer hardware and software;design of computers, notebook computers, laptop com-
`puters,portable computers and handheld computers; design for others in the field of personal digital
`assistants and personal media players; design for others in the field of mobile telephones and smart
`phones; design for others in the field of digitalcameras; computer services, namely,creating an on-
`line community for registeredusers to develop and collaborate on address books and calen-
`dars;computer programming; computer system software services,namely, design and development of
`online computer software systems; providing direct connection services between computer users for
`exchanging data, namely, providing temporary use of online non-downloadable software for the ex-
`change of data; computer system design; design and development of web pages; hosting web pages
`for others;hosting computer application software of others for use in searching and retrieving informa-
`tion from databases and computer networks; providing technical information at the specific request of
`end-users by means of telephone or global computer network; computer services, namely,providing
`search engines for customized searching of computer databases and websites on a global computer
`network; providing customized online web pages featuring user-defined informationwhich includes
`online links to third party web sites; all of the foregoing services excluding any services related to or
`provided in connection with, restaurants, bars, lounges, cafés, catering, foodservice, hotels,
`lodging, temporary accommodations,conferences, banquet facilities, beach clubs, spas, or the pro-
`duction, presentation, or provision of live entertainment
`
`Grounds for Cancellation
`
`Abandonment
`
`Trademark Act Section 14(3)
`
`Attachments
`
`919-537 A 6.15.20 Final Petition to Cancel VW vs. Alibaba.pdf(4337073 bytes )
`
`Signature
`Name
`Date
`
`/barth xavier derosa/
`Barth Xavier deRosa
`06/15/2020
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`
`
`_________________________________________
`
`
`VOLKSWAGEN AKTIENGESELLSCHAFT,
`
`
`
`Petitioner,
`
`v. Cancellation No.
`
`ALIBABA GROUP HOLDING LIMITED Registration No. 4,540,993
`
`
`
`Respondent/Registrant.
`
`_________________________________________
`
`
`
`PETITION FOR CANCELLATION
`
`
`
`In the matter of Registration No. 4,540,993 covering the mark “TAO” for an extensive
`
`variety of goods and services falling within classes 9, 35, 38 and 42 issued on June 3, 2014 to
`
`Alibaba Group Holding Limited, a corporation organized under the laws of the Cayman Islands,
`
`with a principal place of business at P.O. Box 847, Fourth Floor, One Capital Place, Grand
`
`Cayman, Cayman Islands (hereinafter “Respondent/Registrant”). Volkswagen Aktiengesellschaft,
`
`a joint stock company, duly organized under the laws of Germany, with a principal place of
`
`business at Berliner Ring 2, Wolfsburg, Germany 38440 (hereinafter “Petitioner”), believes it is
`
`damaged by such registration and hereby seeks to cancel it.
`
`The grounds for Cancellation under 15 U.S.C. Section 1064(3) of the Lanham Act, as
`
`amended, are as follows:
`
`1. Petitioner is a leading manufacturer and distributor of vehicles together with related
`
`parts and accessories therefor throughout the world, and offers a vast array of services related
`
`thereto.
`
`
`
`1
`
`

`

`2. On June 27, 2019, Petitioner in accordance with the Madrid Protocol Provisions under
`
`Section 66(a) of the Lanham Act, did designate the United States for an Extension of Protection
`
`for registration of the mark “TAOS.” Said Extension of Protection is based on International
`
`Registration No. 1,514,235 dated June 27, 2019, with a priority claim dated February 8, 2019 based
`
`on German Application Ser. No.30 2019 002 821. The Extension of Protection was assigned U.S.
`
`Application Serial No. 79/278,592 for the following goods and services as amended via response
`
`dated March 15, 2020:
`
`Class 12: Vehicles and conveyances; vehicles for locomotion by land, air, water
`
`or rail and their parts; motorized land vehicles; driverless cars [autonomous cars];
`
`motors and engines for land vehicles; propulsion mechanisms for land vehicles;
`
`vehicle chassis; vehicle bodies; couplings for land vehicles; suspension shock
`
`absorbers for vehicles; shock absorbing springs for vehicles; pneumatic tires; tires
`
`for vehicle wheels; rims for vehicle wheels; tires, solid, for vehicle wheels; vehicle
`
`wheels; hubs for vehicle wheels; inner tubes for pneumatic tires; repair outfits for
`
`inner tubes; adhesive rubber patches for repairing inner tubes; spikes for tires; anti-
`
`skid chains for vehicles; nonskid devices for vehicle tires; vehicle seats; rearview
`
`mirrors; head-rests for vehicle seats; anti-theft alarms for land vehicles; anti-theft
`
`devices for vehicles; cigar lighters for automobiles; motor cars; automobiles;
`
`trucks; trailers and semi-trailers for vehicles, trailer hitches for vehicles;
`
`omnibuses; motorcycles, mopeds, bicycles; cable transport apparatus and
`
`installations; carts; trolleys; air vehicles; boats, ships; locomotives; motorbuses;
`
`caravans; tractors; cycles; scooters [vehicles]; chairlifts; funiculars; wheelchairs;
`
`parts and fittings of all the aforesaid goods, included in this class.
`
` Class 28: Sporting articles and equipment; gymnastic articles; Christmas tree
`
`decorations and artificial Christmas trees; fairground and playground apparatus;
`
`toys, games, playthings and novelties; scale model kits [toys]; stuffed toy animals
`
`and other stuffed toys; automatic amusement machines (coin-operated machines);
`
`
`
`2
`
`

`

`arcade video game machines; video game machines; scale model vehicles; toy
`
`vehicles; scooters (toys for children); scale model automobiles; toy automobiles;
`
`radio-controlled toy vehicles; balls for games; kaleidoscopes; board games; playing
`
`cards; playing balls; stationary exercise bicycles; archery implements; appliances
`
`for gymnastics; plastic racetrack; gloves for games; floats for fishing; camouflage
`
`screens [sports articles]; parts and fittings of all aforesaid goods, included in this
`
`class.
`
`Class 35: Retail and wholesale store services for motor vehicles and their parts and
`
`fittings; retail and wholesale mail-order services featuring motor vehicles and their
`
`parts and fittings; negotiation of business contracts for others, namely, negotiation
`
`of contracts for others for the sale and purchase of motor vehicles
`
`Class 37: Reconstruction, repair, dismantling and maintenance of vehicles in the
`
`nature of vehicle repair in the course of vehicle breakdown service; repair and
`
`maintenance of vehicles in the nature of cleaning and servicing, namely, repairing,
`
`washing and polishing, and varnishing of vehicle
`
`3. On March 2, 2020, the Examining Attorney did issue the first Official Action in
`
`Application Ser. No. 79/278,592. In that Official Action, the Examining Attorney refused
`
`registration under Section 2(d) and requested amendments to the identification of goods and
`
`services. In connection with the refusal under Section 2(d) of the Trademark Act, the Examining
`
`Attorney refused registration of Applicant’s “TAOS” mark on the grounds that registration is apt
`
`to create a likelihood of confusion, in part, with U.S. Registration No. 4,540,993 covering the
`
`mark “TAO” as owned by and registered to Respondent, Alibaba Group Holding Limited, for the
`
`following goods and services:
`
`Class 9: Scientific, nautical, surveying, photographic, cinematographic, optical,
`
`weighing, measuring, signaling, checking, life-saving and teaching apparatus and
`
`instruments, namely, telephones, punch clocks, time recording devices, namely, time
`
`
`
`3
`
`

`

`clocks, scales and balances, graduated rulers, electronic pocket translators, neon signs,
`
`electronic notice boards, transparency projection apparatus, kilometer recorders in
`
`the nature of odometers for vehicles, telescopes, mechanisms for counter operated
`
`apparatus, namely, point-of-sale terminals, fire extinguishers, acoustic alarms, namely,
`
`smoke and fire alarms, batteries, exposed files, namely, exposed camera film;
`
`apparatus and instruments for conducting, switching, transforming accumulating,
`
`regulating or controlling electricity, namely, electric wires; electric switches;
`
`electroplating apparatus, namely, electroplating machines, electric welding apparatus,
`
`namely, torches; electrified fences, namely, electric fences; apparatus for recording,
`
`transmission or reproduction of sound or images; blank magnetic data carriers and
`
`recording discs; mechanisms for coin-operated apparatus; cash registers, calculating
`
`machines, data processing equipment and computers; notebook computers; laptop
`
`computers; portable computers; handheld computers; personal digital assistants;
`
`portable media players; mobile telephones; smart phones; digital cameras; computer
`
`workstations comprised of computers and computer monitors; servers, namely,
`
`computer servers; computer and telecommunications networking computer hardware;
`
`computer network adaptors, switches, routers and hubs; wireless and wired modems
`
`and computer equipment, namely, wireless cards; laptop holders in the nature of
`
`protective sleeves and carrying cases, computer bags; fire extinguishing apparatus;
`
`computer hardware; computer software and downloadable software for use in
`
`connection with the provision of an interactive website, namely, for use by third parties
`
`to post information, create electronic product catalogs, respond to requests and place
`
`and fulfill orders for products, services and business opportunities via local and global
`
`computer networks, for use in document management, for searching, browsing and
`
`receiving transmissions of text, electronic documents, graphics and audiovisual
`
`information on local remote area, global computer networks, on intranets or directories
`
`of information available on computer networks, for use in software development and
`
`web authoring, for use in exchanging information via global computer networks and
`
`
`
`4
`
`

`

`online from a computer database and the internet, for business use for financial
`
`management, financial planning, business management, customer relationship
`
`management (CRM), inventory management, sales force management, planning and
`
`management of personal and business finances, and marketing
`
`information
`
`management, data mining, high-speed massive ecommerce data processing, and data
`
`customization all in the field of e-commerce; computer programs and computer
`
`software in the field of business for use in financial management, financial planning,
`
`business management, customer relationship management (CRM),
`
`inventory
`
`management, sales force management, planning and management of personal and
`
`business finances, and marketing information management, all in the field of e-
`
`commerce; telecommunications apparatus devices, namely, VOIP phones, electronic
`
`facsimile apparatus, portable digital electronic device for sending and receiving
`
`electronic mails, and instant messaging communication tool in the nature of portable
`
`telecommunication instant messaging devices; mobile phone handsets, namely, mobile
`
`phones; mobile phone accessories devices, namely, battery chargers, cases, covers,
`
`ear phones and devices for hands free use of mobile phones; all of the foregoing
`
`products excluding any products related to restaurants, bars, lounges, cafés, catering,
`
`food service, hotels, lodging, temporary accommodations, conferences, banquet
`
`facilities, beach clubs, or spas, any products related to music or entertainment sold or
`
`provided in connection with restaurants, bars, lounges, cafes, catering, food service,
`
`hotels, lodging, temporary accommodations, conferences, banquet facilities, beach
`
`clubs, or spas, and any products related to the production, presentation, or provision of
`
`live entertainment
`
`
`
`Class: 35: Advertising; business management; business administration; providing
`
`office functions; database management; market research and business consulting
`
`services; business consultancy services relating to facilitating the transaction of
`
`business via local and global computer networks by locating and providing referrals for
`
`
`
`5
`
`

`

`the delivery of a wide variety of business and consumer products and services;
`
`providing of business information of goods and services of others via local and global
`
`computer networks; business consultancy services in the field of global computer web
`
`sites, namely, e-commerce websites, where third parties can offer and source goods and
`
`services, place, determine the status of and fulfill trade leads and orders, enter into
`
`contracts and transact business; providing computerized online ordering services
`
`featuring a wide variety of consumer, business and industrial products; advertising of
`
`goods and services of others via local and global computer networks; international
`
`import and export agency services; rental of advertising space on communication
`
`media; online trading services in the nature of online auctioneering services via the
`
`Internet and providing online business evaluation relating thereto; online retail store
`
`services, namely, an e-commerce website featuring a wide variety of consumer goods
`
`of others; business consultancy services in the field of operating an electronic
`
`marketplace for the buyers and sellers of goods and/or services on a global computer
`
`network; business administration and management assistance for others in the field of
`
`facilitating business transaction via local and global computer networks; corporate
`
`business management consultancy services; marketing and promotion services;
`
`publication of publicity materials; dissemination of advertising materials, updating of
`
`advertising materials, compilation of advertisements for use as web pages on the
`
`Internet; rental of advertising space; computer data processing; providing information
`
`concerning commercial sales on e-commerce websites; providing business
`
`information, promotional information services, namely, promoting the goods of others
`
`by providing information regarding discounts, coupons, rebates, vouchers and special
`
`offers for the goods of others; telephone answering service; auctioneering provided on
`
`the Internet; personnel management; commercial sales information, business
`
`information, advertising and commercial information, all in the field of e-commerce,
`
`through a global computer network and via the Internet; presentation of goods, namely,
`
`the goods of others, on communication media for retail purposes; the bringing together,
`
`
`
`6
`
`

`

`for the benefit of others, of a variety of goods, enabling customers to conveniently view
`
`and purchase those goods from a general merchandise Internet web site specializing in
`
`the marketing of the sale of goods and services of others; retail and wholesale store
`
`services featuring telephones, mobile phone handsets, mobile phone accessories,
`
`electronic and telecommunications goods, computer hardware and computer software,
`
`batteries, battery chargers, apparatus and instruments for recording, receiving,
`
`transmitting and/or reproducing data, information, pictures, images and/or sound,
`
`precious metals, precious stones, magnetic and non-magnetically encoded cards,
`
`picture frames, textiles, laces and embroidery, buttons, ribbons, pins and needles,
`
`artificial flowers, carpets, rugs, games and electronic toys, chemicals used in industry,
`
`science, photography and agriculture, paints, varnishes and lacquers, cleaning and
`
`bleaching preparations, fuels, pharmaceutical, veterinary and sanitary preparations,
`
`ironmongery and small items of metal hardware, machines and machine tools, cutlery,
`
`razors and hand tools, computers, calculating machines, electrical, photographic,
`
`cinematographic and optical apparatus and instruments, surgical and medical apparatus
`
`and instruments, apparatus for lighting, heating, steam generating, refrigerating,
`
`drying, ventilating, water supply and sanitary purposes, vehicles, firearms, fireworks,
`
`silverware, horological and chromomeric instruments, musical instruments, magazine,
`
`picture, typewriters and office requisites, packaging materials, rubber and plastics for
`
`manufacture use, packing and insulating materials, mirrors, ropes, string, nets, tents,
`
`yarns and threads for textile use, coat hangers, dressmaker’s articles, bed and table
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`covers; playthings, floral products, tobacco, smokers' articles and matches; direct mail
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`advertising; buying and selling agency services, namely, purchasing a wide variety of
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`consumer, business and industrial products and services for others; selection and
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`procurement of goods, namely, purchasing of a wide variety of consumer, business and
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`industrial products and services for individuals and businesses; catalog and online
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`ordering services featuring the general consumer goods of others; secretarial services;
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`providing statistical information; organizatio