PTO Form 1957 (Rev 9/2005)
`
`OMB No. 0651-0050 (Exp. 07/31/2017)
`
`Response to Office Action
`
`Input Field
`
`SERIAL NUMBER
`
`LAW OFFICE ASSIGNED
`
`MARK SECTION
`
`MARK
`
`LITERAL ELEMENT
`
`STANDARD CHARACTERS
`
`USPTO-GENERATED IMAGE
`
`MARK STATEMENT
`
`EVIDENCE SECTION
`
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)EVIDENCE FILE NAME(S)
`
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)ORIGINAL PDF FILE
`
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)CONVERTED PDF FILE(S)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(11 pages)
`
`SIGNATURE SECTION
`
`RESPONSE SIGNATURE
`
`SIGNATORY'S NAME
`
`SIGNATORY'S POSITION
`
`SIGNATORY'S PHONE NUMBER
`
`DATE SIGNED
`
`AUTHORIZED SIGNATORY
`
`FILING INFORMATION SECTION
`
`The table below presents the data as entered.
`
`Entered
`
`86621186
`
`LAW OFFICE 115
`
`http://tmng-al.uspto.gov/resting2/api/img/86621186/large
`
`AMERICAN EXPEDITION HONEY GINGER WHEAT ALE
`
`YES
`
`YES
`
`The mark consists of standard characters, without claim to any particular font style, size
`or color.
`
`evi_701095979-20151012103708040692_._AMERICAN_EXPEDITION_OAR_V2.pdf
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0002.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0003.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0004.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0005.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0006.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0007.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0008.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0009.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0010.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0011.JPG
`
`\\TICRS\EXPORT16\IMAGEOUT16\866\211\86621186\xml4\ROA0012.JPG
`
`/khardley/
`
`KEISHA HARDLEY
`
`Associate Attorney, Dunlap, Bennett & Ludwig PLLC (MD Bar)
`
`703.777.7319
`
`10/12/2015
`
`YES
`
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`

`

`SUBMIT DATE
`
`TEAS STAMP
`
`Mon Oct 12 10:40:24 EDT 2015
`
`USPTO/ROA-XX.XXX.XX.XX-20
`151012104024433554-866211
`86-5401de11da5d9a12dcf165
`88c5c1f01189457952b0d1937
`47977ed91ea1c17482-N/A-N/
`A-20151012103708040692
`
`PTO Form 1957 (Rev 9/2005)
`
`OMB No. 0651-0050 (Exp. 07/31/2017)
`
`To the Commissioner for Trademarks:
`
`Response to Office Action
`
`Application serial no. 86621186(cid:160)AMERICAN EXPEDITION HONEY GINGER WHEAT ALE(Standard Characters, see http://tmng-
`al.uspto.gov/resting2/api/img/86621186/large) has been amended as follows:
`
`EVIDENCE
`
`Original PDF file:
`evi_701095979-20151012103708040692_._AMERICAN_EXPEDITION_OAR_V2.pdf
`Converted PDF file(s) ( 11 pages)
`Evidence-1
`Evidence-2
`Evidence-3
`Evidence-4
`Evidence-5
`Evidence-6
`Evidence-7
`Evidence-8
`Evidence-9
`Evidence-10
`Evidence-11
`
`SIGNATURE(S)
`Response Signature
`Signature: /khardley/(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)Date: 10/12/2015
`Signatory's Name: KEISHA HARDLEY
`Signatory's Position: Associate Attorney, Dunlap, Bennett & Ludwig PLLC (MD Bar)
`
`Signatory's Phone Number: 703.777.7319
`
`The signatory has confirmed that he/she is an attorney who is a member in good standing of the bar of the highest court of a U.S. state, which
`includes the District of Columbia, Puerto Rico, and other federal territories and possessions; and he/she is currently the owner's/holder's attorney
`or an associate thereof; and to the best of his/her knowledge, if prior to his/her appointment another U.S. attorney or a Canadian attorney/agent
`not currently associated with his/her company/firm previously represented the owner/holder in this matter: (1) the owner/holder has filed or is
`concurrently filing a signed revocation of or substitute power of attorney with the USPTO; (2) the USPTO has granted the request of the prior
`representative to withdraw; (3) the owner/holder has filed a power of attorney appointing him/her in this matter; or (4) the owner's/holder's
`appointed U.S. attorney or Canadian attorney/agent has filed a power of attorney appointing him/her as an associate attorney in this matter.
`
`Serial Number: 86621186
`Internet Transmission Date: Mon Oct 12 10:40:24 EDT 2015
`TEAS Stamp: USPTO/ROA-XX.XXX.XX.XX-20151012104024433
`554-86621186-5401de11da5d9a12dcf16588c5c
`1f01189457952b0d193747977ed91ea1c17482-N
`
`(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)(cid:160)
`

`

`/A-N/A-20151012103708040692
`
`/A-N/A-20151012103708040692
`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Applicant:
`Serial No.:
`
`Heritage Brewing Co.
`86621 186
`
`Filed:
`Trademark Atty:
`Trademark:
`
`May 06, 2015
`Katherine S. Chang
`AMERICAN EXPEDITION HONEY GINGER WHEAT ALE
`
`RESPONSE TO JULY 29, 2015 OFFICE ACTION
`
`This Response is filed in reply to the Office Action e-mailed on July 29, 2015. The Applicant
`
`respectfully submits the following response. Applicant submits that the above—identified trademark
`
`application for AMERICAN EXPEDITION HONEY GINGER WHEAT ALE is in condition for
`
`allowance to publication.
`
`SECTION 2(d) REFUSAL — LIKELIHOOD OF CONFUSION
`
`Applicant submits a preliminary response to the potential section 2(d) refusal; however, Applicant
`
`reserves all rights to provide a detailed and descriptive response if Examining Attorney Katherine S.
`
`Chang raises a Section 2(d) refusal in a subsequent Office Action.
`
`APPLICANT’S MARK
`
`CITED REGISTERED MARKS
`
`AMERICAN EXPEDITION HONEY
`
`EXPEDITION
`
`GINGER WHEAT ALE
`
`Serial No_ 86621186
`
`Class 032: Beer, ale and lager
`
`Registration. No. 3052688
`
`Class 032: Beer, namely porter, ale, stout and
`malt liquor
`
`

`

`EXPEDITION
`
`Registration No. 4045 5 3 0
`
`Class 020: Nonmetal taps for kegs; nonmetal tap
`globes for kegs
`
`Class 025: Clothing namely, t-shirts, camp shirts
`
`Class 032: Beer; stout; malt liquor
`
`Factors used to determine likelihood of confusion in trademark registration case include: similarity or
`
`dissimilarity of marks in their entireties as to appearance, sound, connotation, and commercial
`
`impression; similarity or dissimilarity and nature of the goods described in application or registration
`
`or in connection with which a prior mark is in use; conditions under which and buyers to whom sales
`
`are made; number and nature of similar marks in use on similar goods; any other established fact
`
`probative of effect of use. Lanham Trade—Mark Act, § 2(d), 15 U.S.C.A. § l052(d). Not all of the
`
`factors used to determine likelihood of confusion in a trademark registration case may be relevant or
`
`of equal Weight
`
`in a given case, and any one of the factors may control a particular case. Id.
`
`Likelihood of confilsion under the Lanham Act, 15 U.S.C. § l052(d), is a legal determination based
`
`upon factual underpinnings. 0n—Lme Careline,
`
`Inc.
`
`1/. Am. Online, Inc, 229 F.3d 1080, 1084
`
`(Fed.Cir.2000).
`
`

`

`AN EXAMINATION OF THE MARKS AS TO APPEARANCE,
`CONNOTATION DETERMINE THEY ARE NOT SIMILAR
`
`SOUND AND
`
`Under In re E. I. du Pont de Nemours & Co., 476 F.2d 1357, 1361, 177 USPQ 563, 567 (C.C.P.A.
`
`1973), the first factor requires examination of "the similarity or dissimilarity of the marks in their
`
`entireties as to appearance, sound, connotation [,] and commercial impression." When considering the
`
`similarity of the marks, "[a]l1 relevant facts pertaining to the appearance and connotation must be
`
`considered." Recot, Inc. v. MC. Becton, 214 F.3d 1322, 1329, 54 USPQ2d 1894, 1897 (Fed. Cir.
`
`2000)
`
`Appearance & Sound
`
`In the instant case,
`
`the Examining Attorney improperly dissected the mark AMERICAN
`
`EXPEDITION HONEY GINGER WHEAT ALE in violation of the anti-dissection rule, which states
`
`that a likelihood of confusion “cannot be predicated on dissection of a mark, that is, only part of a
`
`mark.” In re Nat’! Data Corp, 753 F.3d 1056, 1058 (Fed. Cir. 1985). The Examining Attorney has
`
`discarded the dissimilar portions of Applicant’s mark from the dissimilar portions within cited
`
`Registrant’s marks. The Applicant has applied for AMERICAN EXPEDITION HONEY GINGER
`
`WHEAT ALE, whereas cited marks all owned by the same Registrant include EXPEDITION and
`
`EXPEDITION. The Examining Attorney has erroneously concluded that the terms “honey, ginger,
`
`wheat, and ale” which appear in Applicant’s marks, will not be impressed upon the minds of the
`
`consumer. The filing of a disclaimer with the Patent and Trademark Office does not remove the
`
`disclaimed matter from the purview of determination of likelihood of confusion. In re Shell 01'! C0,,
`
`992 F.61 I204 (Fed. Cir. I 993). These additional terms help to distinguish Applicant’s mark apart from
`
`

`

`the cited registrations. Further, Applicant’s mark consistently appears in conjunction with a backdrop
`
`of the American frontier on the product packaging (See Exhibit A). This product packaging is distinct
`
`and assists in further distinguishing Applicant’s mark apart from the cited registrations. Thus, the
`
`consumer can easily differentiate between the products offered by Applicant versus those offered by
`
`Registrant’s. Moreover, the cited registrations consistently appear in conjunction with the name of the
`
`brewery that produces its described product, Bell’s Brewery (See Exhibit B). As a result of the
`
`differences in appearance of the overall packaging the average consumer will be able to distinguish
`
`between Applicant’s mark and the cited registrations similar to how consumers can distinguish
`
`between beers crafted by Anheuser Busch versus Yuengling & Sons.
`
`Connotation
`
`Further, the Examining Attorney erroneously discounts the connotation created by incorporating the
`
`terms “honey, ginger and wheat ale.” Today’s consumers of beer are more particular and selective than
`
`they have been in previous decades. As a result of this particularity today’s consumers are selective
`
`about the beer they choose to purchase. Due to this particularity, noting that Applicant’s product
`
`contains “honey, ginger, and wheat” will play a significant factor in whether the consumer chooses the
`
`described product Versus the cited registrants or other similar products. The terms “honey, ginger and
`
`wheat ale” immediately convey to the consumer the flavors to be expected within Applicant’s product.
`
`Also, there are significant differences between beers that are ales versus beers that are stouts (See
`
`Exhibit C). In this instance Applicant’s mark indicates it is ale that contains honey, ginger and wheat,
`
`thus a distinct connotation is created in the mind of the consumer permitting the consumer to
`
`distinguish Applicant’s mark apart from the cited registration.
`
`

`

`WHEN VIEWED IN ITS ENTIRETY APPLICANT’S MARK HAS A DISTINCT
`COMNIERCIAL IMPRESSION
`
`Courts have held that the addition of different terms to common elements appreciably reduces the
`
`likelihood of confusion between two marks, even in cases where the goods are highly similar. See
`
`USTrust v. US. States Trust Co., 210 F. Supp 2d9 27-28 (D. Mass. 2002), (holding that UNITED
`
`STATES TRUST COMPANY not confusingly similar to UNITED STATES TRUST COMPANY OF
`
`BOSTON, both for financial services).
`
`Additionally, in In re Electrolyte Labs, 929 F.2d 645, U.S.P.Q. 2d 1239 (Fed. Cir. 1990), the Federal
`
`Circuit reversed the Trademark Trial and Appeal Board and held that the marks “K+ and Design” and
`
`“K+ EFF” for “competitive dietary supplements” were not likely to be confused even if consumers
`
`would say “K-Plus” and “K-Plus EFF” when calling for products.” Id. At [picite]. The Court held that
`
`the “EFF” in the Registrant’s mark was a significant difference and ruled that “[n]o element of a mark
`
`is ignored simply because it is less dominant, or would not have trademark significance if used alone.”
`
`Id. Furthermore, a similar phrase found in two marks is not dispositive of a confusing similarity
`
`between the marks when the marks give off different commercial impressions. See Kellogg Co. v.
`
`Pack’em Enterprises, Inc, 951 F.2d 330 (Fed. Cir. 1991).
`
`Moreover, in In re Hearst Corp, 982 F.2d 493 (Fed.Cir.1992), the court reversed a Trademark Trial
`
`and Appeal Board decision that refused registration of VARGA GIRL because there was a likelihood
`
`of confusion with the registered mark VARGAS and stated the following:
`
`

`

`impression of
`The appearance sound and commercial
`VARGA GIRL derive significant contribution from the
`component “girl.” By stressing the portion “varga” and
`diminishing the portion “girl,” the Board inappropriately
`changed the mark. Although the Weight is given to the
`respective Words is not entirely free of subjectivity, we
`believe that
`the Board erred in its diminution of the
`
`contribution Word “girl.” When GIRL is given fair Weight,
`along with VARGA, confusion with VARGAS becomes
`less likely.
`
`Id. at 494. The registered mark and the applicant’s mark were both for calendars; however, the court
`
`held that VARGA GIRL and VARGAS are sufficiently different in sound, appearance, connotation,
`
`and commercial impression to negate likelihood of confusion. Id.
`
`In the present case, the marks give off different commercial impressions. The cited registrations, all
`
`owned by the same company, are for stout beers versus ale that contains “wheat, honey and ginger.”
`
`Thus, use of the aforementioned terms creates a distinct commercial impression.
`
`In keeping with the
`
`Federal Circuit’s holding in Kellogg, the similar phrase “EXPEDITION,” cannot be dispositive since
`
`the marks give off different commercial impressions.
`
`THE CONSUIVIERS INVOLVED WILL MAKE CAREFUL DECISIONS SUFFICENT TO
`AVOID CONFUSION
`
`The next factor is the conditions under which and buyers to whom sales are made (i.e. impulse v.
`
`careful). Id. The average consumer of beer carefully selects the type of beer purchased based on their
`
`preference for ales versus stouts. Stouts are inherently darker with a distinct ability to taste the malt.
`
`Stouts generally have flavors of chocolate and caramel. Further, there is a higher percentage of alcohol
`
`present in stouts which affects the overall taste and stouts contain less carbonation than other varieties
`
`of beer. Whereas ales, are significantly lighter than stouts, and have more of a fruitful taste; a stark
`
`

`

`contrast from chocolate. As a result of the significant differences the consumer will make caref11l
`
`decisions when selecting a beer to purchase. Thus, there is no likelihood of confusion as a result of the
`
`significant differences between Applicant’s applied for mark and the cited registration.
`
`SIMILAR MARKS FOR SIMILAR GOODS/SERVICES CAN BE REGISTERED
`
`Applicant fi.11”1l16I' asserts that the USPTO has found a mark capable of registration, even in cases
`
`where the marks are nearly identical and are covered under the same classification. Furthermore,
`
`courts have long held that the addition of different terms to a common element appreciably reduces the
`
`likelihood of confusion between two marks. See Colgate Palmolive Co. v. Carter-Wallace, Inc., 432
`
`F.2d 1400, 1402, 167 U.S. P. Q. 529, 530 (C.C.P.A. 1970) (PEAK PERIOD not confusing similar to
`
`PEAK); Servo Corp. Am. v. Servo-Tek Prod. Co., 289 F. 2d 955, 981 129 U.S.P.Q. 352, 353 (C.C.P.A.
`
`1961) (SERVOSPEED not confusingly similar to SERVO); Sweats Fashions, Inc. v. Pannill Knitting
`
`Co., 833 F. 2d 1560, 1564, 4 U.S.P.Q. 2d 1793, 1796 (Fed. Cir. 1987) (SWEATS not confusing
`
`similar to ULTRA SWEATS, both for sportswear); Gen. Mills Inc. v. Kellog Co., 824 F. 2d 622, 627,
`
`3 U.S.P.Q. 2d 1442, 1446 (8th Cir. 1987) (OATMEAL RAISIN CRISP not confusingly similar to
`
`APPLE RASIN CRISP, both for breakfast cereal); Consol. Cigar V. RJR Tobacco Co., 491 F.2d 1265,
`
`1267, 181 U.S.P.Q. 44, 45 (C.C.P.A. 1974) (DUTCH APPLE for pipe tobacco not confusingly similar
`
`to DUTCH MASTERS for cigars).
`
`LIKELIHOOD OF CONFUSION IS NOT SUBSTANTIAL
`
`When determining whether an Applicant’s mark creates a likelihood of confusion with marks covered
`
`by cited registrations, "[a] showing of mere possibility of confusion is not enough; a substantial
`
`likelihood that the public will be confilsed must be shown." Omaha Nat’! Bank v. Citibank (South
`
`Dakota), NA, 633 F. Supp. 231, 233 (D. Neb. 1986). For at least the reasons cited above, Applicant
`
`

`

`respectfully asserts that the potential for confusion is not substantial. As such, the 2(d) refusal should
`
`be resolved in favor of the Applicant.
`
`CONCLUSION
`
`Applicant has fully responded to the Office Action. A majority of the DuPont factors weigh in the
`
`Applicant’s favor. Furthermore, for at least the above reasons, Applicant asserts that Applicant’s
`
`mark, AMERICAN EXPEDITION HONEY GINGER WHEAT ALE, is sufficiently distinct from the
`
`cited registrations, so as not to result in consumer confusion. Applicant respectfillly submits in good
`
`faith that all potential 2(d) refusals, rejections, and/or objections have been overcome and that the
`
`applied for mark is in condition for publication.
`
`

`

`

`

`

`

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`Difference Between Ale and Stout
`- Categorized |l!][lE'I'
`'rv,c,d
`e\'snr‘»= i'}e‘*..>:r=:t tic am: .-
`
`Ale vs Stout
`
`There are clifferant Varieties of beer. Among the different
`lnnds of beer. Ale and Stout me most popular‘, Ale. which is
`often described as robust, fruity and hearty. is made frotu
`top ferntetmng yeast. Tout, whicli
`is 1'icl.\lv ilzwored. dark
`and lteaw.
`is made from pale malt. caramel malt and
`unmalled barley.
`Ale is basicallv made from malted
`tlnrougln warm fez-tnentat-ion with the help of yeast.
`Ales are nanuallyln-en-ed at temperatures ranging between :5 to 25 degrees. .-Ls it feremeuts.
`the geasl. rises on to the top. whicli gin-s the Ale a Sl\‘€'€'1
`flawur and taste. .-\le also comains
`bop; that gne it an herbal tlamur.
`Status are also s1'.|'cng when compared to Ale. The alcohol
`l'nlll<e Ale. Stout is a darker
`content in Smut Ls higher than in Ale.
`.\[o1‘eo\c:'. Stouts also came in dark colours. much
`darker than Ales. \'Vhen compared to Stouts. Ales are matured onlyfor a short time.
`The word Stout “as first found in the Egcnon Manuscript, a document that dates back to
`1677. The word Stout was used for strong or stout beers. Ale is a native Engljsl: \\’Ol‘d and has
`been ClElT~'?(l from Old English alu or efflu.
`Both Ale and Stout comes in many \‘t1l'lBElD1'IS. Stouts are flaunured \\lll] dark fruit. chocolate
`or coffee. Some of the Stout var-ities include Baltic potter. dry stout. imperial stout. oatmeal
`stout, oyster stout, chocolate stout and coffee stout. Ale comes in xariations like Brown ale.
`Pale ale. Scotch ales, Wild ales, Burton ales. Old ales and Belgian ales.
`Sununzujr
`
`Both Ale and btout comes In 'ma1"l_V\'a)'Iahm't5. btouts are flavoured \\1tl1 dark iTnIl, Chocolate
`or
`coffee. Some of the Stout xaritjes include Baltic porter, dry stout. itnperial stout, aauneal
`sto
`tn. ogster stout. chocolate stout and coffee stout. Ale comes in variations like Emu-n ale,
`Pale ale, Scotch ales, Mild ales. Burton alu. Old ales and Belgian ales.
`Sumrnary
`1. Ale, which is often d&:crilJe(l as robust, fruity and hearts‘, is made f-mm top fenuenfitig
`yeast. TDEl.\\']1lCl'l is nclmly flaxunred. dark ana iiaaiy. is made fruin pale malt, camaai mi:
`and Ilmnalted barley.
`
`D X 2. Ynlilc-e Ale. Stout is a clarlcer beer.
`
`3. Stone are also strong when compared to
`Ale.
`4. The alcohol content in Stout is higher than
`in Ale.
`
`7tz.._t._;,c9 .
`.. , (:’[_fl;Ll_L
`. 5 r c L
`EL‘
`2
`
`5. Stems come in dark colours. much darker
`‘ than Ales. When compared to Stouts, Ales are
`matured onlyfor a short time.
`6. Stout is non-ually used for strung or smut
`beers. The word Stout was first found in the Egertml Manuscript. a docurnent that dates back
`to 1517. ana is a naaxa English \\’ol'(l and has lneen deriveci from Old English alu or aaln.
`7. Both Ale and Stout comes in many xai-iatiuns.
`
`Respectfully submitted,
`/Keisha M. Hardley/
`Keisha M. Hardley (MD Bar)
`Associate Attorney of Record for the Applicant
`
`