97772966•Silver & Silver, P.A.
Gesamter Gesetzestext
This Opinion is Not a Precedent of the TTAB Mailed: September 11, 2026 UNITED STATES PATENT AND TRADEMARK OFFICE _____ Trademark Trial and Appeal Board _____ In re Silver & Silver, P.A. _____ Serial No. 97772966 _____ David P. Lhota of Lhota & Associates, P.A. for Silver & Silver, P.A. Jared M. Mason, Trademark Examining Attorney, Law Office 119, Brett Golden, Managing Attorney. _____ Before Heasley, Larkin, and English, Administrative Trademark Judges. Opinion by Larkin, Administrative Trademark Judge: Some attorneys are known for being silver-tongued. This case involves attorneys who are known for being “Silver.” The attorneys at Silver & Silver, P.A. (“Applicant”), seek registration on the Principal Register of the mark shown below
Serial No. 97772966 - 2 - for “Providing legal services in the field of personal injury, car accidents, motorcycle accidents, truck accidents, wrongful death, bicycle accidents, boating accidents, criminal defense, DUI, injuries to children, dog bites, premises liability, slip and fall, workplace accidents, medical malpractice, catastrophic injuries, product liability” in International Class 45.1 The Trademark Examining Attorney has refused registration of Applicant’s mark under Section 2(d) of the Trademark Act, 15 U.S.C. § 1052(d), on the ground that it so resembles the standard-character mark SILVER LAW GROUP, registered by other attorneys on the Principal Register for “legal services” in International Class 45,2 as to be likely to cause confusion when used in connection with the services identified in the application. When the Examining Attorney made the refusal final, Applicant appealed and simultaneously requested reconsideration, which was denied. The appeal is fully briefed.3 We affirm the refusal to register. 1 Application Serial No. 97772966 was filed on January 30, 2023 under Section 1(b) of the Trademark Act, 15 U.S.C. § 1051(b), based on Applicant’s allegation of a bona fide intention to use the mark in commerce. Applicant describes its mark as follows: “The mark consists of the scales of justice in white in a red box and the white stylized wording ‘SILVER INJURY LAW’ over a white line and the smaller stylized wording ‘WWW.SILVERINJURYLAW.COM’ in white letters which are in a white outlined box over a black background.” The colors red, black, and white are claimed as features of the mark. Applicant has disclaimed the exclusive right to use INJURY LAW WWW.SILVERINJURYLAW.COM apart from the mark as shown. 2 The cited Registration No. 4364147 (the “’147 Registration”) issued on July 9, 2013 and has been renewed. The registrant has disclaimed the exclusive right to use LAW GROUP apart from the mark as shown. 3 Citations in this opinion to the briefs refer to TTABVUE, the Board’s online docketing system. The number preceding TTABVUE corresponds to the docket entry number, and any numbers following TTABVUE refer to the page(s) of the docket entry where the cited
Serial No. 97772966 - 3 - I. Prosecution History and Record on Appeal4 We briefly summarize below the prosecution history of the application because it provides useful background to our disposition of the appeal. In the first Office Action, the Examining Attorney refused registration of Applicant’s mark based on the ’147 Registration,5 and required Applicant to submit an amended drawing and an amended description of the mark, and to disclaim INJURY LAW WWW.SILVERINJURYLAW.COM.6 The Examining Attorney made of record USPTO records regarding the ’147 Registration,7 dictionary definitions of materials appear. Applicant’s appeal brief appears at 8 TTABVUE and its reply brief appears at 11 TTABVUE. The Examining Attorney’s brief appears at 10 TTABVUE. Trademark Rule 2.142(b)(2) provides that a reply brief “shall not exceed ten pages in length in its entirety.” 37 C.F.R. § 2.142(b)(2). Applicant’s reply brief totals 50 pages, almost all of which are taken up by two exhibits consisting of materials from the prosecution history of the application. The Board strongly discourages attaching any materials to briefs, including materials from the record, see, e.g., In re Michalko, No. 85584271, 2014 WL2531202, at *1 (TTAB 2014), and it was unnecessary for Applicant to have done so here. We will consider only the six pages of text in Applicant’s reply brief. 4 Citations in this opinion to the application record are to pages in the downloadable .pdf version of the Trademark Status & Document Retrieval (“TSDR”) database of the United States Patent and Trademark Office (“USPTO”). 5 The Examining Attorney inaccurately states in his brief that Applicant originally filed to register its mark “for ‘legal services’ in International Class 045.” 10 TTABVUE 1-2. Applicant sought registration of its mark for the specific legal services listed above from the outset, January 30, 2023 Application at 4, and the Examining Attorney acknowledged this in the first Office Action. October 4, 2023 Office Action at 2 (stating that Applicant was seeking to register its mark “for ‘Providing legal services in the field of personal injury, car accidents, motorcycle accidents, truck accidents, wrongful death, bicycle accidents, boating accidents, criminal defense, DUI, injuries to children, dog bites, premises liability, slip and fall, workplace accidents, medical malpractice, catastrophic injuries, product liability’ in International Class 045.”). Applicant did not “voluntarily amend[ ] its identification,” 10 TTABVUE 2, in its response to the first Office Action. 6 October 24, 2023 Office Action at 1-5. 7 Id. at 7-8.
Serial No. 97772966 - 4 - the words “injury,” “law,” and “legal,”8 and pages from Applicant’s website at silverinjurylaw.com.9 Applicant responded to the Office Action by submitting an amended drawing, entering the required disclaimer, and arguing against the refusal to register.10 Applicant embedded in its response a design that it described as reflecting the “unique design and look” of the cited mark as it appears on the registrant’s website,11 and what appear to be active hyperlinks to its website and the registrant’s website.12 The Examining Attorney then issued an Office Action accepting the amended drawing, mark description, and disclaimer, but making final the refusal to register based on the ’147 Registration.13 The application then became abandoned, but Applicant subsequently petitioned to revive it, arguing that Applicant’s counsel did not receive the Final Office Action prior to the expiration of the response period.14 The Examining Attorney issued a Subsequent Final Office Action allowing Applicant to respond to the original Final Office Action or file an appeal within three months.15 8 Id. at 9-15. 9 Id. at 16-27. 10 January 24, 2024 Response to Office Action at 8, 10-17. 11 Id. at 14. 12 Id. at 10. The Board has “made clear that providing hyperlinks to internet materials is insufficient to make such materials of record.” In re Weiss, No. 88621608, 2024 WL 3617597, at *2 (TTAB 2024) (citations omitted). 13 February 16, 2024 Final Office Action at 1-6. 14 August 5, 2024 Petition to Revive Abandoned Application at 2. 15 May 14, 2025 Subsequent Final Office Action at 1-2.
Serial No. 97772966 - 5 - After obtaining an extension of time to respond to the Subsequent Final Office Action, Applicant appealed and simultaneously requested reconsideration. In its Request for Reconsideration, Applicant argued against the final refusal and made of record a screenshot from the registrant’s website.16 The Examining Attorney denied Applicant’s Request for Reconsideration,17 and the appeal was resumed and is now ready for decision. II. Evidentiary Issue Before we discuss the merits of the appeal, we must address an evidentiary objection by the Examining Attorney. Applicant attached as Exhibits A and B to its appeal brief seven screenshots from its website and nine screenshots from the registrant’s website, 8 TTABVUE 18-26, and the Examining Attorney states that “the vast majority of [them] were never attached to any filing in the record.” 10 TTABVUE 2. He argues that “this new evidence was untimely submitted for the first time during the appeal,” and he “objects to the evidence not previously made of record and requests that the Board disregard it.” Id.18 Applicant responds in its reply brief that it “specifically identified and referenced the relevant websites and marketplace usage during prosecution of the application, including in connection with the Request for Reconsideration and Appeal Brief,” 11 16 November 14, 2025 Request for Reconsideration at 8. 17 December 5, 2025 Denial of Request for Reconsideration at 1-3. 18 The Examining Attorney did not specify exactly which materials are in the record and which are not, but we do not consider attachments to briefs unless they involve a request for judicial notice. We otherwise consider only what is in the prosecution history.
Serial No. 97772966 - 6 - TTABVUE 4, and that “[t]he domain names for the referenced websites, including Applicant’s own website and the Registrant’s website, were provided in the Response to the Non-Final Office Action demonstrating the actual nature of the parties’ respective legal services and marketplace presentation and making them of record.” Id.19 According to Applicant, [t]he Examining Attorney cannot reasonably claim surprise or prejudice from these materials. Indeed, the Examining Attorney was fully aware that the cited registration was being relied upon as the basis for refusal and therefore could have easily reviewed the Registrant’s publicly available website and specimens of use at any time during prosecution. The Examining Attorney himself repeatedly relied upon the cited registration for “legal services” as the basis for refusal and therefore had both the ability and obligation to evaluate the real-world marketplace context of the cited mark. Id. at 3-4.20 Applicant concludes that the referenced websites merely confirm facts already discussed throughout prosecution — namely, that Applicant exclusively provides personal injury-related legal services while Registrant operates in the entirely different field of securities, investment, and financial fraud 19 As noted above, Applicant unnecessarily attached the Office Action and Applicant’s response to its reply brief, causing the reply brief to far exceed the permissible length of ten pages in its entirety. 20 Although this section of our opinion addresses the Examining Attorney’s evidentiary objection, we are compelled to address Applicant’s argument that the Examining Attorney had an “obligation to evaluate the real-world marketplace context of the cited mark,” 11 TTABVUE 3-4, by visiting the registrant’s website. As discussed below, Applicant relies almost exclusively on the real-world uses of the respective marks, which are irrelevant to the issue of the registrability of Applicant’s mark. Examining attorneys have no “obligation to evaluate the real-world marketplace context of the cited mark” (or, for that matter, the applicant’s mark), at least where, as here, the involved goods or services are legally identical and the drawings of the involved marks do not contain extrinsic matter that appears on websites.
Serial No. 97772966 - 7 - litigation and arbitration. The exhibits are therefore corroborative and explanatory of arguments already before the Board rather than improper new evidence. Id. at 4. As discussed above, during prosecution, the Examining Attorney made of record several screenshots from Applicant’s website,21 and Applicant made of record one screenshot from the registrant’s website.22 The exhibits to Applicant’s brief do not contain any of the screenshots from Applicant’s website that are in the record, and they contain screenshots from the registrant’s website in addition to the single one that is in the record. “The record in an application should be complete prior to the filing of an appeal,” In re Jimenez, No. 97551823, 2025 WL 3126703, at *2 (TTAB 2025) (citing Trademark Rule 2.142(d), 37 C.F.R. § 2.142(d)), and “Applicant should not have attached ‘new evidence’ to [its] brief to the Board.” In re Ralphs Famous Italian Ices Franchise Corp., No. 90302728, 2026 WL 1920835, at *9 (TTAB 2026). We sustain the Examining Attorney’s objection to the screenshots attached to Applicant’s appeal brief at 8 TTABVUE 18-21 and 23-26, and have given them no consideration in our decision.23 21 October 24, 2023 Office Action at 16-27. 22 November 14, 2025 Request for Reconsideration at 4. 23 If Applicant wished to make the additional screenshots of record, the proper course was to “submit a request to the Board to suspend the appeal and to remand the application for further examination.” Weiss, 2024 WL 3617597, at *2 (quoting Trademark Rule 2.142(b)). Applicant did not do so.
Serial No. 97772966 - 8 - III. Analysis of Likelihood of Confusion Refusal “The Trademark Act prohibits registration of a mark that so resembles a registered mark as to be likely, when used on or in connection with the goods or services of the applicant, to cause confusion [or] mistake, or to deceive.” In re Charger Ventures LLC, 64 F.4th 1375, 1379 (Fed. Cir. 2023) (cleaned up). Our determination of likelihood of confusion under Section 2(d) of the Trademark Act is based on an analysis of all probative facts in the record that are relevant to the factors set forth in In re E.I. DuPont DeNemours & Co., 476 F.2d 1357, 1361 (CCPA 1973) (“DuPont”). Charger Ventures, 64 F.4th at 1379. We consider each DuPont factor for which there is evidence and argument. See, e.g., In re Guild Mortg. Co., 912 F.3d 1376, 1379 (Fed. Cir. 2019). “Two key factors in every Section 2(d) case are the first two factors regarding the similarity or dissimilarity of the marks and the goods or services, because the fundamental inquiry mandated by § 2(d) goes to the cumulative effect of differences in the essential characteristics of the goods and differences in the marks.” DC Comics v. Cellular Nerd LLC, No. 91246950, 2022 WL 17832492, at *10 (TTAB 2022) (internal quotations and quotation marks omitted). Applicant focuses on the first two key DuPont factors, and the third factor, the “similarity or dissimilarity of established, likely-to-continue trade channels.” DuPont, 476 F.2d at 1361. As Applicant puts it, “application of the most relevant du Pont factors demonstrates that there is no likelihood of confusion between the Applicant’s Mark and the Cited Registration because [of] (A) the dissimilarity of the Applicant’s
Serial No. 97772966 - 9 - Mark and the Cited Registration in their entireties as to appearance, sounds, connotation and commercial impression; (B) the dissimilarity of the legal services (personal injury vs securities and investment fraud) and (C) the dissimilarity of trade channels (victims of personal injury and financial fraud are simply not looking for the same type of law firms).” 8 TTABVUE 10. Applicant also obliquely invokes the fourth DuPont factor, the “conditions under which and buyers to whom sales are made, i. e. ‘impulse’ vs. careful, sophisticated purchasing,” DuPont, 476 F.2d at 1361. 8 TTABVUE 15-16. A. Similarity or Dissimilarity of the Services, Channels of Trade, and Classes of Consumers We begin with the second and third DuPont factors. The second factor “considers ‘[t]he similarity or dissimilarity and nature of the goods or services as described in an application or registration . . . .” In re Detroit Athletic Co., 903 F.3d 1297, 1306 (Fed. Cir. 2018). “This factor considers whether ‘the consuming public may perceive [the goods or services] as related enough to cause confusion about the source or origin of the goods or services.’” In re St. Helena Hosp., 774 F.3d 747, 752 (Fed. Cir. 2014) (quoting Hewlett-Packard Co. v. Packard Press, Inc., 281 F.3d 1261, 1267 (Fed. Cir. 2002)). “In analyzing the services, the Board considers ‘[t]he similarity or dissimilarity and nature of the services as described in an application or registration.’” In re OSF Healthcare Sys., No. 88706809, 2023 WL 6140427, at *4 (TTAB 2023) (quoting In re Embiid, No. 88202890, 2021 WL 2285576, at *10 (TTAB 2021)).
Serial No. 97772966 - 10 - The relatedness of goods or services may be established based on, inter alia, (1) the language of the involved identifications of goods or services, which may show, on the face of the identifications, that the goods or services are literally or legally identical, or are otherwise intrinsically related, and (2) evidence of third-party uses or registrations, which may show that the identified goods or services are commonly offered by the same entity under the same mark. See, e.g., OSF Healthcare, 2023 WL 6140427, at *4. The involved identifications suffice here to show relatedness. The services identified in the cited ’147 Registration are “legal services.” The services identified in the application are “Providing legal services in the field of personal injury, car accidents, motorcycle accidents, truck accidents, wrongful death, bicycle accidents, boating accidents, criminal defense, DUI, injuries to children, dog bites, premises liability, slip and fall, workplace accidents, medical malpractice, catastrophic injuries, product liability.” Applicant argues in its appeal brief that the “legal services offered under Applicant’s Mark are strictly for personal injury including wrongful death and product liability,” while extrinsic evidence shows that “the Cited Registration is registered in connection with ‘legal services’ but [they] are limited to securities, investment and financial fraud arbitration and litigation legal matters as shown in Exhibit B [to Applicant’s appeal brief], the specimens of use filed by registrant in the U.S. Trademark Office and advertisement on the Cited Registration website.” 8 TTABVUE 14 (emphasis in bold here in italics in Applicant’s brief). According to Applicant, “[a] review of their respective websites shown at Exhibit A and Exhibit
Serial No. 97772966 - 11 - B [to Applicant’s appeal brief] instantly eliminates, avoids or obviates any likelihood of confusion or potential for likelihood of confusion.” Id. (emphasis in bold here in italics in Applicant’s brief). The Examining Attorney responds that the registration uses broad wording to describe “legal services”, which presumably encompasses all services of the type described, including applicant’s more narrow “providing legal services in the field of personal injury, car accidents, motorcycle accidents, truck accidents, wrongful death, bicycle accidents, boating accidents, criminal defense, DUI, injuries to children, dog bites, premises liability, slip and fall, workplace accidents, medical malpractice, catastrophic injuries, product liability”. 10 TTABVUE 7-8 (citations omitted). The Examining Attorney concludes that “applicant’s and registrant’s services are legally identical,” id. at 8 (citations omitted), because they are no “restrictions here on the face of the registration [and] registrant’s services are presumed to include all reasonably possible fields of legal services, including those of applicant.” Id. In its reply brief, Applicant claims that the Examining Attorney improperly disregards marketplace realities, and that “likelihood of confusion must be evaluated from the standpoint of actual consumers in the marketplace under the relevant DuPont factors.” 11 TTABVUE 5. Applicant “submits that [the Examining Attorney’s] analysis ignores practical marketplace distinctions highly relevant under DuPont.” Id. at 6. Applicant reiterates that it “exclusively provides personal injury and accident-related legal services” while “Registrant, by contrast, focuses on securities, investment, and financial fraud matters as reflected by its own website and specimens of use.” Id. at 6-7.
Serial No. 97772966 - 12 - In comparing the services, “we must construe the services identified in the cited [’147] [R]egistration as broadly as reasonably possible ‘to include all [services] of the nature and type described therein,’” OSF Healthcare, 2023 WL 6140427, at *5 (quoting In re Solid State Design Inc., No. 87269041, 2018 WL 287909, at *6 (TTAB 2018) (internal quotation omitted)), and “we must resolve any ambiguities regarding their coverage in favor of the cited registrant ‘given the presumptions afforded the [’147] [R]egistration under Section 7(b)’ of the Trademark Act.” Id. (quoting In re C.H. Hanson Co., No. 77983232, 2015 WL 6121759, at *5 (TTAB 2015) (citing 15 U.S.C. § 1057(b)). We must give “‘full sweep’ to an identification of goods or services regardless of [the] registrant’s actual business,” Advance Mag. Publishers, Inc. v. Fashion Elecs., Inc., No. 91247034, 2023 WL 4261426, at *15 (TTAB 2023) (quoting Paula Payne Prods. Co. v. Johnson Publ’g Co., 473 F.2d 901, 902 (CCPA 1973)), and “we may consider . . . restrictions [regarding the actual services] only if they are included in the identification of goods or services.” In re FCA US, LLC, No. 85650654, 2018 WL 1756431, at *4 n.18 (TTAB 2018), aff’d, 778 F. App’x 962 (Fed. Cir. 2019). As the Board noted in FCA US, “[i]n innumerable cases, the Board hears arguments about how the parties’ actual goods, services, customers, trade channels, and conditions of sale are narrower or different from the goods and services identified in the applications and registrations,” but “as stated in equally innumerable decisions of our primary reviewing court, we may consider any such restrictions only if they are included in the identification of goods or services.” Embiid, 2021 WL 2285576, at *14 n.38 (quoting FCA US, 2018 WL 1756431, at *4 n.18) (emphasis in bold here in italics in Embiid). Under these “innumerable decisions,” “[o]ur decision . . . must be based on the identification of [services] in the
Serial No. 97772966 - 13 - [’147] Registration and subject Application, as that determines the scope of the benefit of registration.” Sock It To Me, Inc. v. Fan, No. 91230554, 2020 WL 3027605, at *10 (TTAB 2020). The “legal services” broadly recited in the cited ’147 Registration are not restricted to any specific type of legal services such as the “securities, investment and financial fraud arbitration and litigation legal matters” referred to by Applicant, 8 TTABVUE 14, and we cannot “import restrictions into the identification . . . based on alleged real world conditions.” In re i.am.symbolic, llc, 866 F.3d 1315, 1327 (Fed. Cir. 2017) (citing Stone Lion Cap. Partners, L.P. v. Lion Cap. LLP, 746 F.3d 1317, 1323 (Fed. Cir. 2012)). We must deem the broadly identified “legal services” in the cited ’147 Registration to encompass the narrower “legal services in the field of personal injury, car accidents, motorcycle accidents, truck accidents, wrongful death, bicycle accidents, boating accidents, criminal defense, DUI, injuries to children, dog bites, premises liability, slip and fall, workplace accidents, medical malpractice, catastrophic injuries, product liability” identified in the application. As a result, the services are legally identical,24 and the second DuPont factor strongly supports a conclusion that confusion is likely. OSF Healthcare, 2023 WL 6140427, at *9. 24 Applicant was not without remedies against the breadth of the identification of “legal services” in the cited ’147 Registration. Applicant “ha[d] the option of seeking a consent from the owner of the [’147] [R]egistration, or seeking a restriction of the registration under Section 18 of the Trademark Act, 15 U.S.C. § 1068, which permits the Board in an inter partes proceeding to cancel registrations in whole or in part, or to otherwise restrict or rectify . . . the registration of a registered mark.” Solid State Design, 2018 WL 287909, at *1 (internal quotation and quotation marks omitted). There is no evidence that Applicant pursued either option.
Serial No. 97772966 - 14 - The third DuPont factor “considers ‘[t]he similarity or dissimilarity of established, likely-to-continue trade channels.’” Detroit Athletic Co., 903 F.3d at 1308 (quoting DuPont, 476 F.2d at 1361). As with the second DuPont factor, the third factor must be evaluated based on the identifications of services in the cited ’147 Registration and the application, not on the actual use of the marks. Stone Lion, 746 F.3d at 1323. As a result, Applicant’s argument that the trade channels are dissimilar because “victims of personal injury and financial fraud are simply not looking for the same type of law firms,” 8 TTABVUE 10, is unpersuasive. “Because the services described in the application and the [’147] [R]egistration are legally identical . . . we must presume that the channels of trade and classes of purchasers are the same as to those . . . identical services.” OSF Healthcare, 2023 WL 6140427, at *9 (quoting Monster Energy Co. v. Lo, No. 91225050, 2023 WL 417620, at *8 (TTAB 2023) (citing In re Viterra Inc., 671 F.3d 1358, 1362 (Fed. Cir. 2012)). We are entitled to “rely on this legal presumption in determining likelihood of confusion.” Viterra, 671 F.3d at 1362. The third DuPont factor thus also strongly supports a conclusion that confusion is likely. OSF Healthcare, 2023 WL 6140427, at *9. B. Similarity or Dissimilarity of the Marks Under the first DuPont factor, “we consider the ‘similarity or dissimilarity of the marks in their entireties as to appearance, sound, connotation and commercial impression.’” In re Ye Mystic Krewe of Gasparilla, No. 90522364, 2025 WL 2953731, at *4 (TTAB 2025) (quoting DuPont, 476 F.2d at 1361). “Similarity in any one of these elements may be sufficient to find the marks confusingly similar.” Sage Therapeutics,
Serial No. 97772966 - 15 - Inc. v. Sageforth Psych. Servs., LLC, No. 91270181, 2024 WL 1638376, at *5 (TTAB 2024) (quoting In re Inn at St. John’s, LLC, No. 87075988, 2018 WL 2734893, at *5 (TTAB 2018) (citation omitted), aff’d per curiam, 777 F. App’x 516 (Fed. Cir. 2019)); accord Krim-Ko Corp. v. Coca-Cola Bottling Co., 390 F.2d 728, 732 (CCPA 1968) (“It is sufficient if the similarity in either form, spelling or sound alone is likely to cause confusion.”) (citation omitted). “The proper test is not a side-by-side comparison of the marks, but instead whether the marks are sufficiently similar in terms of their commercial impression such that persons who encounter the marks would be likely to assume a connection between the parties.” Sage Therapeutics, 2024 WL 1638376, at *5 (quoting Coach Servs., Inc. v. Triumph Learning LLC, 668 F.3d 1356, 1368 (Fed. Cir. 2012)). “The focus is on the recollection of the average purchaser, who normally ‘retains a general rather than a specific impression of marks.’” Id. (quoting In re i.am.symbolic, llc, No. 85916778, 2018 WL 3993582, at *4 (TTAB 2018) (citations omitted)). “[S]imilarity is not a binary factor, but is a matter of degree.” St. Helena Hosp., 774 F.3d at 752 (quoting In re Coors Brewing Co., 343 F.3d 1340, 1344 (Fed. Cir. 2003)). Where, as here, the involved services are legally identical, a lesser degree of similarity between the marks is required for confusion to be likely. Century 21 Real Estate Corp. v. Century Life of Am., 970 F.2d 874, 877 (Fed. Cir. 1992) (“When marks would appear on virtually identical goods or services, the degree of similarity necessary to support a conclusion of likely confusion declines.”).
Serial No. 97772966 - 16 - The involved marks are SILVER LAW GROUP in standard characters and Applicant’s composite mark, show again below: Applicant argues that its mark “differs in appearance, sound, connotation and commercial impression when compared to the Cited Registration and is used in connection with completely different and unrelated legal services such that they do not reach out to or attract the same or same type of potential clients.” 8 TTABVUE 10. According to Applicant, [t]he appearance, sound, sight, and commercial impression of Applicant’s Mark, when viewed in its entirety (giving fair weight to the significant contributions of its component parts), are dissimilar in appearance, sight, and commercial impression when compared to the Cited Registration. The mere fact that the marks share the common words “SILVER” and “LAW” does not automatically result in a likelihood of confusion, as the marks must be viewed in their entiret[ies]. While Applicant’s mark includes the words “SILVER” and “LAW” it also includes the term “INJURY” between “Silver” and “Law” as well as the domain name www.SilverInjuryLaw.com and does not include the term “GROUP”. The most relevant and operative difference in the marks is the term “INJURY” in Applicant’s Mark wherein anyone looking for a law firm or attorney for a securities or fraud litigation or arbitration matter would intuitively if not instantly know that Applicant does not provide these financial related legal services and therefore would not think or be confused that Applicant’s law firm is related to or affiliated with the Cited Registration or Silver Law Group. Id. at 11-12.
Serial No. 97772966 - 17 - Applicant notes that its mark “comprises a design mark” featuring “the scales of justice in white in a red box and the words SILVER INJURY LAW in white over a white line and www.SilverInjuryLaw.com in white letters below the white line which are in a white outlined box over a black background.” Id. at 13. Applicant argues that its design mark “has a distinct look and feel which identifies and differentiates if [sic] from other law firms, including the Cited Registration,” and that the mark shown in the ’147 Registration “has its own unique design and look, apart from the words,” based on a page from the registrant’s website. Id. The Examining Attorney responds that “the marks are highly similar in look, sound and commercial impression inasmuch as they both contain ‘SILVER’ and ‘LAW’,” and that “the minute differences of applicant’s website address and applicant’s ‘INJURY’ and registrant’s ‘GROUP’ are insufficient to overcome the otherwise existing similarities between the marks.” 10 TTABVUE 4. According to the Examining Attorney, [t]he overarching point here is that even looking at the marks in their entireties, given registrant’s unrestricted legal services on the face of the registration, consumers with a general recollection of marks seeking out the services would be likely to confuse one “Silver . . . Law” for another. This is especially true since the dominant term SILVER is identical in each mark and consumers will call on that dominant term to seek out applicant or registrant. It would also be reasonable for them to conclude that “SILVER INJURY LAW” is part of or affiliated with the “SILVER LAW GROUP,” but merely the division or office that deals in legal services for “INJURY LAW.” Id. at 5-6. The Examining Attorney argues that the words in Applicant’s mark are more significant than the design elements, id. at 6, and that the registrant’s
Serial No. 97772966 - 18 - standard-character mark could be styled in the same manner as the words in Applicant’s composite mark. Id. at 6-7. In its reply brief, Applicant argues that the word “INJURY” in its mark “is the dominant distinguishing term because it immediately informs consumers that Applicant specializes in personal injury representation,” and that the “Examining Attorney’s theory would effectively grant Registrant exclusive rights to the surname ‘Silver’ combined with the descriptive term ‘Law’ across all legal services regardless of practice area, which exceeds the proper scope of protection for such wording.” 11 TTABVUE 6. Marks must be considered in their entireties, but “in articulating reasons for reaching a conclusion on the issue of confusion, there is nothing improper in stating that, for rational reasons, more or less weight has been given to a particular feature of a mark, provided the ultimate conclusion rests on consideration of the marks in their entireties.” Detroit Athletic Co., 903 F.3d at 1305 (quoting In re Nat’l Data Corp., 753 F.2d 1056, 1058 (Fed. Cir. 1985)). As noted above, the Examining Attorney argues that SILVER is the dominant portion of both marks, while Applicant argues that the word INJURY in its mark “is the dominant distinguishing term” in its mark because it identifies Applicant’s practice specialty. 11 TTABVUE 6. We agree with the Examining Attorney. In the cited standard-character mark SILVER LAW GROUP, the word SILVER is the first word in the mark and the words LAW GROUP that follow SILVER have no source-identifying significance and have been disclaimed because they merely describe the form of the provider of the
Serial No. 97772966 - 19 - identified “legal services.” See Miller v. Miller, No. 91184841, 2013 WL 2329829, at *9 (TTAB 2013) (finding that “‘LAW GROUP’ is a generic designation for a law firm.”). The “non-source identifying nature of [LAW GROUP] and the disclaimer[ ] thereof constitute rational reasons for giving those [words] less weight in the analysis.” Detroit Athletic Co., 903 F.3d at 1305. We find that the lead word SILVER is the dominant portion of the cited mark. With respect to Applicant’s mark, “[w]hen a mark comprises both words and a design, the words are normally accorded greater weight because they are more likely to be impressed upon a purchaser’s memory and would typically be used by purchasers to request the goods or services.” Iron Balls Int’l Ltd. v. Bull Creek Brewing, LLC, No. 92079099, 2024 WL 2844425, at *12 (TTAB 2024) (citing Viterra, 671 F.3d at 1362). This general principle applies here because the only significant design element in Applicant mark is the “scales of justice in white in a red box,”25 which are a ubiquitous symbol of the United States legal system in which attorneys provide legal services. Cf. Major League Baseball Players Ass’n v. Chisena, No. 91240180, 2023 WL 2986321, at *4 (TTAB 2023) (in a case involving New York Yankees star Aaron Judge, the applicant explained that his mark, which included the scales of justice and a gavel superimposed on a baseball field, connoted that “baseball is governed by rules and umpires similar to a courtroom proceeding is governed by laws and judges”) (internal quotation and quotation marks omitted), aff’d, 2026 WL 25 The concentric rectangular designs in Applicant’s mark are “nothing more than . . . non- descript ‘carrier[s]’ for the words and design.” Sabhnani v. Mirage Brands, LLC, No. 92068086, 2021 WL 6072822, at *16 (TTAB 2021) (citations omitted).
Serial No. 97772966 - 20 - 60319 (Fed. Cir. Jan. 8, 2026). The scales of justice have no source-identifying significance in the context of legal services, and would not be used by consumers to request or refer to the services. With the exception of the word SILVER, all the wording in Applicant’s mark has been disclaimed. In view of the disclaimers, the lead word SILVER serves as the primary identifier of the source of Applicant’s services, and we find that it is the dominant portion of Applicant’s mark. The fact that the lead word SILVER dominates both marks is significant because “consumers typically notice [lead] words first” and they “are likely to make the greatest impression on consumers.” Detroit Athletic Co., 903 F.3d at 1303 (citations omitted). We turn now to the required comparison of the marks in their entireties, in which we will give the shared lead word SILVER greater weight than the other elements of the marks. With respect to appearance, because the cited mark SILVER LAW GROUP is a standard-character mark, “we must consider that the literal elements of the mark (the words and the letters) may be presented in any font style, size or color, including the same font, size and color as the literal portions of Applicant’s mark.” In re Aquitaine Wine USA, LLC, No. 86928469, 2018 WL 1620989, at *5 (TTAB 2018). “This is because the rights associated with a standard character mark reside in the wording per se and not in any particular font style, size, or color.” Id. (citing Citigroup Inc. v. Cap. City Grp. Inc., 637 F.3d 1344, 1353 (Fed. Cir. 2011) (“the registrant is
Serial No. 97772966 - 21 - entitled to depictions of the standard character mark regardless of font style, size, or color, not merely ‘reasonable manners’ of depicting its standard character mark.”)). Accordingly, we must assume that the registrant could display its mark in the same font style, size, and color in which the words SILVER INJURY GROUP are displayed in Applicant’s mark.26 From the standpoint of a consumer with a general rather than specific mind’s eye recollection of the cited SILVER LAW GROUP mark in that depiction, who separately encounters Applicant’s mark for legally-identical services, the marks are very similar in appearance because their literal elements begin with the word SILVER followed by non-source-identifying words that describe the form of the provider or the field of the services. But even if the comparison is between Applicant’s composite mark and the cited mark in block letters or another font or stylization, the marks are visually similar because their literal elements begin with the identical word SILVER. Detroit Athletic Co., 903 F.3d at 1303. The second literal elements of the marks, INJURY LAW and LAW GROUP, respectively, “are different, and some consumers may notice and recall the differences,” but the literal elements of the marks “share the same structure, starting with the dominant [SILVER] element and then add[ing]” wording “to create 26 As discussed above, Applicant cites the registrant’s actual use of its standard-character mark in a stylized format in arguing that the marks are dissimilar visually. 8 TTABVUE 13. Because the registrant’s rights in its standard-character mark “reside in the wording per se and not in any particular font style, size, or color,” Aquitaine Wine, 2018 WL 1620989, at *5, Applicant cannot rely on the registrant’s current depiction of its standard-character mark, “which could change at any time.” Cielo e Terra, S.p.A. v. Hoteles y Viñedos del Valle de Guadalupe S.A. de C.V., No. 91287216, 2026 WL 2624328, at *23 n.40 (TTAB 2026) (citing Look Cycle Int’l v. Kunshan Qiyue Outdoor Sports Goods Co., No. 92079409, 2024 WL 3739358, at *9 (TTAB 2024) (citing Citigroup, 637 F.3d at 1353)).
Serial No. 97772966 - 22 - a [SILVER-]formative mark.” Sage Therapeutics, 2024 WL 1638376, at *6. “This structure results in marks that look like variations on a [SILVER] theme. This is important because consumers familiar with the [SILVER LAW GROUP] mark and the services provided under that mark may view [Applicant’s SILVER-dominated] mark as an extension of the [SILVER LAW GROUP] mark or as an affiliated branch of the business that provides services under [Applicant’s SILVER-dominated] mark.” Id. “The common [‘SILVER’] element of the marks anchors them in a way to the same theme and creates a risk that consumers will mistakenly assume connections between the [legally-identical] services provided under the marks. This type of similarity increases the likelihood of confusion.” Id. We find that the marks are similar in appearance. The marks have some differences in sound if they are verbalized as “SILVER LAW GROUP” and “SILVER INJURY LAW,”27 but those differences are far outweighed by the fact that “the first and dominant [SILVER] element of each mark will sound identical.” Id. “The risk here is that consumers will believe that [Applicant and the registrant] are connected because of their shared use of the word [SILVER], featured so prominently in their marks used for [legally-identical] services.” Id. We find that the marks are quite similar in sound. 27 We find it very unlikely that when consumers verbalize Applicant’s mark, they would include Applicant’s lengthy website address www.silverinjurylaw.com, particularly because the “Board has acknowledged the ‘penchant of consumers to shorten marks.’” Cielo e Terra, 2026 WL 2624328, at *25 (quoting Iron Balls, 2024 WL 2844425, at *25 (internal quotation omitted)). If consumers verbalized the respective marks simply as “Silver,” engaging in a practice that is common when the names of law firms are spoken, the marks would be identical in sound.
Serial No. 97772966 - 23 - Finally, with respect to meaning, both marks are dominated by the word SILVER, which in the context of legal services would most likely be viewed as the surname of one or more attorneys in the respective law firms providing the services.28 We find that the marks are quite similar in connotation and commercial impression because they are both likely to identify attorneys named Silver as the providers of the identified legal services. The marks are similar in appearance, and quite similar in sound and connotation and commercial impression. The first DuPont factor strongly supports a conclusion that confusion is likely. Naterra, Inc. v. Bensalem, 92 F.4th 1113, 1119 (Fed. Cir. 2024). C. Fourth DuPont Factor The fourth DuPont factor considers the “conditions under which and buyers to whom sales are made, i. e., ‘impulse’ vs. careful, sophisticated purchasing.” DuPont, 476 F.2d at 1361. Applicant argues that “consumers looking for legal representation exercise a high level or degree of care, investigation and consideration when selecting a law firm or lawyer.” 8 TTABVUE 15.29 Applicant further argues that “[a]nyone 28 Pages from Applicant’s website made of record by the Examining Attorney identify Bruce Silver as one of the attorneys in Applicant’s Professional Association. October 24, 2023 Office Action at 22-23. The ’147 Registration’s last listed owner is Scott L. Silver, P.A., id. at 7, and the screenshot from the registrant’s website made of record by Applicant identifies Scott Silver as a member of the firm. November 14, 2025 Request for Reconsideration at 8. 29 Applicant cites Elizabeth Taylor Cosmetics Co. v. Annick Goutal, S.A.R.L., 673 F. Supp. 1238, 1247 (S.D.N.Y. 1987), for the proposition that “it has been acknowledged and [is] indisputable that people looking to hire and retain a law firm exercise a much higher degree of care and investigation than consumers of ordinary products and services.” 8 TTABVUE 15-16. The Elizabeth Taylor Cosmetics case involved perfume consumers, not purchasers of legal services.
Serial No. 97772966 - 24 - looking for a law firm or attorney has a specific legal need and researches those firms and attorneys that offer a particular type of legal service and spend great time and effort in investigating and finding a law firm that meets their specific legal need.” Id. at 16. In its reply brief, Applicant concludes that [l]egal services are not impulse purchases. Consumers typically conduct extensive research, review attorney qualifications and websites, evaluate practice specialties, and often participate in consultations before retaining counsel. These realities substantially reduce, if not outright eliminate, any likelihood of confusion, especially where the firms practice in wholly different legal disciplines. 11 TTABVUE 7. Applicant’s arguments are unsupported by any record evidence, and attorney argument, no matter how silver-tongued, is “no substitute for evidence.” Cielo e Terra, 2026 WL 2624328, at *135 (quoting Iron Balls, 2024 WL 2844425, at *26 (quoting Cai v. Diamond Hong, Inc., 901 F.3d 1367, 1371 (Fed. Cir. 2018)). For the reasons discussed below, the record does not support a finding that consumers of “legal services in the field of personal injury, car accidents, motorcycle accidents, truck accidents, wrongful death, bicycle accidents, boating accidents, criminal defense, DUI, injuries to children, dog bites, premises liability, slip and fall, workplace accidents, medical malpractice, catastrophic injuries, product liability” would exercise more than ordinary care in selecting an attorney. It is common knowledge that many legal services are extremely expensive, and purchases of such services “are not impulse purchases . . . and would ordinarily be [made] with a relatively high degree of care.” Jimenez, 2025 WL 3126703, at *7
Serial No. 97772966 - 25 - (discussing the purchase of roofing services) (citations omitted). But it is also common knowledge that legal services provided to clients with personal injury claims are essentially costless because, as Applicant’s website confirms, personal injury attorneys “only get paid when we win or settle your case.”30 Indeed, Applicant’s website urges prospective clients to “REMEMBER, THERE’S NO OBLIGATION!”31 The contingency-fee basis for such services means that there is no immediate or ongoing financial risk involved in retaining an attorney in a personal injury case. Moreover, injured consumers appear to be able to engage personal injury attorneys online at any time, day or night, as confirmed by Applicant’s website, which provides for a “Free Consultation,” initiated by completing a form, and touts availability “24/7.”32 Applicant’s website encourages an injured consumer to retain a personal injury attorney in the immediate aftermath of an injury, when the consumer may be affected by the injury and in a hurry to find an attorney to obtain compensation for the injury. There are surely some personal injury clients who will select a lawyer after some investigation, but “the applicable standard of care for the likelihood of confusion analysis is that of the least sophisticated consumer.” Primrose Ret. Cmtys., LLC v. Edward Rose Senior Living, LLC, No. 91217095, 2016 WL 7655551, at *12 (TTAB 2016) (citing Stone Lion, 746 F.3d at 1325). On this record, we find that the least 30 October 24, 2023 Office Action at 24. 31 Id. at 17. 32 Id. at 24.
Serial No. 97772966 - 26 - sophisticated potential purchaser of personal injury legal services is unlikely to exercise more than ordinary care in selecting an attorney, and the fourth DuPont factor is neutral in our analysis of the likelihood of confusion. D. Summary of DuPont Factors The key first and second DuPont factors, and the third factor, strongly support a conclusion that confusion is likely, while the fourth DuPont factor is neutral. The services, channels of trade, and classes of purchasers are legally identical, and the marks, which are both dominated by the name SILVER, are similar in appearance, and quite similar in sound, and connotation and commercial impression. We conclude that consumers with a general rather than specific recollection of the cited standard-character mark SILVER LAW GROUP for unrestricted “legal services” who separately encounter Applicant’s SILVER-dominated mark for various personal injury legal services are likely to believe mistakenly that the SILVER LAW GROUP now provides, or is highlighting its provision of, personal injury legal services through SILVER INJURY LAW. Decision: The refusal to register is affirmed.
Was bedeutet dieser Text für Ihre Situation?
Kostenlose und unverbindliche Beratung
Schildern Sie uns Ihre Situation. Unser Team meldet sich per E-Mail bei Ihnen für Ihre Beratung.
Setzen Sie Ihre Recherche in ChatGPT oder Claude fort
Verbinden Sie Omnilex, um den Rechtskorpus über Ihren KI-Assistenten zu durchsuchen.