P&P Imports LLC

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This Opinion is Not a
Precedent of the TTAB

Mailed: September 25, 2026

UNITED STATES PATENT AND TRADEMARK OFFICE

Trademark Trial and Appeal Board

In re P&P Imports LLC

Serial No. 98669267

Kevin White, Esq. of P&P Imports LLC,
for P&P Imports LLC,

Claudia A. Kopenski, Trademark Examining Attorney, Law Office 129,
Pam Willis, Managing Attorney.
Before Lykos, Allard and O’Connor,

Administrative Trademark Judges.

Opinion by O’Connor, Administrative Trademark Judge:

P&P Imports LLC (“Applicant”) seeks registration on the Principal Register of the
standard-character mark GOLF DARTS for “action skill games,” in International
Class 28.1

The Trademark Examining Attorney refused registration on the ground that the

proposed mark is merely descriptive of the identified goods under Section 2(e)(1) of

1 Application Serial No. 98669267 was filed on July 26, 2024 pursuant to Section 1(a) of the
Trademark Act, 15 U.S.C. § 1051(a), based on Applicant’s claimed first use of the mark
anywhere and in commerce at least as early as December 2, 2022 (the “Application”).

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the Trademark Act, 15 U.S.C. § 1052(e)(1). When the refusal was made final,
Applicant requested reconsideration and filed this appeal, which was suspended. The
application was remanded to the Examining Attorney to consider the request for
reconsideration, which was denied. The appeal was resumed, and is fully briefed. For
the reasons that follow, we affirm the refusal to register.
I. Mere Descriptiveness – Applicable Law
In the absence of acquired distinctiveness,2 Section 2(e)(1) of the Trademark Act
prohibits registration of a mark on the Principal Register that, when used in
connection with an applicant’s goods, is merely descriptive of them. 15 U.S.C.
§ 1052(e)(1). A term is merely descriptive if it immediately conveys knowledge of an
ingredient, quality, feature, function, or characteristic of the identified goods. In re
TriVita, Inc., 783 F.3d 872, 874 (Fed. Cir. 2015); see also In re Chamber of Com. of the
U.S., 675 F.3d 1297, 1300 (Fed. Cir. 2012). By contrast, a mark is suggestive if
imagination, thought or perception is required to reach a conclusion as to the qualities
or characteristics of the goods. In re Gyulay, 820 F.2d 1216, 1217 (Fed. Cir. 1987).
The determination of whether a proposed mark is merely descriptive must be
made in relation to the goods for which registration is sought, not in the abstract. In
re Bayer AG, 488 F.3d 960, 964 (Fed. Cir. 2007). This requires consideration of the
context in which the putative mark is used or intended to be used in connection with
those goods, and the possible significance that it would have to the average purchaser
of the goods in the marketplace. Id. See also In re N.C. Lottery, 866 F.3d 1363, 1367
2 Applicant does not claim acquired distinctiveness.

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(Fed. Cir. 2017) (citations omitted) (in considering whether an applied-for mark is
merely descriptive, the Board “must consider a mark in its commercial context to
determine the public’s perception”). The question is not whether someone presented
with only the proposed mark could guess the goods listed in the identification, but
rather whether someone who knows what the goods are will understand the proposed
mark to convey information about them. DuoProSS Meditech Corp. v. Inviro Med.
Devices, Ltd., 695 F.3d 1247, 1254 (Fed. Cir. 2012).
“When two or more merely descriptive terms are combined, the determination of
whether the composite mark also has a merely descriptive significance turns on
whether the combination of terms evokes a new and unique commercial impression.”
In re Omniome, Inc., No. 87661190, 2019 TTAB LEXIS 414, at *3. However, if each
component retains its merely descriptive significance in relation to the goods, the
combination results in a composite that is itself merely descriptive. Id.
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.” Bayer, 488 F.3d at 964 (cited in Heritage All. v. Am. Pol’y Roundtable, 133
F.4th 1063, 1068 (Fed. Cir. 2025)). It may also be obtained from “labels, packages, or
in advertising material directed to the goods,” In re Abcor Dev. Corp., 588 F.2d 811,
814 (CCPA 1978), or from websites and publications. N.C. Lottery, 866 F.3d at 1368.
The sources consulted may include Applicant’s specimen of use. Id. (Board “did not
err by considering the explanatory text of the specimens in the descriptiveness
inquiry”).

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II. Analysis
We first consider the meanings of the terms GOLF and DARTS, and the composite
GOLF DARTS, in view of Applicant’s identified “action skill games,” the specimen of
use, and other evidence in the record. See, e.g., In re Petroglyph Games, Inc., No.
78806413, 2009 TTAB LEXIS 465, at *14 (“First, we examine the evidence concerning
the meanings that would be ascribed to the term BATTLECAM and the separate
terms BATTLE and CAM, when used with applicant’s goods.”).
Dictionary evidence made of record by Applicant defines “golf” as “a game in which
a player using special clubs attempts to sink a ball with as few strokes as possible
into each of the 9 or 18 successive holes on a course.”3 “Dart” is defined as “a small
missile usually with a pointed shaft at one end and feathers at the other” and “darts”
is defined as “a game in which darts are thrown at a target.”4 These definitions show
that golf and darts are known games that use particular implements to attain
particular objectives.
The specimen provided for Applicant’s “action skill games” and excerpts from
Applicant’s website and Amazon.com product listing show that Applicant’s goods
include a “dartboard target,” “darts scoreboard,” and so-called “‘Chip N’ Stick’ golf
balls” that are modified with hook and loop fastener so they can stick to the target:
3 October 14, 2025 Request for Reconsideration, TSDR 60 (entry from MERRIAM-WEBSTER
DICTIONARY).
Page references herein to the application record refer to the online database of the USPTO’s
Trademark Status & Document Retrieval (“TSDR”) system.
4 Id. at 55 (entry from MERRIAM-WEBSTER DICTIONARY).

Serial No. 98669267

aq

5 FAH
11

b

5 December 11, 2024 Nonfinal Office Action, TSDR 5.

_5-

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Advertising on Applicant’s website, www.playgosports.com, and an Amazon.com
listing states “GOLF DARTS: An exciting new chipping game that combines the
precision of darts with the fun of golf; The included Chip N’ Stick golf balls stick to
the oversized fabric target for scoring.”6 The advertising further states
“TRADITIONAL DART GAMES: Practice and improve your chipping skills while
playing classic darts games like Cricket and 301, or make up your own (game rules
included).”7 As explained on Applicant’s website, “GoSports Golf Darts is a fun twist
on two beloved games. Hit the Chip N’ Stick golf balls onto the giant fabric dartboard
to score points. The target features full color graphics that make you feel like you are
playing darts on the golf course!”8
This evidence shows that Applicant’s “action skill games” include features that
combine elements of both golf and darts. When the words GOLF and DARTS are
combined into GOLF DARTS and used for Applicant’s goods, the words retain their
original meanings as referring to features of the goods, which include aspects of both
golf and darts. See, e.g., In re Zuma Array Ltd., No. 79288888, 2022 TTAB LEXIS
281, at *8, 22 (composite mark found descriptive where combination of terms did not
“convey[ ] any distinctive source identifying impression contrary to the
6 See id.; January 21, 2026 Denial of Request for Reconsideration, TSDR 9. Applicant also
provided a copy of its Amazon.com listing, October 14, 2025 Request for Reconsideration,
TSDR 31-32, which appears to be the same in all material respects as that provided by the
Examining Attorney.
The evidence indicates that “chipping” is a type of golf shot. See, e.g., January 21, 2026 Denial
of Request for Reconsideration, TSDR 20.
7 December 11, 2024 Nonfinal Office Action, TSDR 5 (Applicant’s website); January 21, 2026
Denial of Request for Reconsideration, TSDR 9 (Applicant’s Amazon.com listing).
8 December 11, 2024 Nonfinal Office Action, TSDR 6.

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descriptiveness of the individual parts”) (cleaned up). The record supports a finding
that consumers are likely to perceive GOLF DARTS as directly and immediately
conveying information about significant features of Applicant’s “action skill games,”
namely, that the goods combine features of the games of golf and darts. See, e.g.,
Chamber of Com., 675 F.3d at 1301 (content of applicant’s website, along with articles
discussing the activities of chambers of commerce, constituted substantial evidence
supporting Board’s finding of mere descriptiveness).
Applicant argues that GOLF DARTS is suggestive in that the combination of
GOLF and DARTS “presents a bizarre and incongruous meaning that cannot be
grasped without some measure of imagination and mental pause.”9 Pointing to the
dictionary definitions,10 Applicant contends that its game lacks traditional elements
of either golf (no course, holes, etc.) or darts (no feathered darts, needle darts piercing
a regulation dartboard, etc.) and, therefore, consumers must engage in a multistep
analysis to arrive at meaning for the applied-for mark.
Although the term GOLF DARTS may at first glance seem unusual when
considered in the abstract, we find nothing bizarre or incongruous about the
combination of the words GOLF and DARTS when it is considered in relation to
Applicant’s “action skill games.” The goods “action skill games” are identified broadly
9 6 TTABVUE 6.
References to the briefs on appeal refer to TTABVUE, the Board’s online docketing system.
The number preceding “TTABVUE” corresponds to the docket entry number; the number(s)
following “TTABVUE” refer to the page number(s) of that particular docket entry.
10 October 14, 2025 Request for Reconsideration, TSDR 55, 60 (entries from MERRIAM-
WEBSTER DICTIONARY for dart/darts and golf).

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and as reflected in the evidence, encompass a game that combines aspects of both golf
and darts. See In re Allen Electric & Equip. Co., 458 F.2d 1404, 1405 (CCPA 1972)
(identified goods were “antennas” and there was evidence in the record that there are
antennas known as “scanning antennas,” such that the mark SCANNER was merely
descriptive). As seen in Applicant’s specimen and advertising, Applicant’s game
combines features from both golf and darts, including a dartboard-style target and
modified golf balls. The specimen depicts players hitting golf balls at the dartboard
target, and the game is specifically promoted as a way to improve one’s chipping skills
while playing classic darts games.
The term GOLF DARTS directly and immediately conveys information about
characteristics of Applicant’s goods. This is unlike cases where incongruity was found
because there was a difference or disconnect between the terms in the mark and the
goods or services. See, e.g., In re Shutts, No. 73245440, 1983 TTAB LEXIS 150, at *1,
6-7 (SNO-RAKE not merely descriptive of “snow removal hand tool having a handle
with a snow-removing head at one end, the head being of solid uninterrupted
construction without prongs”); In re Tennis in the Round Inc., 1978 TTAB LEXIS 44,
at *6-7 (TENNIS IN THE ROUND not merely descriptive of providing tennis facilities
in a setting that was not analogous to a “theater-in-the-round”).
Despite Applicant’s insistence otherwise, it is of no moment that Applicant’s game
does not include all of the rules or implements of either golf or darts.11 It is not
11 See, e.g., 6 TTABVUE 9 (stating that analysis “is based on a contemplation of the entirety
of a representative product, not just suggestive elements of Applicant’s goods”).

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necessary that a term describe all of the purposes, functions, characteristics, or
features of the goods to be considered merely descriptive; it is enough if the term
describes one significant function, attribute, or property. Chamber of Com., 675 F.3d
at 1300. See also In re Oppedahl & Larson LLP, 373 F.3d 1171, 1173 (Fed. Cir. 2004)
(“A mark may be merely descriptive even if it does not describe the ‘full scope and
extent’ of the applicant’s goods or services.”) (quoting In re Dial-A-Mattress Operating
Corp., 240 F.3d 1341, 1346 (Fed. Cir. 2001)).
Applicant also argues that its combination of terms is “jarring and suggestive”
because it suggests “an undefined combination of non-overlapping concepts and
gameplay that cannot itself be immediately derived from the terms of Applicant’s
Mark.”12 We do not agree that the combination of GOLF and DARTS for “action skill
games” would be perceived as jarring or suggestive, especially in light of Applicant’s
own advertising materials and specimen discussed above. Moreover, the Examining
Attorney provided evidence of others using the terms “Golf Darts” or “Dart Golf” with
reference to a game that combines features of both golf and darts, namely:
• Blog post on gldproducts.com titled “How to Play Golf Darts” describes
a darts game called “Golf Darts” that mimics a 9- or 18- round game of
golf with stroke counts determined by which part of the board is hit and
the overall objective of using as few “strokes” as possible.13
• Article on darthelp.com titled “How to Play Golf Darts on a Standard
Dartboard” describes a similar game in which the number of strokes is
12 6 TTABVUE 8-9. Applicant’s argument misstates the applicable legal standard, which, as
noted above, does not consider the proposed mark in the abstract or ask whether a person
could guess what the goods are if presented with only the mark. DuoProSS, 695 F.3d at 1254.
Instead, the proposed mark must be considered with the identified goods in mind.
13 December 11, 2024 Nonfinal Office Action, TSDR 9-10.

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determined by where the dart lands and the objective is to finish 9 or 18
rounds while scoring as low as possible.14
• Wikipedia.org entry for “Dart Golf” stating that “Dart golf games are
games in which darts are thrown at traditional dart boards or dart
boards that resemble golf courses with colored areas that represent a
golf course. Dart golf games use golf-like rules and scoring. Rules and
board configurations of the game vary from league to league….”15
• Wiktionary.org entry for “dart golf” stating that it is a noun meaning
“[a] variant of darts in which the dartboard represents (and may
resemble) a golf course, and having rules and scoring derived from
golf.”16
Although, as Applicant states,17 these games are not the same as Applicant’s
because they use a traditional dartboard and darts, this evidence shows that
Applicant’s consumers are likely to be familiar with the concept of a dart or dart-like
game that follows the play and scoring of golf. Cf. Petroglyph Games, 2009 TTAB
LEXIS 465, at *30-32 (even without evidence that products actually featured battle
cameras, evidence of video game players using terms “camera,” “battle camera” or
“battle cam” indicates the terms are familiar, descriptive terms in the computer game
field; BATTLECAM held descriptive). In view of this commercial context, a proposed
mark that combines the words GOLF and DARTS for an action skill game that itself
combines features of both games would not be jarring to the average consumer.
Applicant also argues that the registration on the Principal Register of other
marks, including those that combine DART with another word for action skill games
14 Id. at 16-18.
15 Id. at 14.
16 April 11, 2025 Final Office Action, TSDR 6.
17 9 TTABVUE 3-4.

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and similar goods, shows that GOLF DARTS should be deemed suggestive.18 These
include active registrations for marks such as SMACK DARTS and RINGER DARTS
(DARTS disclaimed in both marks) and cancelled registrations for SEX-DARTS and
GOLFDARTS.19 The two cancelled registrations on their face are of limited value as
they are evidence only of the fact that the registrations issued. See, e.g., In re Wal-
Mart Stores, Inc., No. 86261962, 2019 TTAB LEXIS 1, at *40 (citing cases).
As for the remaining registrations, they too are of limited value because they
involve different marks than the applied-for mark GOLF DARTS and are based on
entirely different records. “The great variation in facts from case to case prevents the
formulation of specific rules for specific fact situations. Each case must be decided on
its own merits.” TRADEMARK MANUAL OF EXAMINING PROCEDURE (TMEP) § 1209.01(b)
(May 2026) (citing In re Ampco Foods, Inc., No. 73313197, 1985 TTAB LEXIS 46, at
*7; In re Venturi, Inc., No. 73004593, 1977 TTAB LEXIS 200, at *7). An applied-for
mark that is merely descriptive or generic is not registrable simply because other
seemingly similar marks have been registered. In re Consumer Prot. Firm PLLC, No.
87445801, 2021 TTAB LEXIS 67, at *29; TMEP § 1209.03(a). “Even if some prior
18 6 TTABVUE 8, 9-10 (pointing to eight registrations that Applicant made of record during
prosecution). Applicant’s re-submission of this evidence with its appeal brief was
unnecessary. See, e.g., In re Black Card LLC, No. 90641690, 2023 TTAB LEXIS 478, at *6
(evidence made of record during prosecution should not have been refiled with the brief; the
Board discourages practice of filing evidence again with a party’s appeal brief).
19 See October 14, 2025 Request for Reconsideration, TSDR 12, 22, 29, 37.
Applicant’s reply brief refers to yet another registered mark, ACQUA DARTS. 9 TTABVUE
7, n.1. Insofar as Applicant failed to make this registration properly of record, we give it no
consideration. See Trademark Rule 2.142(d), 37 C.F.R. § 2.142(d) (record should be complete
prior to the filing of an appeal).

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registrations had some characteristics similar to [Applicant’s mark], the [US]PTO’s
allowance of such prior registrations does not bind the Board.” In re Nett Designs,
Inc., 236 F.3d 1339, 1342 (Fed. Cir. 2001). We must assess each proposed mark on
the record of public perception submitted with the application. Id. Accordingly, we
find that the other registrations do not overcome the showing that has been made of
mere descriptiveness.
Lastly, Applicant argues that there is doubt as to the descriptiveness of the
proposed mark that should be resolved in its favor.20 Here, however, we have
no doubt that average consumers with an understanding of Applicant’s goods will
directly and immediately perceive that the proposed mark GOLF DARTS conveys
information about the goods.
III. Conclusion
Based on the foregoing, the proposed mark GOLF DARTS directly and
immediately conveys information about Applicant’s “action skill games,” namely, that
they include features of the games of golf and darts. We therefore find Applicant’s
proposed mark to be merely descriptive of the identified goods.
Decision:
The mere descriptiveness refusal under Section 2(e)(1) of the Trademark Act is
affirmed.
20 6 TTABVUE 10-12.