AdReach LLC

This Opinion is not a
Precedent of the TTAB
Mailed: September 15, 2026
UNITED STATES PATENT AND TRADEMARK OFFICE
_____
Trademark Trial and Appeal Board
_____
In re AdReach LLC
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Serial No. 99207780
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Janice Housey of Litmus Law PLLC,
for AdReach LLC.
Robin Lindemann, Trademark Examining Attorney, Law Office 117,
Megan Askew, Managing Attorney.
_____
Before Heasley, Pologeorgis, and Lavache,
Administrative Trademark Judges.
Opinion by Heasley, Administrative Trademark Judge:
AdReach LLC (“Applicant”) seeks registration on the Principal Register of
the mark ADREACH (in standard characters) for “advertising, marketing, and
promoting the goods and services of others via placement of advertisements on
packaging for food and beverages,” in International Class 35.1
1 Application Serial No. 99207780 was filed on May 29, 2025, based on a declared bona fide
intention to use the mark in commerce under Section 1(b) of the Trademark Act, 15 U.S.C.
§ 1051(b).

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The Trademark Examining Attorney has refused registration of Applicant’s
proposed mark under Section 2(e)(1) of the Trademark Act, 15 U.S.C. § 1052(e)(1), on
the ground that it is merely descriptive of Applicant’s identified services.
When the refusal was made final, Applicant appealed and requested
reconsideration. After the Examining Attorney denied the request for
reconsideration, the appeal proceeded. The appeal is fully briefed. We affirm the
refusal to register.
I. Applicable Law
Section 2(e)(1) of the Trademark Act, 15 U.S.C. § 1052(e)(1), prohibits registration
of any “mark which (1) when used on or in connection with the goods [or services] of
the applicant is merely descriptive … of them,” absent acquired distinctiveness under
Section 2(f) of the Act.2 15 U.S.C. § 1052(f). In re Yarnell Ice Cream, LLC, No.
86824279, 2019 WL 3183842, *6 (TTAB 2019). “A mark is merely descriptive if it
immediately conveys information concerning a feature, quality, or characteristic of
the goods or services for which registration is sought.” Real Foods Pty v. Frito-Lay N.
Am., Inc., 906 F.3d 965, 972 (Fed. Cir. 2018) (quoting In re N.C. Lottery, 866 F.3d
1363, 1367 (Fed. Cir. 2017)) (internal punctuation omitted)).
Citations to the prosecution file refer to the USPTO’s Trademark Status & Document
Retrieval (“TSDR”) system and identify the documents by title, date, and page in the
downloadable .pdf version. References to the briefs and other materials in the appeal record
refer to the Board’s TTABVUE online docketing system.
2 Applicant does not claim acquired distinctiveness under Section 2(f).

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II. Whether the Proposed Mark ADREACH is merely descriptive of
Applicant’s Recited Services
In this case, the Examining Attorney maintains that ADREACH is merely
descriptive of Applicant’s services because AD is short for “advertisement” and
REACH is an industry term meaning the extent of intended customers the
advertisement reaches.3 Taken together, the Examining Attorney concludes, the
proposed mark merely describes the service Applicant proposes to provide: to extend
the reach of others’ advertising by placing it on food and beverage packages.
Evidence that a term is merely descriptive to the relevant purchasing public may
be obtained from any competent source, such as dictionaries, newspapers, or surveys.
In re Nett Designs, Inc., 236 F.3d 1339, 1341 (Fed. Cir. 2001). It also may be obtained
from websites and publications. See N.C. Lottery, 866 F.3d at 1368. The Examining
Attorney cites Merriam-Webster for the proposition that “AD” is a recognized
abbreviation of “advertisement,” and that the two words are used interchangeably.4
In re Thomas Nelson, Inc., No. 76681269, 2011 WL 481341, *6 (TTAB 2011)
(abbreviation that is generally recognized as substantially synonymous with full
descriptive word is itself descriptive).
The Examining Attorney also submits third-party website evidence showing how,
in the advertising and marketing industry, “REACH” is generally recognized and
3 Examining Attorney’s brief, 8 TTABVUE 3-4.
4 Merriam-Webster.com, Feb. 26, 2026 Office Action, Denial of Request for Reconsideration,
at 69.

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commonly used as a term describing the extent of individuals or households exposed
to an ad. To illustrate:
• SellForte - https://sellforte.com/dictionary/reach: “Reach is a fundamental
marketing metric that measures the total number of unique individuals
or households exposed to a marketing message, advertisement, or
campaign within a specific time period.” “In marketing measurement, reach
represents the breadth of your audience and indicates how many different
people have been exposed to your brand or message at least once.” (Feb. 26,
2026 Office Action, Denial of Request for Reconsideration 4).
• The Campus Agency - https://thecampusagency.com/how-to-calculate-reach-
in-marketing-formulasexamples-and-tips/: “Marketing reach refers to the
number of unique individuals who are exposed to your message….” (Id.
at 13),
• GWI - https://www.gwi.com/blog/advertising-effectiveness: “’Reach’ refers to
the number of people who actually saw a company’s advertising.” (Id.,
at 49-56).
• Perion - https://perion.com/glossary/channel/: “Channels can be digital, such
as social media, search engines, and websites, or traditional, like television,
radio, and print media” and “Choosing the right advertising channels is crucial
for maximizing ad reach, engagement, and campaign effectiveness.” (Id. at
63).
• MetricHQ - https://www.metrichq.org/marketing/ad-reach/: “Ad Reach is a
count of the number of people who viewed your ads at least once.
Reach can help you understand how many people have been exposed to a
specific advertisement or marketing message.” (October 21, 2025 Office Action,
8-9).
• Optimize Digital Marketing - https://www.whyoptimize.com/why-is-my-ad-
reach-down-in-q4-this-year: “Ad reach refers to the total number of
unique users who see your advertisement during your marketing
campaign.” (Id. at 23).
• Criteo - https://www.criteo.com/blog/spend-less-perform-more-with-smarter-
scaling/: “Three pillars for scaling ad reach and ROI,” “Diversifying through
commerce media, specifically via the open internet, offers attractive
alternatives to Google and Meta ads, providing opportunities to efficiently
expand your advertising reach” and “Scaling your ad reach is essential.”
(December 1, 2025 Office Action. 43-47; boldface added).

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Descriptiveness is determined from the viewpoint of the relevant purchasers. In
re Bed & Breakfast Registry, 791 F.2d 157, 160 (Fed.Cir.1986); In re Gyulay, 820 F.2d
1216, 1217 (Fed. Cir. 1987). And as this evidence demonstrates, the relevant
purchasers here—potential advertisers—would be quite familiar with the commonly
used term “REACH.”
Taken together, then, the Examining Attorney concludes, AD and REACH merely
describe a feature or characteristic of Applicant’s services: expanding the reach of its
clients’ ads. See, e.g., State Permits, Inc. v. Fieldvine, Inc., No. 92075095, 2024 WL
3825297, *12 (TTAB 2024 (PERMIT[S].COM describes assisting others in obtaining
construction permits.); TRADEMARK MANUAL OF EXAMINING PROCEDURE (“TMEP”)
§ 1209.03(p) (June 2026) (“Terms that identify the function or purpose of a product or
service may be merely descriptive under 15 U.S.C. §1052(e)(1)[.]”).
Applicant readily agrees that its service is intended to expand brand exposure to
consumers; it maintains, however, that given the nature of its ad placement on food
and beverage containers, it does not and cannot quantify the extent of that
expansion—a feature it contends is an essential element of “REACH”:
Applicant offers the placement of messages or advertisements for brands
on packaging for food and beverages—an area typically devoid of
advertising.5
Clearly, by the very nature of Applicant’s Services, Applicant aims to
improve the “reach” of its clients’ advertisements, as this is the inherent
goal of advertising, marketing, and promoting….6
Applicant’s Services “reach” new venues: hotels, concerts, kitchen
5 Applicant’s main brief, 6 TTABVUE 9.
6 Id. at 6 TTABVUE 13.

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counters, pantries, and anywhere else food and beverages are available.7
The target audience then may serve as a walking billboard of an
advertisement and the “ad” then “reach”es a further audience.8
Nonetheless, Applicant maintains:
The placement of advertisements on the physical packaging for food and
beverages has no bearing on measuring the effectiveness of any advertising
campaign, and, in fact, Applicant makes no claim to the same.9
[F]or Applicant’s Services, there would be NO WAY possible to determine
“the number of people who viewed your ads at least once….10
[T]he “reach” of purchasers of Applicant’s Services cannot be measured.11
“AD REACH,” as defined as by the Examining Attorney, only has a
meaning in the digital world.12
7 Id. at 6 TTABVUE 14.
8 Id. at 6 TTABVUE 21.
9 Applicant’s reply brief, 9 TTABVUE 4.
10 Applicant’s main brief, 6 TTABVUE 12.
11 Id.
12 Id. at 6 TTABVUE 15. Applicant does not contend that the absence of a space between AD
and REACH has any effect on its meaning. This is no doubt in acknowledgment of the case
law establishing that “[i]t is almost too well established to cite cases for the proposition that
an otherwise merely descriptive term is not made any less so by merely omitting spaces
between the words….” Minnesota Mining & Mfg. Co. v. Addressograph-Multigraph Corp.,
1967 WL 7276, *2 (TTAB 1967). The Board explains why this is: “when a compound term
comprises two ordinary English words, consumers often recognize them as such, rather than
considering the combination to be a fanciful term with no meaning at all” and “whether such
a mark appears as one word or two often has little or no effect on consumers’ impression of
it.” Anheuser-Busch, LLC v. Innvopak Sys. Pty Ltd, No. 91194148, 2015 WL 5316485, *10
(TTAB 2015). See, e.g., In re Carlson, 2009 WL 1719596, *2 (TTAB 2009) (“the compression
of the words URBAN HOUSING into a single term, URBANHOUZING, still conveys the
commercial impression of two words. In other words, consumers would recognize the mark
as consisting of the separate elements URBAN and HOUZING”); In re A La Vieille Russie
Inc., 2001 WL 862510, *1 n. 2 (TTAB 2001) (“the compound term RUSSIANART is as merely
descriptive as its constituent words, ‘Russian Art”’).

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The Examining Attorney counters that Applicant’s own website touts its service’s
“REACH”:13
“Targeted Reach: place your message in the hands of premium audiences
at hotels, venues and events,”14
“Powerful Reach – connect with high value travelers when they are most
receptive and unhurried,”15
Tellingly, Applicant’s website also claims that Applicant can measure and
analyze its success in extending brand exposure:
“Full Service Support: From creative and production to fulfillment and
analytics, we handle it all,”16
“Performance Analytics – detailed reporting to measure success,” and
“generating measurable brand impression and extended exposure.”17
If Applicant does not and cannot measure the extent of its service’s reach, then
how could it tout these features on its website? In re Gould Paper Corp., 834 F.2d
1017, 1019 (Fed. Cir. 1987)) (“an applicant’s own website or marketing materials may
be probative, or even, … ‘the most damaging evidence,’ in indicating how the relevant
public perceives a term”); In re Fallon, No. 86882668, 2020 WL 6255423, *12 (TTAB
2020) (“the text used on [Applicant’s] website is the most compelling evidence of the
13 Examining Attorney’s brief, 8 TTABVUE 6-10.
14 Dec. 1. 2025 Office Action at 8.
15 Id. at 12.
16 Id. at 8-13.
17 Id. at 10. Nov. 3, 2025 Response to Office Action at 22.

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mere descriptiveness of Applicant’s proposed mark”). As Applicant’s website
indicates, its success in expanding brand exposure can indeed be measured.
At worst, Applicant’s “reach” could be measured on a one-for-one basis: one view
for each purchase of a food or beverage container. As the Examining Attorney notes,
measurement of results is not limited to digital channels, but includes other
channels.18 Two third-party sites affirm:
Perion - https://perion.com/glossary/channel/: “Channels can be digital,
such as social media, search engines, and websites, or traditional, like
television, radio, and print media” and “Choosing the right advertising
channels is crucial for maximizing ad reach, engagement, and campaign
effectiveness.”19
Advertisemint-https://www.advertisemint.com/print-advertising/: “Print
Advertising is a valuable asset for any business looking to expand its reach
and grow,” … “Monitoring metrics such as coupon redemptions, website
visits from QR codes in print ads, or phone inquiries linked to a specific
campaign can provide valuable insights into its effectiveness. Additionally,
tracking brand visibility and recall through surveys and customer feedback
can gauge the impact of print ads” and “Monitor key metrics like ad reach,
engagement, and conversion rates.”20
Applicant additionally argues that its proposed mark is not merely descriptive
because it is suggestive, a double entendre, incongruous, or indicative of an end
result. We address these arguments in turn.
A mark is suggestive, rather than merely descriptive, if it “‘requires imagination,
thought and perception to reach a conclusion as to the nature of the [services].’” In re
18 Examining Attorney’s brief, 8 TTABVUE 11.
19 February 26, 2026 Office Action at 63.
20 Id. at 32-37.

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Fat Boys Water Sports LLC, 2016 WL 3915986, *5 (TTAB 2016) (quoting StonCor
Grp., Inc. v. Specialty Coatings, Inc., 759 F.3d 1327, 1332 (Fed. Cir. 2014)).
Applicant suggests that:
In connection with Applicant’s Mark, the word “reach” should be
considered in its ordinary meaning:
- to stretch out : extend
- to touch or grasp by extending a part of the body (such as a hand) or an
object
- to hand over : pass21
Applicant’s Mark in connection with Applicant’s Services refers to ultimate
consumers of the food/beverage “reach”ing for the package bearing the “ad.”
…
“ADREACH” coveys a distinct image of physically “reaching” for a carton
displaying an advertisement and/or that the nature of this advertising
vehicle has a greater reach than traditional or typical advertisements.22
The Examining Attorney’s definition is consistent with the “greater reach”
interpretation: “Reach : Range or scope of influence or effect.”23 “‘[S]o long as any one
of the meanings of a term is descriptive, the term may be considered to be merely
descriptive.’” In re Mueller Sports Med., Inc., No. 87209946, 2018 WL 2277503, *6
(TTAB 2018) (quoting In re Chopper Indus., 1984 WL 63033, *2 (TTAB 1984)).
Applicant’s intended connotation does not control. UMG Recordings, Inc. v. Mattel,
Inc., No. 91176791, 2011 WL 5014005, *21 (TTAB 2011). As the third-party evidence
demonstrates, the relevant purchasers, those who would engage in the advertising,
21 Merriam-Webster.com, November 3, 2025 Response to Office Action at 11.
22 Applicant’s main brief, 6 TTABVUE at 19-20.
23 AHDictionary.com, Feb. 26, 2026 Office Action at 79.

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would be familiar with the common meaning of “reach” in the advertising context.
Applicant’s proposed mark is not suggestive.
Alternatively, Applicant contends its proposed ADREACH mark is a double
entendre. Its rationale, however, remains the same: “Not only does ‘ADREACH’
convey physically ‘reaching’ for an ad on a product, but also the ‘ad’ is ‘reach’ing out
to its target audience. Further, Applicant’s services are ‘reach’ing into new physical
locations or spaces for advertising….”24
That is not a double entendre. The multiple interpretations that make an
expression a ‘double entendre’ must be associations that the relevant public would
make fairly readily, and must be readily apparent from the proposed mark itself. In
re Calphalon Corp., No. 86356713, 2017 WL 1476288, *10 (TTAB 2017); In re S.
Malhotra & Co. AG, No. 79194076, 2018 WL 4660940, *5 (TTAB 2018). For example,
in In re Colonial Stores, Inc., 394 F.2d 549 (CCPA 1968), the mark SUGAR & SPICE
was not merely descriptive of bakery products because it immediately evoked the
nursery rhyme “sugar and spice and everything nice.” Id. at 552-53. Unlike that case,
Applicant does not establish that the relevant public in the industry—businesspeople
already familiar with the term “ad reach”—would ascribe to it an alternative meaning
not readily apparent from the applied-for mark. Again, an applicant’s intended
interpretation does not control the relevant public’s perception. UMG v. Mattel, 2011
WL 5014005, at *21.
24 Applicant’s main brief, 6 TTABVUE 21.

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Putting a new twist on the same argument, Applicant argues that ADREACH is
incongruous because “the purchaser of the physical good reaches for the ad. While an
ad may metaphorically have ‘reach,’ the person does the reaching, not the ad.”25
Applicant relies on In re Shutts, which held in pertinent part that:
The concept of mere descriptiveness, it seems to us, must relate to general
and readily recognizable word formulations and meanings, either in a
popular or technical usage context, and should not penalize coinage of
hitherto unused and somewhat incongruous word combinations whose
import would not be grasped without some measure of imagination and
“mental pause”.
1983 WL 51780, *2 (TTAB 1983).
Applicant’s reliance on Shutts is misplaced, however, as the term “ad reach” is not
a new coinage, but a popular technical usage, generally and readily recognizable, as
the third-party evidence shows. In consequence, the relevant purchasers in the
industry would not need to engage in a “mental pause” that would render the term
incongruous, and therefore suggestive.
Applicant finally argues that “[a]t most, ‘AD REACH’ would relate to the end
result of Applicant’s Services, not the services themselves … Applicant’s Mark
suggests the desired end result [of] Applicant’s Services: advertising Applicant’s
client’s products in a way that seeks to ensure that consumers of food/beverage not
only ‘view’ the client’s advertisement but then also interact with that ad in a way that
exposes the ad to others (e.g., by carrying the ad around on the food/beverage
container).”26 Applicant relies on In re Noble Co., 1985 WL 72017 (TTAB 1985), in
25 Id. at 6 TTABVUE 22.
26 Id. at 6 TTABVUE 23-24.

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which the Board found NOBURST was not merely descriptive of an antifreeze and
rust inhibitor of heating systems.
Once again, Applicant’s reliance is misplaced. In Noble, the Board found that
NOBURST:
suggests a desired result of using the product…. It is a shorthand way of
suggesting that the product reduces the likelihood that pipes of a water
system in which it is used will burst as a result of adverse conditions. We
do not believe this conclusion is readily arrived at by merely observing the
mark on the goods but that it requires interpretation by the viewer. We
therefore, find the mark to be suggestive rather than merely descriptive of
the goods.
Id. at *1.
That rationale does not apply here, where Applicant’s mark clearly states the
purpose and function of its services. TMEP § 1209.03(p) (“Terms that identify the
function or purpose of a product or service may be merely descriptive under 15 U.S.C.
§1052(e)(1)[.]”).
If a term is merely descriptive, it fails to distinguish the applicant’s goods or
services from those of others, who have an equal right to use the term. Hoover Co. v.
Royal Appliance Mfg. Co., 238 F.3d 1357, 1360 (Fed. Cir. 2001) (“Furthermore,
descriptive terms are in the public domain and should be free for use by all who can
truthfully employ them to describe their goods [or services]. See Estate of P.D.
Beckwith, Inc. v. Comm’r of Patents, 252 U.S. 538, 543-44 (1920)”). This rationale
underlying the mere descriptiveness refusal applies to the purpose, or end goal, of
goods or services, as well as their function.

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In State Permits v. Fieldvine, for example, the Board stated: “We find that
PERMIT[S].COM is, at best, highly descriptive of the parties’ services. Petitioner's
services specifically include “obtaining ... government and regulatory permits ... for
others.” … The parties are referred to, and refer to themselves, as ‘permit expediters.’
Thus, the term PERMIT, in each mark, describes the most important characteristic
or end goal of the identified services, namely, assisting others in obtaining
construction permits.” 2024 WL 3825297, at *12 (emphasis added).
Applicant’s proposed mark also describes the function of its services. Advertisers’
primary end goal is to increase consumer familiarity with their brands. To that end,
Applicant’s services purport to add a new channel of advertising: attaching the
promotions to food and beverage containers. Its ADREACH mark thus describes a
means to a desired end, as well as the end itself. It is an intermediate step toward
increasing brand awareness among consumers. See In re Clorox Co., 1977 WL 22562,
*2 (TTAB 1977) (finding ERASE merely descriptive of stain remover; “While the term
“ERASE” is generally employed to describe an act of rubbing, scraping, or obliterating
characters, letters, markings, and the like usually from writings of one sort or
another, it does nevertheless immediately describe to the average purchaser of
household detergents the purpose and function of applicant's product.”).
Applicant’s proposed mark thus merely describes both the purpose and function
of its service.

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III. Conclusion
Based on careful review of the arguments and evidence of record under the
applicable law, and giving Applicant the benefit of the doubt, we find that the
proposed mark is merely descriptive within the meaning of 15 U.S.C. § 1052(e)(1).
Decision: The refusal to register Applicant’s proposed ADREACH mark is
affirmed.