Law Offices of Michael S. Lamonsoff, PLLC

This Opinion is Not a
Precedent of the TTAB
Mailed: February 11, 2026
UNITED STATES PATENT AND TRADEMARK OFFICE
_____
Trademark Trial and Appeal Board
_____
In re Law Offices of Michael S. Lamonsoff, PLLC
_____
Serial No. 98316445
Serial No. 98317034
Serial No. 98317055
(Consolidated)
_____
Stephanie Furgang Adwar of Adwar Ivko LLC for Law Offices of Michael S.
Lamonsoff, PLLC.
Laura Golden, Trademark Examining Attorney, Law Office 103,
Stacy Wahlberg, Managing Attorney.
_____
Before Larkin, Cohen, and Bradley,
Administrative Trademark Judges.
Opinion by Larkin, Administrative Trademark Judge:
Some attorneys are known for slinging the bull. These three appeals involve an
attorney who wants to be known for being the bull.
Michael S. Lamonsoff, who does business as the Law Offices of Michael S.
Lamonsoff, PLLC (“Applicant”),1 seeks registration on the Principal Register of the
1 Applicant’s briefs in each appeal refer to Applicant as the “Appellant.”

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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standard-character marks MICHAELTHEBULL.COM,2 MICHAEL “THE BULL”
LAMONSOFF,3 and MICHAEL THE BULL,4 all for “legal services” in International
Class 45.
Standing in his way is not a matador with a red cape, but rather another attorney,
Bradley A. Pistotnik (“Registrant”), who owns a bull pen of ten registrations of
English-, Spanish-, and “Spanglish”-language word and composite word-and-design
marks containing the word BULL (or its Spanish equivalent TORO) for “attorney
services” in International Class 45, which have all been cited by the Examining
Attorney assigned to Applicant’s three applications as a bar to registration of
Applicant’s marks under Section 2(d) of the Trademark Act, 15 U.S.C. § 1052(d). The
cited word marks are CALL IN THE BULL,5 ABOGADO EL TORO,6 WE’RE THE
2 Application Serial No. 98316445 was filed on December 15, 2023 under Section 1(a) of the
Trademark Act, 15 U.S.C. § 1051(a), based on Applicant’s claimed first use of the mark and
first use of the mark in commerce at least as early as October 1, 2023.
3 Application Serial No. 98317034 was filed on December 15, 2023 under Section 1(a) of the
Trademark Act, 15 U.S.C. § 1051(a), based on Applicant’s claimed first use of the mark and
first use of the mark in commerce at least as early as October 1, 2023. Applicant entered the
following statement in the application: “The name(s), portrait(s), and/or signature(s) shown
in the mark identifies Michael Lamonsoff, whose consent(s) to register is made of record.”
4 Application Serial No. 98317055 was filed on December 15, 2023 under Section 1(a) of the
Trademark Act, 15 U.S.C. § 1051(a), based on Applicant’s claimed first use of the mark and
first use of the mark in commerce at least as early as October 1, 2023.
5 Registration No. 5150748 issued on February 28, 2017 and has been maintained.
6 Registration No. 5022205 issued on August 16, 2016 and has been maintained. Registrant
translated the mark as “the bull attorney,” and disclaimed the exclusive right to use
ABOGADO apart from the mark as shown.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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BULL ATTORNEYS HIRE THE BIG GUNS,7 and THE BULL ATTORNEYS!,8 all in
standard characters, and the cited composite marks are shown below:
9
10
11
7 Registration No. 6693682 issued on April 5, 2022.
8 Registration No. 5334164 issued on November 14, 2017 and has been maintained.
Registrant disclaimed the exclusive right to use ATTORNEYS apart from the mark as shown.
9 Registration No. 5022207 issued on August 16, 2016 and has been maintained. Registrant
described his mark as “consist[ing] of a graphic depiction of a bull with horns standing on a
curved line over the word ‘ABOGADO’, in all caps with the first and last letters larger than
the other letters, which is above a banner containing the words ‘EL TORO’, in all caps.”
Registrant translated the words “Abogado El Toro” as “the bull attorney,” and disclaimed the
exclusive right to use “Abogado” apart from the mark as shown.
10 Registration No. 6198713 issued on November 17, 2020. Registrant described the mark as
“consist[ing] of a stylized uppercase word ‘THE’, above the stylized uppercase words ‘BULL
ATTORNEYS’, all of which is surrounded by shadow and above the lowercase wording ‘BRAD
PISTOTNIK LAW’. The text in the mark is to the right of a cartoon representation of a bull
with a lowered head standing on top of a curved outline of the ground.” Registrant disclaimed
the exclusive right to use ATTORNEYS and LAW apart from the mark as shown.
11 Registration No. 6771320 issued on June 28, 2022. Registrant described his mark as
“consist[ing] of a stylized bull with a lowered head standing on top of a curved line, which
appears above the stylized wording ‘BULL ATTORNEYS P.A.’ The wording ‘800-WIN-BULL’
is centered underneath.” Registrant disclaimed the exclusive right to use ATTORNEYS P.A.
apart from the mark as shown.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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12
13
14
12 Registration No. 6778145 issued on July 5, 2022. Registrant described his mark as
“consist[ing] of the letter ‘I’ followed by a heart followed by the words ‘THE BULL
ATTORNEYS’ in all caps.” Registrant disclaimed the exclusive right to use ATTORNEYS
apart from the mark as shown.
13 Registration No. 6771319 issued on June 28, 2022. Registrant described his mark as
“consist[ing] of a stylized bull with a lowered head standing on top of a curved line, which
appears above the stylized wording ‘BULL ATTORNEYS P.A.’ The wording ‘800-WIN-BULL’
is centered underneath and is featured above the wording ‘WE ARE THE BULL
ATTORNEYS HIRE THE BIG GUNS. SOMOS LOS ABOGADOS LOS TOROS. DE ARMAS
GRANDES.’” Registrant translated the phrase “Somos los Abogados los Toros. De Armas
Grandes” as ‘We Are the Bull Attorneys. With Big Weapons,” and disclaimed the exclusive
right to use ATTORNEYS P.A. apart from the mark as shown.
14 Registration No. 6771318 issued on June 28, 2022. Registrant described his mark as
“consist[ing] of a stylized bull with a lowered head standing on top of a curved line, which
appears above the stylized wording ‘ABOGADOS LOS TOROS’. The wording ‘800-WIN-
BULL’ is centered underneath and is featured above the wording ‘SOMOS LOS ABOGADOS
LOS TOROS. DE ARMAS GRANDES.’” Registrant translated the phrases “Abogados los
Toro” and “Somos los Abogados los Toros. De Armas Grandes.” as “The Bull Attorneys” and
“We are the Bull Attorneys. With Big Weapons,” respectively, and disclaimed the exclusive
right to use ABOGADOS apart from the mark as shown.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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Applicant’s three applications were assigned to the same Examining Attorney,
and, as discussed below, were examined in parallel. When the Examining Attorney
made each refusal final, Applicant appealed, and requested reconsideration, which
was denied.
Applicant and the Examining Attorney have filed briefs in each appeal, and
Applicant filed a reply brief in the appeal in Serial No. 98317034.15 Because the issues
presented in the three appeals are very similar, and the respective records are
identical, we consolidate the three appeals sua sponte, In re S. Malhotra & Co., No.
79194076, 2018 WL 4660940, at *1 (TTAB 2018), and will decide them in a single
opinion. We reverse the three refusals to register.
I. Prosecution Histories and Records on Appeal16
Applicant’s three applications were all filed on December 15, 2023 based on the
same specimens of use, consisting of the transcript of a radio commercial for
Applicant’s services and pages from Applicant’s website at MichaelTheBull.com.
Non-final Office Actions refusing registration under Section 2(d) based on the ten
cited registrations discussed above were issued in all three cases on July 16, 2024.
The Examining Attorney made of record USPTO electronic records regarding the ten
15 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
materials appear. Applicant’s appeal brief appears at 6 TTABVUE, and the Examining
Attorney’s brief appears at 8 TTABVUE, in all three appeals. Applicant’s reply brief in the
appeal in Serial No. 98317034 appears at 9 TTABVUE.
16 Citations in this opinion to the application records 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” or “Office”).

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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cited registrations,17 and dictionary definitions of the words “legal” and “attorney.”18
Applicant’s responses to the non-final Office Actions were filed in all three cases on
January 9, 2025. Applicant made no evidence of record in its responses.
Final Office Actions were issued in all three cases on February 6, 2025.19 The
Examining Attorney made of record a Wikipedia entry captioned “Spanish language
in the United States;”20 pages from the website at forbes.com;21 pages from the
website at census.gov;22 dictionary definitions of the words “attorney” and legal;”23
pages from the websites of various law firms;24 and USPTO electronic records
regarding Registration No. 2930150 of the mark 1-800-THE BULL for “Licensing of
intellectual property, namely, licensing of a servicemark slogan written in the form
of a toll-free telephone number.”25
On May 6, 2025, Applicant appealed the three final refusals, and simultaneously
requested reconsideration in each case. The Examining Attorney denied Applicant’s
Requests for Reconsideration on June 10, 2025. The Examining Attorney made of
17 July 16, 2024 Office Actions at TSDR 8-22, 32-35 (Ser. Nos. 98316445 and 98317034); July
16, 2024 Office Action at TSDR 7-25 (Ser. No. 98317055).
18 July 16, 2024 Office Actions at TSDR 23-31, 36-41 (Ser. Nos. 98316445 and 98317034); July
16, 2024 Office Action at TSDR 26-40 (Ser. No. 98317055).
19 The Examining Attorney issued a superseding Final Office Action on March 11, 2025 in
Application Serial No. 98317055 to withdraw an issue regarding an additional fee payment
that was inadvertently included in the previous Final Office Action.
20 February 6, 2025 and March 11, 2025 Final Office Actions at TSDR 9-25.
21 February 6, 2025 and March 11, 2025 Final Office Actions at TSDR 26-29.
22 February 6, 2025 and March 11, 2025 Final Office Actions at TSDR 30-37.
23 February 6, 2025 and March 11, 2025 Final Office Actions at TSDR 38-59.
24 February 6, 2025 and March 11, 2025 Final Office Actions at TSDR 60-88.
25 February 6, 2025 and March 11, 2025 Final Office Actions at TSDR 89-90.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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record additional pages from the websites of various law firms.26 The three appeals
were resumed, and are now ready for decision.
II. Analysis of Likelihood of Confusion Refusals
“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 the 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 likelihood of
confusion 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 almost entirely on the first DuPont factor in each appeal, stating
that the issue before the Board is “[w]hether Appellant’s Mark is sufficiently
26 June 10, 2025 Denials of Request for Reconsideration at TSDR 5-46.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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dissimilar from the Cited Registrations to avoid a finding of likelihood of confusion,”
6 TTABVUE 5 (Ser. Nos. 98316445, 98317034, and 98317055), and arguing that “[i]t
is Appellant’s position that the differences in sound, appearance and connotation of
Appellant’s Mark from the Cited Registrations is what makes clear that Appellant is
a different source of legal services from the source of the Cited Registrations.” Id. at
7.27
A. Similarity or Dissimilarity of the Services, Channels of Trade,
and Classes of Consumers28
We begin with the second DuPont factor, which “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 services] as
related enough to cause confusion about the source or origin of the . . . 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 . . .
27 As discussed below, Applicant also discusses a number of third-party registrations that
Applicant claims show “registered marks that were similar to the Cited Registrations” or that
“use an animal personification in their marks without any finding of likelihood of confusion.”
6 TTABVUE 7-8 (Ser. No. 98316445). In its reply brief in the appeal in Serial No. 98317034,
Applicant alludes to the sixth DuPont factor, the “number and nature of similar marks in use
for similar goods.” DuPont, 476 F.2d at 1361, 9 TTABVUE 4-7 (Ser. No. 98317034). We have
given that factor no consideration because it was not raised in the other two appeals and was
raised for the first time in the appeal in Serial No. 98317034 only in Applicant’s reply brief,
to which the Examining Attorney had no opportunity to respond. Cf. Major League Baseball
Players Ass’n v. Chisena, No. 91240180, 2023 WL 2986321, at *26 (TTAB 2023), aff’d, 2026
WL 60319 (Fed. Cir. Jan. 8, 2026).
28 We will address the second and third DuPont factors with respect to each appeal in the
same section because the three applications have identical identifications of services.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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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)).
The relatedness of goods or services may be established based on various evidence,
including (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 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. Id.
The services in Applicant’s three applications are identified as “legal services,”
while the services in the ten cited registrations are identified as “attorney services.”
“‘Apparently conceding the issue [as to the similarity . . . of the [services] and the
similarity . . . of trade channels], Applicant did not address these du Pont factors in
its brief, so we offer only a brief explanation of our conclusion.’” In re Ye Mystic Krewe
of Gasparilla, No. 90522364, 2025 WL 2953731, at *3 (TTAB 2025) (quoting In re
Morinaga Nyugyo K. K., No. 86338392, 2016 WL 5219811, at *2 (TTAB 2016)).
The records show that the adjective “legal” in the three identifications of services
means, among other things, “of, relating to, or having the characteristics of the
profession of law or one of its members,”29 while an “attorney” is a “person who is
29 July 16, 2024 Office Actions at TSDR 23, 28 (MERRIAM-WEBSTER DICTIONARY) (Ser. Nos.
98316445 and 98317034); July 16, 2024 Office Action at TSDR 26, 31 (MERRIAM-WEBSTER
DICTIONARY) (Ser. No. 98317055).

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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legally qualified and licensed to represent a person in a legal matter, such as a
transaction or a lawsuit,”30 and a “lawyer qualified to represent clients in legal
proceedings.”31 Taken together, these definitions show that “legal services” and
“attorney services” are synonymous. The involved services are thus identical and the
second DuPont factor strongly supports a conclusion that confusion is likely with
respect to the marks shown in all three applications. OSF Healthcare, 2023 WL
6140427, at *9 (citation omitted).
The third DuPont factor considers the “similarity or dissimilarity of established,
likely-to-continue trade channels.” DuPont, 476 F.2d at 1361. Because the involved
services are identical, and the respective identifications do not contain any
restrictions regarding legal practice areas, channels of trade, or classes of consumers,
“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 (citation
omitted). The third DuPont factor also strongly supports a conclusion that confusion
is likely with respect to the marks shown in all three applications. Id.
B. Similarity or Dissimilarity of the Marks32
Under the first DuPont factor, “we consider the ‘similarity or dissimilarity of the
marks in their entireties as to appearance, sound, connotation and commercial
30 July 16, 2024 Office Actions at TSDR 40 (THE AMERICAN HERITAGE DICTIONARY) (Ser. Nos.
98316445 and 98317034); July 16, 2024 Office Action at TSDR 39 (THE AMERICAN HERITAGE
DICTIONARY) (Ser. No. 98317055).
31 February 6, 2025 and March 11, 2025 Final Office Actions at TSDR 39 (COLLINS
DICTIONARY).
32 Although the Examining Attorney has cited the same ten marks against each of Applicant’s
marks, we will discuss the first DuPont factor in the three appeals in separate sub-sections

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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impression.’” Ye Mystic Krewe of Gasparilla, 2025 WL 2953731, at *4
(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, 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)). The average
purchaser here is a natural or juristic person seeking legal advice and representation.
because the applications show different marks. Many of the arguments made by Applicant
and the Examining Attorney under the first DuPont factor are same in each appeal. We will
summarize the arguments in detail in the appeal in Serial No. 98316445, which we address
first, and will not repeat those arguments in each section to the extent possible, but will
instead cross-reference and summarize them where possible. We will also cross-reference our
findings where appropriate.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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Where, as here, “the services are identical, the degree of similarity between the
marks necessary to support a determination that confusion is likely declines.” In re
Jimenez, No. 97551823, 2025 WL 3126703, at *4 (TTAB 2025) (citing Bridgestone
Ams. Tire Operations, LLC v. Fed. Corp., 673 F.3d 1330, 1337 (Fed. Cir. 2012)).
At the outset, we address two issues that are common to all three appeals: (1) the
application of the doctrine of foreign equivalents to the cited marks that consist of, or
contain, words in Spanish, and (2) the third-party registrations discussed by both
Applicant and the Examining Attorney in their briefs.
1. Application of the Doctrine of Foreign Equivalents33
As shown and discussed above, four of the cited marks consist of or contain words
in Spanish. The Examining Attorney argues that Spanish “is a common, modern
language in the United States,” 8 TTABVUE 5, that under the doctrine of foreign
equivalents, United States consumers “would understand the Spanish-language
marks to include translations of the word [sic] THE BULL and THE BULLS,
combined with additional wording,” id. at 6, and that “[t]he relevant cited
registrations with Spanish wording provide the following translations: THE BULL
ATTORNEY, THE BULL ATTORNEYS WE ARE THE BULL ATTORNEYS. WITH
33 The Examining Attorney makes essentially the same arguments regarding the doctrine of
foreign equivalents in each appeal. We will cite her brief in the appeal in Serial No. 98316445.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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BIG WEAPONS, and WE ARE THE BULL ATTORNEYS. WITH BIG WEAPONS.”
Id.34 Applicant does not dispute that the doctrine of foreign equivalents applies.35
“The doctrine of foreign equivalents has been considered . . . in the context of
likelihood of confusion—‘to determine . . . similarity of connotation in order to
ascertain confusing similarity with English word marks.’” In re Vetements Grp. AG,
137 F.4th 1317, 1323 (Fed. Cir. 2025), cert. denied, No. 25-215 (U.S. Jan. 12, 2026)
(quoting Palm Bay Imps., Inc. v. Veuve Clicquot Ponsardin Maison Fondee en 1772,
396 F.3d 1369, 1377 (Fed. Cir. 2006)). The Federal Circuit has held that “‘[t]he
doctrine should be applied only when it is likely that the ordinary American
purchaser would stop and translate [the foreign-language word] into its English
equivalent.’” Id. at 1323-24 (quoting Palm Bay, 396 F.3d at 1377 (internal quotation
and quotation marks omitted)).36
“We have consistently found that Spanish is a ‘common language’ in the United
States, and we have routinely applied the doctrine of foreign equivalents to Spanish-
language marks.” Ricardo Media Inc. v. Inventive Software, LLC, No. 91235063, 2019
WL 3956987, at *8 (TTAB 2019) (citations omitted). Like many Spanish words, the
word “toro” appears to be a “loan word” that has become part of the American English
vernacular. See In re Taverna Izakaya LLC, No. 88612441, 2021 WL 5411210, at *4
34 These translations correspond respectively to the cited Registration Nos. 5022207,
6771319, and 6771318.
35 In fact, as discussed below, Applicant cites a third-party mark that contains the Spanish
word TOROS as a mark that is similar to the marks shown in the cited registrations.
36 We note in that regard that in the mark shown in cited Registration No. 6771319, there is
no need to “stop and translate” the Spanish words because the English translation of those
words appears directly above the Spanish words.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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(TTAB 2021) (finding that “the term ‘taverna’ has also entered English as
a loan word and is defined as ‘A café or small restaurant serving Greek food.’”).
The Board may take judicial notice of dictionary definitions, including definitions
from online dictionaries that exist in printed format or have fixed regular editions,
see, e.g., In re Nursecon, LLC, Ser. No. 88052194, 2024 WL 5265079, at *10 n.64
(TTAB 2024) (citation omitted), and we take judicial notice that the MERRIAM-
WEBSTER DICTIONARY defines “toro” as “bull” (merriam-webster.com, last accessed on
February 10, 2026). See August Stork KG v. Florend Indústria e Comércio de
Chocolates LTDA, No. 91277224, 2025 WL 4107480, at *7 (TTAB 2025) (“The fact
that MERCI and DANKE appear in U.S. English dictionaries, defined as foreign
terms, establishes that U.S. consumers are likely to be familiar with both foreign
language words and translate the words to understand their English meaning.”). In
addition, the composite mark shown in cited Registration No. 5022207 contains a bull
design, and the composite mark shown in cited Registration No. 6771318 contains
both a bull design and the English-language word BULL.
Accordingly, we will apply the doctrine of foreign equivalents to the cited marks
consisting of or containing Spanish words because we find that it is likely that
ordinary purchaser of legal services would understand at least that the words “toro”
and “toros” in those marks mean “bull” and “bulls,” respectively.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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2. Third-Party Registrations37
In each appeal, Applicant discusses numerous third-party registrations that fall
into two categories: (1) registrations of marks for legal services that contain the word
BULL or its Spanish plural equivalent TOROS, owned by the Balkin Law Group, 6
TTABVUE 7-8, and (2) what Applicant describes as registrations that “also use an
animal personification in their marks without any finding of likelihood of confusion,”
id. at 8, which include marks that refer to or describe attorneys as lions, eagles, dogs
(including bulldogs and pitbulls), and wolves. Id. at 9-13. Applicant discusses these
third-party marks in connection with the first factor, but third-party marks offered
to show the conceptual weakness of a mark should be considered under the sixth
DuPont factor. Spireon, Inc. v. Flex Ltd., 71 F.4th 1355, 1363 (Fed. Cir. 2023).38
With respect to the first category, Applicant argues that “[a]t the time the Cited
Registrations were registered, there were three existing registered marks that were
similar to the Cited Registrations, a point that was previously discussed in
Appellant’s Response to Office Action.” 6 TTABVUE 7-8. These were “(1) BALKIN
37 Applicant and the Examining Attorney make essentially the same arguments regarding
the third-party registrations in each appeal. We will cite their briefs in the appeal in Serial
No. 98316445.
38 Under the sixth DuPont factor, the “number and nature of similar marks in use on similar
goods,” DuPont, 476 F.2d at 1361, “third-party registrations containing an element that is
common to both . . . marks can show that that element has a normally understood and well-
recognized descriptive or suggestive meaning.” Spireon, 71 F.4th at 1363 (quotation and
quotation marks omitted). Applicant discusses the sixth DuPont factor only in its reply brief
in the appeal in Serial No. 98317034, and, as noted above, we have given the sixth factor no
consideration in that appeal because Applicant did not timely discuss it and in the other
appeals because Applicant did not raise it.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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LAW GROUP 1-800-THE BULL (Reg. No. 86301366),39 (2) 1-800-THE BULL (Reg.
No. 5059017), and (3) 1-800-LOS TOROS (Reg. No. 4983900) (the ‘Balkin
Registrations’).” Id. at 8. According to Applicant, “[d]espite the existing Balkin
Registrations at the time, the ten applications for the Cited Registrations were
permitted to proceed to registration, lending strength to the argument that more than
one company can use the same animal personification in the same industry without
a likelihood of confusion.” Id.
With respect to the second category, Applicant argues that there are “numerous
marks that are registered by the USPTO, all for legal services, that also use an
animal personification in their marks without any finding of likelihood of confusion.”
Id. Applicant discusses the particulars of these third-party registrations, id. at 9-13,
and concludes that
[t]his overwhelming number of marks that share an animal
personification for legal services contradicts a finding of
likelihood of confusion between Applicant’s Mark and the
Cited Registrations. Refusing to register Appellant’s
Marks would essentially mean that only one good or service
provider per industry could use an animal to describe their
goods or services, despite obvious differences in sound,
connotation, and appearance. This notion is contrary to the
law, belied by the records of the USPTO, and clearly weighs
in favor of overturning the Examining Attorney’s refusal.
Id. at 13.
The Examining Attorney addresses the third-party registrations discussed by
Applicant as follows:
39 The listed registration number appears to be the serial number of the application that
matured into the registration.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 17 -
Applicant argues that at the time the cited marks were
registered, there existed other registrations that included
the word BULL for use with related services. To support
applicant’s arguments, applicant submitted evidence of
cancelled or expired third-party registrations. However, a
cancelled or expired registration is only evidence that the
registration issued and it does not carry any of the legal
presumptions under [Trademark Act] Section 7(b), such as
the presumption that the registration is valid, owned by
the registrant, and that the registrant has the exclusive
right to use the mark in commerce in connection with the
goods and/or services specified in the registration
certificate.
8 TTABVUE 7 (quotation, quotation marks, and citations omitted). The Examining
Attorney further argues that “[a]t this time, there is only one registrant with THE
BULL trademark registrations for use with legal services. As such, the registrations
are entitled to a broad scope of protection.” Id. at 8.
With respect to the “additional trademarks for legal services that use an animal
personification without finding any likelihood of confusion,” id., the Examining
Attorney argues that “[o]nce again, these third party registrations are of no
consequence in this matter.” Id. According to the Examining Attorney, “[t]he fact that
other, distinct, trademarks are registered is of no consequence in this case” because
“[p]rior decisions and actions of other trademark examining attorneys in applications
for other marks have little evidentiary value and are not binding upon the USPTO or
the Trademark Trial and Appeal Board.” Id.
The Examining Attorney concludes that Applicant’s “arguments discussing the
coexistence of third party registrations for various Lion designs, and marks featuring
the terms EAGLE, BULLDOG, DOG, WOLF, and PITBULL have no bearing on this
case, involving the BULL wording.” Id. at 9.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 18 -
None of the third-party registrations discussed by Applicant are in the record in
any of the three appeals.40 During prosecution of each application, the Examining
Attorney advised Applicant as follows:
Applicant goes on to argue that the cited marks registered
over third party marks at the time they were registered. As
an evidentiary matter, these files were not made of record
for consideration. To make third-party registrations part of
the record, an applicant must submit copies of the
registrations, or the complete electronic equivalent from
the USPTO’s automated systems, prior to appeal.41
Applicant requested reconsideration in each case, but did not heed the Examining
Attorney’s advice and did not make the cited third-party registrations of record in its
Requests for Reconsideration.42 Applicant simply referred to them once again in its
three appeal briefs. 6 TTABVUE 7-13.
Surprisingly, however, the Examining Attorney did not object in her briefs to
Applicant’s renewed references to these third-party registrations and did not ask the
Board to disregard them. Instead, she discussed the “Balkin Registrations,” claiming
that Applicant “submitted evidence of cancelled or expired third-party registrations,”
8 TTABVUE 7, and the other referenced third-party marks for “legal services that
40 As noted above, the Examining Attorney made of record USPTO electronic records
regarding Registration No. 2930150 of the mark 1-800-THE BULL for “Licensing of
intellectual property, namely, licensing of a service mark slogan written in the form of a toll-
free telephone number,” owned by the Balkin Law Group, February 6, 2025 Final Office
Actions at TSDR 89-90 (Ser. Nos. 98316445 and 98317034); March 11, 2025 Final Office
Action at TSDR 89-90 (Ser. No. 98317055), but this is not one of the “Balkin Registrations”
discussed by Applicant in its appeal briefs.
41 February 6, 2025 Final Office Actions at TSDR 5 (Ser. Nos. 98316445 and 98317934);
March 11, 2025 Final Office Action at TSDR 5 (Ser. No. 98317055).
42 May 6, 2025 Requests for Reconsideration at TSDR 4-12 (Ser. Nos. 98316445, 98317934,
and 98317055).

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 19 -
use an animal personification without finding any likelihood of confusion,” id. at 8,
arguing that “[t]he fact that other, distinct, trademarks are registered is of no
consequence in this case.” Id.
We agree with the Examining Attorney that any registrations of marks for legal
services that characterize attorneys as animals other than bulls, such as lions, eagles,
dogs, or wolves, have no bearing on the registrability of Applicant’s marks over the
marks shown in the cited registrations. “It is axiomatic that the Board must assess
each mark on its own facts and record,” and “the prior decisions and actions of other
trademark examining attorneys in registering other marks are not binding upon the
USPTO or the Board.” In re Korn Ferry, No. 90890949, 2024 WL 3219482, at *5
(TTAB 2024) (quotations and quotation marks omitted). “Each case is decided on its
own facts, and each mark stands on its own merits.” Id. (citation omitted). We will
give these referenced third-party registrations no consideration in our decision
despite the Examining Attorney’s failure to object to them because they have no
probative value on the issue of the similarity or dissimilarity of Applicant’s three
marks to the marks shown in the ten cited registrations.
It is less clear, however, what to do about the “Balkin Registrations.” Although
they are not of record, the Examining Attorney treats them in her briefs as if they
were, and represents that they are now longer subsisting. 8 TTABVUE 7.43 We view
43 As noted above, Applicant did not file reply briefs in the appeals in Serial Nos. 98316445
and 98317055. Applicant filed a reply in the appeal in Serial No. 98317034, but did not
discuss the “Balkin Registrations,” much less dispute the Examining Attorney’s claim in her
brief in Serial No. 98317034 that the “Balkin Registrations” are no longer subsisting,
suggesting that Applicant agrees that they have been cancelled.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 20 -
Applicant’s and Examining Attorney’s discussion of the “Balkin Registrations” as
tantamount to a stipulation that we can consider them for whatever probative value
they may have, and that we may take judicial notice of their current status
notwithstanding the Board’s well-established general practice not to take judicial
notice of registrations. See, e.g., In re Seminole Tribe of Fla., No. 87890892, 2023 WL
3751113, at *3 (TTAB 2023). We take judicial notice that the “Balkin Registrations”
have all been cancelled, and a “cancelled or expired registration has no probative
value other than to show that it once issued and it is not entitled to any of the
statutory presumptions of Trademark Act Section 7(b).” Made in Nature, LLC v.
Pharmavite LLC, No. 91223352, 2022 WL 2188890, at *15 (TTAB 2022) (citing Action
Temp. Servs. Inc. v. Labor Force Inc., 870 F.2d 1563, 1566 (Fed. Cir. 1989)). We will
give the “Balkin Registrations” no consideration in our decision despite the
Examining Attorney’s failure to object to them because they have no probative value
on the issue of the similarity or dissimilarity of Applicant’s three marks to the marks
shown in the ten cited registrations.
3. Similarity or Dissimilarity of the Marks in Serial No.
98316445
The mark shown in Serial No. 98316445 is MICHAELTHEBULL.COM in
standard characters. Applicant summarizes its position regarding the dissimilarity
of this mark and the ten cited marks as follows:
The refusal in this case is primarily predicated upon a
finding of likelihood of confusion based upon the use of the
word BULL in both the Cited Registrations and Appellant’s
Mark. The Examining Attorney’s rejection relied upon the
finding that the commercial impression created by the use
of one word, BULL, used as the personification of the traits

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 21 -
of the registrant, is so strong that even where that word is
used in combination with differently appearing and
differently sounding words, it would so confuse the public
as to source, that no other applicant should be permitted to
use it in connection with the same class of services. The
Examining Attorney’s argument, however, is inapposite to
the myriad of registrations where a personification of a
particular quality is used by multiple registrants for
similar services, and also because the Cited Registrations
themselves were permitted in the face of exiting [sic]
registrations where BULL was used for the same service.
6 TTABVUE 6.44
According to Applicant, the Examining Attorney incorrectly argues that these
marks “create the same overall commercial impression solely because of the inclusion
of the word BULL,” and the “fact that Appellant’s Mark does not sound alike or have
a similar appearance to the Cited Registrations, does not seem to have been
considered at all.” Id. at 14 (citation omitted).
Applicant states that the “Examining Attorney finds that the dominant portion of
the mark is BULL,” id., but argues that “the dominant portion of Appellant’s Mark is
not BULL, but Appellant’s first name MICHAEL. The use of ‘THE BULL’ is clearly
intended to describe a nickname of Appellant’s principal denoting that Appellant’s
principal is, personally, a hard charging, strong advocate whose nickname is THE
BULL.” Id. at 15.
Applicant further argues that “[n]one of the Cited Registrations give the
commercial impression that any of those marks are nicknames for any identified
44 As discussed above, we have given no consideration to the referenced third-party
registrations.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 22 -
individual, nor do they sound or appear similar to MICHAELTHE BULL.COM.” Id.
Applicant addresses the ten cited registrations as follows:
Of all of the Cited Registrations, many are so lengthy and
wordy that it would be contrary to logic to even consider
them confusing to Appellant’s Mark. Where the Cited
Registrations are more succinct (i.e., ABOGADO EL TORO
(Reg. No. 5022205), ABOGADO EL TORO & Design (Reg.
No. 5022207), CALL IN THE BULL (Reg. No. 5150748),
and THE BULL ATTORNEYS! (Reg. No. 5334164), none of
these registrations use a first name or refer to a trait of a
named singular attorney, and none of the Cited
Registrations use BULL to indicates that any particular
individual has the qualities of a bull.
The direct translations of the Cited Registrations which
appear in Spanish are also not the same in sound,
connotation or appearance as Appellant’s Mark. The direct
translation of the Spanish marks is “Attorney The Bull”
and “Attorneys The Bulls” which identifies a non-descript
singular attorney and a non-descript group of attorneys,
rather than a specific individual.
Id.
The Examining Attorney responds that Applicant’s “mark and all of the registered
marks refer to the relevant legal practitioner as ‘THE BULL’ or ‘THE BULLS’ (or the
Spanish equivalent of the same), creating the same overall commercial impression,”
and that “[b]ecause the marks all create the commercial impression of lawyers who
are bulls, stubbornly fighting for their clients, the marks are confusingly similar.” 8
TTABVUE 6.
The Examining Attorney rejects Applicant’s specific arguments for dissimilarity
of the marks as follows:
Applicant argues that the marks are not confusingly
similar because the dominant element of the applied-for
mark is applicant’s first name, Michael. In this case,

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 23 -
applicant’s mark contains three distinct elements, which it
has combined--the name of applicant, as well as the
nickname ‘THE BULL’, and the .COM top-level domain
indicator. As noted above, marks may be confusingly
similar where similar terms or similar parts of terms
appear in the compared marks and create a similar overall
commercial impression. In this case, each part of
applicant’s mark creates a distinct impression that stands
alone. The fact that applicant has added additional
wording to the confusingly similar portion of the mark does
not mitigate the confusing similarity. This is because both
the applied-for mark and the registered marks create the
overall commercial impression of attorneys who go by the
nickname ‘THE BULL’. Of the ten cited marks, nine do not
include a name that would alert consumers, in a side by
side analysis, that the two attorneys are not the same.
Similarly, the .COM designation in applicant’s mark
merely indicates that the mark is being used as a website
URL. These additional elements do not mitigate the overall
similarity provided by the common element ‘THE BULL’
that appears in the relevant marks.
Id.
The Examining Attorney further notes that Applicant “argues that the cited
marks are different because applicant’s mark identifies a specific person who is a bull,
rather than a ‘non-descript’ person or persons who are bulls,” but argues that “the
marks all still create the overall commercial impression of attorneys who have
nicknamed themselves THE BULL. As such, the marks are confusingly similar.” Id.
at 7.
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.,

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 24 -
753 F.2d 1056, 1058 (Fed. Cir. 1985)). We agree with Applicant that in the context of
the identified legal services, the dominant portion of its MICHAELTHEBULL.COM
mark is the lead word MICHAEL, which identifies (albeit incompletely) the specific
service provider. In the context of the mark as a whole, the lead word MICHAEL is
likely to make the greatest impression on consumers, id. at 1303, because the
elements of the mark that follow MICHAEL, the words THE BULL and the TLD
.COM, respectively identify “MICHAEL’S” nickname and the domain at which he can
be reached online. We turn now to the required comparison of the marks in their
entireties, giving greater weight in that comparison to the name MICHAEL in
Applicant’s mark than to the nickname THE BULL or the TLD .COM.
We begin with the four marks that consist of or contain Spanish words. As
explained above, the doctrine of foreign equivalents contemplates that most marks
consisting of or containing foreign words are dissimilar to the compared English-
language marks in appearance and sound, as the doctrine provides a means “to
determine . . . similarity of connotation in order to ascertain confusing similarity with
English word marks.” Vetements Grp., 137 F.4th at 1323 (quotation and quotation
marks omitted). That working assumption applies with full force in all three appeals.
Applicant’s mark MICHAELTHEBULL.COM, and (1) the cited Spanish-language
word mark ABOGADO EL TORO, (2) the cited composite mark containing those
words, and (3) the cited composite marks containing the words “Somos los Abogados
los Toros. De Armas Grandes” (and one also containing the words “Abogados los

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 25 -
Toros”), in addition to English words and the telephone number 800-WIN-BULL, do
not look or sound at all alike.45
We also find that these marks are dissimilar in meaning. Applicant’s mark names
a specific individual service provider whose nickname is “The Bull” and who can be
reached online. In contrast, the cited marks connote an unidentified attorney or group
of attorneys who are described respectively as a bull or as bulls, and who can be
reached by phone and, in two of the marks, are identified as having “big guns” (an
odd mix of metaphors because bulls do not carry weapons), imagery that is not
present in Applicant’s mark.
We turn next to the cited mark that includes Registrant’s name, which we display
again below:
This mark is quite dissimilar in appearance and sound to Applicant’s mark
MICHAELTHEBULL.COM, and it is equally dissimilar in meaning because it
specifically identifies the “Bull Attorneys” as part of a law office that is headed by
45 Applicant’s three marks are all in standard characters and “may be presented in any font
style, size or color, including the same font, size and color as the literal portions of [the cited]
mark[s],” In re Aquitaine Wine USA, LLC, No. 86928469, 2018 WL 1620989, at *5 (TTAB
2018), although we “consider variations of the depictions of the standard character
mark only with regard to ‘font style, size, or color’ of the ‘words, letters, numbers, or any
combination thereof’,” and not with respect to the design elements in the cited marks. Id. at
6 (emphasis in bold here in italics in the original). We have taken the possibility of such
variations into account in our comparisons of all of the involved marks in appearance.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 26 -
attorney Brad Pistotnik, and there is no reference to a “bull attorney” named
“Michael.”
The word marks CALL IN THE BULL, WE’RE THE BULL ATTORNEYS HIRE
THE BIG GUNS, and THE BULL ATTORNEYS! are dissimilar in appearance and
sound to MICHAELTHEBULL.COM because the only visual and oral similarity is
the presence of the word BULL in the involved marks. The marks are also dissimilar
in meaning because two of these cited marks refer to plural BULL ATTORNEYS
(with one referring to their BIG GUNS), and none of them identifies someone named
“MICHAEL” as the service provider.
We turn finally to the two composite marks shown again below:
These marks are also dissimilar in appearance, sound, and meaning to Applicant’s
mark MICHAELTHEBULL.COM because the only commonality is the presence of
the word BULL, and the BULL ATTORNEYS are identified as a group, with no
reference to an individual named MICHAEL.
We find that Applicant’s mark MICHAELTHEBULL.COM and the cited marks
are dissimilar in all means of comparison. The key first DuPont factor strongly

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 27 -
supports a conclusion that confusion is unlikely with respect to the
MICHAELTHEBULL.COM mark shown in Application Serial No. 98316445.
4. Similarity or Dissimilarity of the Marks in Serial No.
98317034
The mark shown in Serial No. 98317034 is MICHAEL “THE BULL”
LAMONSOFF in standard characters. Applicant’s overall argument is virtually
identical to the one that it made in the appeal in Serial No. 98316445. 6 TTABVUE 6
(Ser. No. 98317034). With respect to the specific marks at issue in the appeal in Serial
No. 98317034, Applicant begins its argument as follows:
Appellant’s Mark and the Cited Registrations are
dissimilar in the following ways: appearance, sound,
connotation, and to a certain extent, commercial
impression, as well. In sum, when comparing the Cited
Registrations to Appellant’s Mark, the conclusion of
dissimilarity is inescapable.
When assessing the similarity of the marks in terms of
appearance, sound, connotation, and commercial
impression, examiners may take into account several
factors. The first to consider is whether the dominant
portion of the mark is the same or very similar to the cited
registered mark.
Id. at 14 (citation omitted). Applicant argues that “the dominant portion of
Appellant’s Mark is not BULL, but Appellant’s legal name MICHAEL LAMONSOFF”
because “[t]he use of ‘THE BULL’ is clearly intended to describe a nickname of
Appellant’s principal denoting that Appellant’s principal is, personally, a hard
charging, strong advocate whose nickname is THE BULL.” Id. at 15. Applicant
concludes that “[n]one of the Cited Registrations give the commercial impression that
any of those marks are nicknames for any identified individual, nor do they sound or

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 28 -
appear similar to MICHAEL ‘THE BULL’ LAMONSOFF.” Id. Applicant addresses
the ten cited registrations in a manner virtually identical to the way in which it
addresses the cited marks in the appeal in Serial No. 98316445. Id.
The Examining Attorney responds that “purchasers would understand the
Spanish-language marks to include translations of the word THE BULL and THE
BULLS, combined with additional wording.” 8 TTABVUE 6. She again argues that
applicant’s mark and all of the registered marks refer to
the relevant legal practitioner as ‘THE BULL’ or ‘THE
BULLS’ (or the Spanish equivalent of the same), creating
the same overall commercial impression. Because the
marks all create the commercial impression of lawyers who
are bulls, stubbornly fighting for their clients, the marks
are confusingly similar.
Id.
The Examining Attorney rejects Applicant’s argument that the name MICHAEL
LAMONSOFF is the dominant portion of the mark, arguing that
each part of applicant’s mark creates a distinct impression
that stands alone. The fact that applicant has added
additional wording to the confusingly similar portion of the
mark does not mitigate the confusing similarity. This is
because both the applied-for mark and the registered
marks create the overall commercial impression of
attorneys who go by the nickname “THE BULL”. Of the ten
cited marks, nine do not include a name that would alert
consumers, in a side by side analysis, that the two
attorneys are not the same.
Id.
The Examining Attorney concludes that
the overall commercial impression left to consumers is that
the attorney is a bull. When recalling the trademark,
consumers are more likely to retain this unique commercial

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 29 -
impression than to remember the specific name of the
lawyer.
Finally, applicant argues that the cited marks are different
because applicant’s mark identifies a specific person who is
a bull, rather than a ‘non-descript’ person or persons who
are bulls. Nonetheless, the marks all still create the overall
commercial impression of attorneys who have nicknamed
themselves THE BULL. As such, the marks are
confusingly similar.
Id. at 7.
In its reply brief, Applicant argues that its mark “differs from the Cited
Registrations in that it does not simply add a prefix, suffix, or space, and it is not
entirely subsumed by the Cited Registrations, nor are the Cited Registrations
subsumed by Appellant’s Mark.” 9 TTABVUE 8. According to Applicant, its mark
“adds the entire legal name of the Mark’s principal, setting it apart as discernably
different from the Cited Registrations.” Id. Applicant concludes that “[n]ot only does
Appellant’s Mark include additional words, but those words are a legal name that
directly identifies the service provider, and, other than BULL, does not include any
other words which appear in the Cited Registrations,” id. at 9, and that “the word
‘BULL’ in Appellant’s Mark appears in quotes so as to denote that it is Appellant’s
nickname which he has acquired due to his approach to legal services.” Id.
With respect to the Spanish words in the cited marks, Applicant argues in its reply
brief that “[s]even of the ten Cited Registrations, two of which are entirely in Spanish
and two which are a combination of Spanish and English, refer to a group of ‘bull’
attorneys fighting for their collective clients,” id. at 10, and that “the dominant
portion of Appellant’s Mark is not the word BULL, as the Examining Attorney

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 30 -
asserts, but is the Appellant’s principal’s legal name,” which “changes the meaning
and commercial impression of the mark completely.” Id.
We agree with Applicant that the dominant portion of its mark MICHAEL “THE
BULL” LAMONSOFF is the full name “MICHAEL LAMONSOFF,” which identifies
the specific provider of the involved legal services. The words “THE BULL” in
quotation marks that appear between the first and last names of the service provider
are clearly set off as MICHAEL LAMONSOFF’S nickname. We will give greater
weight in the required comparison of the marks in their entireties to the name
MICHAEL LAMONSOFF in Applicant’s mark than to his stated nickname “THE
BULL.” That comparison is very similar to the one in which we engaged above in the
appeal in Serial No. 98316445, but we find that the marks are more dissimilar in the
appeal in Serial No. 98317034 because the entire name of the service provider
nicknamed “THE BULL” appears in Applicant’s mark.
We begin this time with the composite mark that includes Registrant’s name Brad
Pistotnik. That mark is quite dissimilar in all means of comparison to Applicant’s
mark MICHAEL “THE BULL” LAMONSOFF because the respective marks explicitly
identify different attorneys with very different names.
With respect to the four cited marks consisting of or containing Spanish words,
MICHAEL “THE BULL” LAMONSOFF and those marks do not look or sound at all
alike, and they are also dissimilar in meaning because Applicant’s mark identifies a
specific individual service provider whose nickname is “THE BULL,” while the cited
marks allude to an unidentified attorney or group of attorneys who are described

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 31 -
respectively as a bull or as bulls and are described in two of the marks as having “big
guns,” an association entirely absent from Applicant’s mark.
The cited word marks CALL IN THE BULL, WE’RE THE BULL ATTORNEYS
HIRE THE BIG GUNS, and THE BULL ATTORNEYS! are more dissimilar than
similar in appearance and sound to MICHAEL “THE BULL” LAMONSOFF because
the only visual and oral similarity is the presence of the word BULL in the involved
marks. With respect to meaning, two of these marks refer to plural BULL
ATTORNEYS, one of which also refers to their BIG GUNS, and none of the cited word
marks identifies a specific individual or individuals as the BULL or one of the BULL
ATTORNEYS.
The two remaining composite marks are also dissimilar in appearance, sound, and
meaning to Applicant’s mark MICHAEL “THE BULL” LAMONSOFF because the
only commonality is the presence of the word BULL, and the BULL ATTORNEYS
referenced in the cited marks are identified as a group, with no reference to an
individual, much less one named MICHAEL LAMONSOFF.
We find that Applicant’s mark MICHAEL “THE BULL” LAMONSOFF and the
cited marks are dissimilar in all means of comparison. The first DuPont factor
strongly supports a conclusion that confusion is unlikely with respect to the
MICHAEL “THE BULL” LAMONSOFF mark shown in Application Serial No.
98317034.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 32 -
5. Similarity or Dissimilarity of the Marks in Serial No.
98317055
The mark shown in Serial No. 98317055 is MICHAEL THE BULL in standard
characters. This mark is very similar structurally to the mark
MICHAELTHEBULL.COM shown in Serial No. 98316445, with the only differences
being the presence of spaces between the words in the MICHAEL THE BULL mark,
and the absence in that mark of the TLD .COM, which has no source-identifying
significance. See, e.g., In re Katch, LLC, No. 86301765, 2019 WL 2560528, at *9
(TTAB 2019).
In the appeal in Serial No. 98317055, Applicant’s arguments, 6 TTABVUE 14-15,
and the Examining Attorney’s arguments, 8 TTABVUE 4-7, are very similar to those
that they made in the appeal in Serial No. 98316445, and our analysis of the
similarity or dissimilarity of the marks is also very similar.
Applicant argues that the dominant portion of its mark MICHAEL THE BULL “is
not BULL, but Appellant’s first name MICHAEL” and that the “use of ‘THE BULL’
is clearly intended to describe a nickname of Appellant’s principal denoting that
Appellant’s principal is, personally, a hard charging, strong advocate whose
nickname is THE BULL.” 6 TTABVUE 15. According to Applicant, “[n]one of the
Cited Registrations give the commercial impression that any of those marks are
nicknames for any identified individual, nor do they sound or appear similar to
MICHAEL THE BULL.” Id.
The Examining Attorney responds that “Applicant argues that the marks are not
confusingly similar because the dominant element of the applied-for mark is

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
- 33 -
applicant’s first name, Michael. In this case, applicant’s mark contains two distinct
elements, which it has combined--the name of applicant, as well as the nickname
‘THE BULL’.” 8 TTABVUE 6. The Examining Attorney further argues that
each part of applicant’s mark creates a distinct impression
that stands alone. The fact that applicant has added
additional wording to the confusingly similar portion of the
mark does not mitigate the confusing similarity. This is
because both the applied-for mark and the registered
marks create the overall commercial impression of
attorneys who go by the nickname “THE BULL”. Of the ten
cited marks, nine do not include a name that would alert
consumers, in a side by side analysis, that the two
attorneys are not the same.
Id. She concludes that
[i]n this case, the overall commercial impression left to
consumers is that the attorney is a bull. When recalling the
trademark, consumers are more likely to retain this unique
commercial impression than to remember the specific
name of the lawyer.
Finally, applicant argues that the cited marks are different
because applicant’s mark identifies a specific person who is
a bull, rather than a “non-descript” person or persons who
are bulls. Nonetheless, the marks all still create the overall
commercial impression of attorneys who have nicknamed
themselves THE BULL. As such, the marks are
confusingly similar.
Id. at 7.
We agree with Applicant that the name MICHAEL is the dominant portion of its
mark because it appears first and because the words THE BULL that follow it would
be viewed as “MICHAEL’S” nickname even though they are not contained within
quotation marks. We will give greater weight to the name MICHAEL than to the
words THE BULL in our comparison of the marks in their entireties.

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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Turning first to the four marks that consist of or contain Spanish words,
Applicant’s mark MICHAEL THE BULL, and (1) the cited Spanish-language word
mark ABOGADO EL TORO, (2) the cited composite mark containing those words,
and (3) the cited composite marks containing the words “Somos los Abogados los
Toros. De Armas Grandes” (and one also containing the words “Abogados los Toros”),
in addition to English words and the telephone number 800-WIN-BULL, again do not
look or sound at all alike. We also find that these marks are dissimilar in meaning
because Applicant’s mark identifies a specific individual service provider named
MICHAEL whose nickname is “THE BULL,” while the cited marks allude to an
unspecified attorney or group of attorneys who are described respectively as a bull or
as bulls and, in two of the marks, are identified as having “big guns,” imagery that is
again not present in Applicant’s mark.
The cited composite mark containing the words “The Bull Attorneys” and the
phrase “Brad Pistotnik Law” is quite dissimilar in appearance and sound to
Applicant’s mark MICHAEL THE BULL, and it is equally dissimilar in meaning,
because it specifically identifies the “Bull Attorneys” as part of a law office that is
headed by attorney Brad Pistotnik, and there is no reference to a “bull attorney”
named “MICHAEL.”
The word marks CALL IN THE BULL, WE’RE THE BULL ATTORNEYS HIRE
THE BIG GUNS, and THE BULL ATTORNEYS! are more dissimilar than similar in
appearance and sound to MICHAEL THE BULL because the only visual and oral
similarity is the presence of the word BULL in the involved marks. With respect to

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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meaning, two of these marks refer to plural BULL ATTORNEYS, one of which refers
also to their BIG GUNS, and none of them identifies “MICHAEL” as the service
provider. We find that these marks are more dissimilar than similar in meaning.
Finally, the two cited composite marks are dissimilar in appearance, sound, and
meaning to Applicant’s mark MICHAEL THE BULL because the only commonality
is the presence of the word BULL, and both cited marks contain the plural BULL
ATTORNEYS, who are identified as a group, with no reference to an individual
named “MICHAEL.”
We find that Applicant’s mark MICHAEL THE BULL and the cited marks are
dissimilar in all means of comparison. The first DuPont factor strongly supports a
conclusion that confusion is unlikely with respect to the MICHAEL THE BULL mark
shown in Application Serial No. 98317055.
C. Balancing the Two Key DuPont Factors
“The final step in analyzing likelihood of confusion is to weigh the DuPont factors
for which there has been evidence and argument; ‘explain the results of that
weighing;’ and discuss ‘the weight [we] assigned to the relevant factors.’” Jimenez,
2025 WL 3126703, at *8 (quoting Charger Ventures, 65 F.4th at 1379). “No
mechanical rule determines likelihood of confusion, and each case requires weighing
of the facts and circumstances of the particular mark.” Id. (quoting In re Mighty Leaf
Tea, 601 F.3d 1342, 1346 (Fed. Cir. 2010)). “‘[T]he weight afforded to each factor
depends on the circumstances’ and ‘[a]ny single factor may control a particular case.’”

Serial Nos. 98316445, 98317034, and 98317055 (Consolidated)
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Id. (quoting Stratus Networks, Inc. v. UBTA-UBET Commc’ns Inc., 955 F.3d 994, 998
(Fed. Cir. 2020)).
In each appeal, the two key DuPont factors point us in different directions. The
key second factor, and the third factor, both strongly support a conclusion that
confusion is likely because the services, channels of trade, and classes of consumers
are identical. As discussed above, the identical nature of the services also reduces the
degree of similarity between the marks that is required for confusion to be likely.
At the same time, however, each of Applicant’s three marks, and all of the ten
cited marks, “are different in their entireties, weighing heavily against finding a
likelihood of confusion,” Jimenez, 2025 WL 3126703, at *8, with many of the cited
marks being very dissimilar to Applicant’s marks. A single DuPont factor may be
dispositive of the issue of likelihood of confusion, Kellogg Co. v. Pack’em Enters., Inc.,
951 F.2d 330, 333 (Fed. Cir. 1991) (finding no legal error in the Board’s ruling “that
the dissimilarity of ‘the marks in their entireties’ itself made it unlikely that
confusion would result from the simultaneous use of the marks”), and we conclude
here that “the respective marks overall are different enough that even when used on
identical . . . services in overlapping trade channels, consumers likely would not be
confused into believing that they emanate from the same source.” Heil Co. v. Tripleye
GmbH, No. 91277359, 2024 WL 4925901, at *38 (TTAB 2024).
Decision: The refusals to register in Serial Nos. 98316445, 98317034, and
98317055 are reversed.