`
`ESTTA Tracking number:
`
`ESTTA1081338
`
`Filing date:
`
`09/11/2020
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`92074485
`
`Party
`
`Correspondence
`Address
`
`Defendant
`Alibaba Group Holding Limited
`
`ALEXIS P GRILLI
`NIXON PEABODY LLP
`799 9TH STREET NW
`SUITE 500
`WASHINGTON, DC 20001
`UNITED STATES
`Primary Email: nptm@nixonpeabody.com
`Secondary Email(s): was.managing.clerk@nixonpeabody.com, ag-
`rilli@nixonpeabody.com
`202-585-8000
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Other Motions/Papers
`
`Alexis P. Grilli
`
`nptm@nixonpeabody.com, was.managing.clerk@nixonpeabody.com, ag-
`rilli@nixonpeabody.com
`
`Signature
`
`Date
`
`/Alexis P. Grilli/
`
`09/11/2020
`
`Attachments
`
`FIFTH Consent Motion to Extend.pdf(14616 bytes )
`
`
`
`Attorney Docket No.: 074619-239
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`)
`VOLKSWAGEN AKTIENGESELLSCHAFT, )
`)
`Petitioner, )
`)
`)
`)
`)
`)
`)
`)
`
`v.
`
`ALIBABA GROUP HOLDING LIMITED
`
`Cancellation No. 92074485
`Registration No. 4,540,993
`
`
`
`Respondent/Registrant.
`
`FIFTH CONSENT MOTION TO EXTEND DEADLINES
`FOR SETTLEMENT DISCUSSIONS
`
`Respondent, Alibaba Group Holding Limited (“Respondent”), with the consent of
`
`Petitioner Volkswagen Aktiengesellschaft (“Petitioner”) hereby moves the Board to extend the
`
`deadline for Respondent to file its Answer and all remaining deadlines and trial dates for two (2)
`
`additional weeks in the above referenced proceeding in accordance with TBMP 509.02 as the
`
`parties are engaged in settlement discussions.
`
`Upon acceptance of this motion, Respondent’s deadline to file its Answer will be set for
`
`September 27, 2020, and the remaining dates will be extended as follows:
`
`
`
`Time to Answer
`Deadline for Discovery Conference
`Discovery Opens
`Initial Disclosures Due
`Expert Disclosures Due
`Discovery Closes
`Plaintiff’s Pretrial Disclosures Due
`Plaintiff’s 30•day Trial Period Ends
`Defendant’s Pretrial Disclosures Due
`Defendant’s 30-day Trial Period Ends
`Plaintiffs Rebuttal Disclosures Due
`
`4824-0373-6778.1
`
`
`
`9/27/2020
`10/27/2020
`10/27/2020
`11/26/2020
`3/26/2021
`4/25/2021
`6/9/2021
`7/24/2021
`8/8/2021
`9/22/2021
`10/7/2021
`
`
`
`Plaintiffs 15-day Rebuttal Period Ends
`Plaintiff’s Opening Brief Due
`Defendant’s Brief Due
`Plaintiffs Reply Brief Due
`Request for Oral Hearing (optional) Due
`
`11/6/2021
`1/5/2022
`2/4/2022
`2/19/2022
`3/1/2022
`
`
`
`In the event that this Motion is not granted, Respondent respectfully requests additional time
`
`to file its Answer.
`
`Dated: September 11, 2020
`
`Respectfully submitted,
`
`NIXON PEABODY LLP
`
` by: _/Alexis P. Grilli/
`
`Jeffrey L. Costellia
`Lauren J. Arnold
`Alexis P. Grilli
`Nixon Peabody LLP
`799 9th Street, N.W., Suite 500
`Washington, D.C. 20001
`202-585-8000 (Phone)
`202-585-8080 (Facsimile)
`nptm@nixonpeabody.com
`was.managing.clerk@nixonpeabody.com
`Counsel for Respondent
`
`4824-0373-6778.1
`
`
`
`- 5 -
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on September 11, 2020, I caused to be served via electronic mail a true
`
`and correct copy of the foregoing Fifth Consent Motion to Extend, upon the following:
`
`
`Barth Xavier Derosa
`Belzer PC
`2905 Bull Street
`Savannah, Ga 31405
`bderosa@belzerlaw.com, rwomack@belzerlaw.com, paralegal@belzerlaw.com
`
`
`
`/Alexis P. Grilli/ _____________
`Alexis P. Grilli
`
`4824-0373-6778.1
`
`
`
`- 6 -
`
`
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