Protect for Success, LLC

This Opinion is Not a
Precedent of the TTAB
Mailed: January 21, 2026
UNITED STATES PATENT AND TRADEMARK OFFICE
_____
Trademark Trial and Appeal Board
_____
In re Protect for Success, LLC
_____
Serial No. 98051678
_____
Stephanie Pottick of Pottick Law PC,
for Protect for Success, LLC.
Amit Shoor, Trademark Examining Attorney, Law Office 117,
Cynthia Tripi, Managing Attorney.
_____
Before Greenbaum, Dunn, and English,
Administrative Trademark Judges.
Opinion by Dunn, Administrative Trademark Judge:
Protect for Success, LLC (Applicant) seeks registration on the Principal Register
of the proposed mark NO LAW DEGREE REQUIRED (in standard characters) for:1
Business consultation services; Business advisory services in the field of
business strategy; Providing general business information via a website, social
media, the internet, satellite, cable and wireless mobile devices; providing
commentary in the field of business strategies, in International Class 35.
1 Application Serial No. 98051678 filed under Section 1(a) of the Trademark Act, 15 U.S.C.
§ 1051(a), based upon Applicant’s claim of first use anywhere since at least as early as
November 28, 2021 and use in commerce since at least as early as January 22, 2022 in all
three classes.
References to the application are to the downloadable .pdf version of documents available
from the USPTO’s TSDR (Trademark Status and Document Retrieval) database. The
TTABVUE citations refer to the Board’s electronic docket, with the first number referring to
the docket entry and the second number, if applicable, referring to the page within the entry.

Serial No. 98051678
- 2 -
Education and entertainment services, namely, providing non-downloadable
webinars, seminars, educational conferences, workshops, presentations,
lectures, coaching, courses and classes on business and legal information, tips,
tools and strategies and distribution of materials in connection therewith;
Educational services, namely, providing online instruction in the fields of law
and business information, tips, tools and strategies; Education and
entertainment services, namely, providing non-downloadable videos, blogs, in
the fields of law and business; Providing online non-downloadable news
articles and newsletters in the fields of legal and business information, tips,
tools and strategies, in International Class 41.
Providing information in the field of law; Providing commentary in the field of
law regarding legal strategies; Providing general legal information via a
website, social media, the internet, satellite, cable and wireless mobile devices,
in International Class 45.
The application was refused registration as to all three classes under Sections 1,
2, and 45 of the Trademark Act, 15 U.S.C. § §§ 1051-53 and 1127, on the ground that
the proposed mark, as shown on the specimens of record, fails to function as a service
mark for the recited services, but conveys an informational message. After the
Trademark Examining Attorney made the refusal final, Applicant appealed and
requested reconsideration. After the Examining Attorney denied the request for
reconsideration, the appeal was resumed.
We affirm the refusal to register.
I. Evidentiary Matter
Applicant’s brief was accompanied by more than 100 pages described in the brief
as “Evidence from Non-Final Office Action of March 7, 2024” and “Evidence from
Final Office Action of October 10, 2024 Evidence from Non-Final Office Action of
March 7, 2024” [Exhibit A]; and “copies of registrations or the electronic equivalents
from the USPTO’s automated systems” [Exhibits B and C] “being submitted with this

Serial No. 98051678
- 3 -
Appeal Brief.”2 While the Examining Attorney did not specifically object to this
evidence, he also did not refer to it in his brief.
Trademark Rule 2.142(d) provides that “[t]he record in the application should be
complete prior to the filing of the appeal. Evidence should not be filed with the Board
after the filing of a notice of appeal.” 37 C.F.R. § 2.142(d); In re Inn at St. John’s, LLC,
No. 87075988, 2018 TTAB LEXIS 170, at *4 (“The evidence submitted with
Applicant’s appeal brief that Applicant did not previously submit during prosecution
... is untimely and will not be considered.”), aff’d mem., 777 F. App’x 516 (Fed. Cir.
2019). Because the attached exhibits are untimely and the Examining Attorney did
not treat the new evidence as of record, we have not considered them.3
II. Legal Standard for Failure to Function as a Service Mark
“Before there can be registrability, there must be a trademark (or a service mark)
and, unless words have been so used, they cannot qualify for registration.” In re
Standard Oil Co., 275 F.2d 945, 947 (CCPA 1960). Section 45 of the Trademark Act
defines a “service mark” in relevant part as “any word, name, symbol, or device, or
any combination thereof used by a person . . . to identify and distinguish the services
of one person, including a unique service, from the services of others and to indicate
the source of the services, even if that source is unknown.” 15 U.S.C. § 1127. “[T]he
2 6 TTABVUE 1, 4-6.
3 To the extent some of the evidence attached to the brief is already of record, it is duplicative
and also does not require separate consideration. See In re Info. Builders Inc., No. 87753964,
2020 TTAB LEXIS 20, at *5 n.4 (“Exhibits to briefs that merely duplicate evidence already
in the record are of little or no use in an ex parte proceeding. They are neither a convenience,
nor a courtesy.”).

Serial No. 98051678
- 4 -
source identifier requirement is broader than just whether a proposed mark is generic
or descriptive, and typically focuses on how the mark is used in the marketplace and
how it is perceived by consumers.” In re GO & Assocs., LLC, 90 F.4th 1354, 1356 (Fed.
Cir. 2024). “It is thus well-established that an applied-for mark that does not serve
as a source identifier fails to function as a trademark and should be refused federal
trademark registration.” In re Brunetti, 151 F.4th 1367, 1375 (Fed. Cir. 2025). The
registrability requirement that matter functions as a mark applies to service marks
as well as trademarks. In re TracFone Wireless, Inc., No. 87221529, 2019 TTAB
LEXIS 152, at *2-3.
“Failure to function” is an umbrella term because there are many reasons why a
proposed mark may not function as an indicator of source. In addition to the proposed
mark being merely informational, the proposed mark may be, for example, the title
of a single creative work, a trade name, or a model number.4 The informational failure
to function refusal itself has sub-categories, for example, the informational message
is a widely used or commonplace message, or merely conveys general information
4 See In re Cooper, 254 F.2d 611, 616 (CCPA 1958) (“As Teeny-Big is no more than the name
of a book, its only name, it is not a trademark under the statute, Section 2.”); In re Walker
Process Equip., Inc., 233 F.2d 329, 331 (CCPA 1956) (“It seems obvious, as was pointed out
by the Assistant Commissioner, that the words ‘Walker Process Equipment Inc.’ were
adopted primarily for the purpose of identifying the applicant and distinguishing it from
other producers of goods [as trade name] rather than for the purpose of identifying or
distinguishing its goods from those of other producers.”); SawStop, LLC v. Felder KG, No.
91255905, 2025 TTAB LEXIS 351, at *27 (“Again, this evidence shows PCS as part of the
respective model numbers for the saws, which appear in very small, non-stylized font under
descriptive wording, in stark contrast to what appears to be the actual source-indicating
matter (SawStop(R)), which is displayed in larger, stylized, red font at the top of the page
and is expressly designated as a registered trademark.”). See also THE TRADEMARK MANUAL
OF EXAMINING PROCEDURE (TMEP) § 1202.01-19 (Nov. 2025) and cases cited therein.

Serial No. 98051678
- 5 -
about the goods or services. See GO & Assocs., LLC, 90 F.4th at 1357 (“[T]he third-
party uses of the mark show that ‘everybody vs racism’ is commonly used in an
informational and ornamental manner on clothing items, tote bags, and other retail
items sold by third-parties to convey an anti-racist sentiment.”) (cleaned up);
Standard Oil Co., 275 F.2d at 947 (“Taken together, [the words GUARANTEED
STARTING] amount to no more than a sort of condensed announcement that the
applicant will guarantee the work done in order to insure the starting of the
customer’s car.”).
In this case, the Examining Attorney refused registration for failure to function
as informational on bases that the proposed mark: (1) merely conveys general
information about Applicant’s services and (2) is a widely used or commonplace
expression. More specifically, registration was refused because Applicant uses its
proposed mark NO LAW DEGREE REQUIRED in a “non-source-indicative manner”
to state its services navigate legal issues with “no fluff,” “just what you need to know,”
“easy to understand,” and with “no law degree required,” and because the proposed
mark NO LAW DEGREE REQUIRED is a commonplace expression “used to convey
the business sentiment that laypeople can make sense of laws without attending law
school and/or having a legal degree.”5 As discussed below, we find the record shows
that Applicant’s use of NO LAW DEGREE REQUIRED fails to function as a mark
because it is informational and merely conveys information about Applicant’s
business consultation, educational courses, and legal information services.
5 8 TTABVUE 3, 5.

Serial No. 98051678
- 6 -
A. Applicant’s Uses
In support of its three classes of services, Applicant’s specimens are described as
“web pages using the mark,” and comprise an excerpt from Applicant’s LinkedIn page
and its website:6 Applicant’s specimens indicate that Applicant offers “practical, bite-
sized, and easy to understand solutions to common legal issues” and courses with
“practical tips on business and legal.” Accordingly, we find Applicant’s business
consultation services, educational services, and legal information services provide the
same business and legal information services to clients in three different ways.
Moreover, because Applicant’s services are not limited to any particular
prospective client or purchaser, we find all three classes of Applicant’s services appeal
to members of the general public interested in business and legal information
services, whether offered in business consultation, educational courses, or legal
information services. See In re Pound Law, LLC, No. 87724338, 2022 TTAB LEXIS
398, at *8-9 (“In this case, because there are no limitations to the channels of trade
6 June 20, 2023 Specimen comprising three copies of the same webpages from LinkedIn and
one screenshot from Applicant’s website. A single specimen may support multiple classes.
Jean Patou, Inc. v. Theon, Inc., 9 F.3d 971, (Fed. Cir. 1993) (“[A]ppellant’s product has dual
uses, which place it near the borderline between ‘cosmetics’ and ‘pharmaceuticals.’ Believing
that naming two classes in its application somehow provides more ‘protection,’ applicant
named two classes in its application … [and] [t]en specimens, all the same, were filed, five
for each named class to comply with the rules.”). Accord In re Int’l Salt Co., No. 72286531,
1970 TTAB LEXIS 162, at *1-2 (“It is settled, moreover, that the owner of a trademark has a
right to register the trademark for a particular product in a plurality of classes covering the
different purposes or uses of the article that happen to fall within two or more classification
classes instead of the usual single class. … In those instances where the specimens are of a
general utility, and there is nothing on their surface or in the record to suggest that they
cannot possibly be used in connection with a product when employed for the purpose
enumerated, the examiner is obligated to accept the statement under oath in the application
that the specimens are so being used.”); TMEP § 904.01(b).

Serial No. 98051678
- 7 -
or classes of consumers, the relevant consuming public for legal and legal referral
services includes ordinary members of the general public.”). As used below, the
phrase NO LAW DEGREE REQUIRED is merely informational; that is, it is ordinary
language used to inform prospective consumers of the level of education necessary to
understand Applicant’s business and legal information which may be conveyed via
its business consultation services, its educational courses, and its legal information
services.
7
7 June 20, 2023 Specimen at TSDR 3. The full webpage was not submitted, the above excerpt
reflects the specimen.

Serial No. 98051678
- 8 -
8
We agree that the placement of NO LAW DEGREE REQUIRED amidst other
information about Applicant’s services supports the finding that Applicant’s use of
NO LAW DEGREE REQUIRED would be perceived as merely conveying information
about the level of education required for consumers of Applicant’s three classes of
services. See In re Brock Residence Inns, Inc., No. 73310690, 1984 TTAB LEXIS 90,
at *2, 5 (“[T]he phrase ‘FOR A DAY, A WEEK, A MONTH OR MORE!’, as applied to
applicant’s [hotel] services, is simply an ordinary informational statement about the
availability of rooms for various lengths of time and that it is not likely that
purchasers will ever perceive the phrase as an indicium of origin.”) (internal citation
omitted).
8 Id. at 2.

Serial No. 98051678
- 9 -
B. Third-Party Uses of NO LAW DEGREE REQUIRED
The evidence of record corroborates our finding that Applicant’s use of “no law
degree required” will be perceived as informing the prospective purchaser of the level
of education necessary to understand the business and legal information conveyed by
Applicant’s business consultation, educational courses, and legal information
services. “[T]he Board properly consider[s] both [Applicant’s] uses and third-party
uses when assessing how the public would likely perceive the mark.” GO & Assocs.,
90 F.4th at 1356. The third-party uses shown below demonstrate that NO LAW
DEGREE REQUIRED has an ordinary meaning that conveys that prospective
customers do not require legal training to understand legal concepts in an article or
publication (A-E), or to perform certain jobs in the legal field (F-K). Moreover, we find
this evidence to be directly relevant to Applicant’s services which are unrestricted in
how the consultation, education, and legal information services are performed, and
so may include the use of written materials, such as shown below. The evidence is
also directly relevant because Applicant’s services are unrestricted as to purpose, and
so may include the purpose of aiding job performance in the legal field.
A. Transcend Legal9
Thanks for learning about Transcend’s policies! Most of this is for the legal
teams of our business customers. Part of Transcend’s mission is help
companies be transparent about their data practices, and so we describe ours
plainly in our privacy center – no law degree required.
B. Insurance Law Essentials 10
Insurance Law Essentials provides you with valuable tools for insurance
coverage legal research. With the insight of the most respected insurance
9 March 7, 2024 Office Action TSDR 15.
10 Id. at 13.

Serial No. 98051678
- 10 -
coverage minds in the country at your fingertips, Insurance Law Essentials
will keep you informed of key legal trends from across the country – no law
degree required.
C. 09/03/24 Oracle Privacy Settlement Claim Guide11
A historic $115 million class action settlement has been reached in Katz-
Lacabe et al v. Oracle America, Inc., a data privacy lawsuit alleging tech giant
Oracle wrongfully compiled dossiers on millions of people’s online and offline
activities without consent. If you resided in the U.S. anytime from 2018•2024,
your rights may be impacted and you could get a cash payment.
This guide breaks down the key claims, settlement benefits, and how to file a
claim in simple terms anyone can understand – no law degree required!
D. The Pocket Lawyer for Filmmakers12
This no-nonsense reference provides fast answers in plain English with no law
degree required. It is designed to reduce legal costs by providing the vital
information you need to make informed decisions on the legal aspects of your
film, video, and TV productions.
E. Get smart on naming and branding – no law degree required!13
To be clear, I’m not an attorney, I’m in marketing. And as a marketer, I’ve
named a lot of different things over the years: products, services, ideas,
technologies, brands. All of these things need to be trademarked. So, I wanted
to share some of what I’ve learned about trademark law.
F. Shopcreativelaw.com/shop/the-consulting-agreement14
We passed the bar so you don’t have to
Customize Your template, no law degree required
…
Use confidently
Pop the completed contract into your CRM or on your site. Then sleep soundly
knowing you and your business are legally well taken care of.
G. No Law Degree Required15
You don’t have to be a lawyer to study law: GW Law offers the Master of
Studies in Law (MSL) degree for professionals who want to develop a crucial
11 October 10, 2024 Office Action TSDR 5.
12 Id. at TSDR 9.
13 Id. at TSDR 15.
14 Id. at TSDR 11.
15 March 7, 2024 Office Action 11.

Serial No. 98051678
- 11 -
understanding of the law that provides them with a competitive advantage in
high-demand fields.
H. No Law Degree Required16
This course sits within the UD School of Law and you will receive a Master of
Law degree (M.S.L.), but no GMAT, GRE, or LSAT is required for program
admission.
I. 05/11/23 5 Law-Related Jobs You Can Get Without Going To Law School17
Making sense of laws, rules and regulations sometimes requires a special set
of skills. If you’re someone who appreciates a good guideline, you might be a
match for one of these 5 law-related jobs – no law degree required.
J. 01/01/07 Patent Your Career18
As the patent boom continues unabated, career opportunities abound for
engineers – no law degree required
If you are looking for a position that exposes you to cutting edge technology
without becoming pigeon-holed into a specific technological field, then a
position in the ever-growing field of intellectual property (IP) support might be
for you. Law forms, businesses, and government entities are hiring engineers
in droves due to the patent filings boom over the last decade.
K. Court Records Research Without the Law Degree19
Court records are an underutilized genealogical resource. Join Kate Townsend
and discover how to explore courthouses (no law degree required) to find
records involving your ancestors.
L. What is Like Being a Lawyer But Not?20
…
As for actual suggestions, have you given any thought to compliance jobs? No
law degree required (though a bonus), very 9-5 and depending on the
industry, decent money too.
16 October 10, 2024 Office Action TSDR 13.
17 March 7, 2024 Office Action TSDR 9.
18 Id. at 17.
19 Id. at 5.
20 October 10, 2024 Office Action TSDR 7.

Serial No. 98051678
- 12 -
Applicant criticizes this evidence as insufficient in quantity to support the refusal
in all three classes.21 We disagree for two reasons. One, no particular quantity of
evidence is necessary. See TracFone Wireless, at *8 (“Although these examples are
few in number, the record supports a finding that UNLIMITED CARRYOVER as
used on the specimen will be perceived as merely an informational slogan which
conveys information about carrying over unlimited data from one
telecommunications billing cycle to the next rather than as a service mark to indicate
source.”). Indeed, an informational failure to function refusal may be upheld based
on the applicant’s own use of the proposed mark. See In re J. Hungerford Smith Co.,
279 F.2d 694, 695 (CCPA 1960) (“In holding that ‘Burgundy’ has not been shown to
have become distinctive of appellant’s flavoring syrup, the board relied primarily on
the ground that appellant has not used the word on such goods as a trademark but
only as a flavor designation. That conclusion appears to be borne out by the two
specimens submitted with appellant’s application.”).
Second, Applicant’s core activity for all three classes of services – as demonstrated
by its specimens as well as its identification of services – is providing business and
legal information, making the three classes of services in the subject application
closely related. In view of this, we disagree that the evidence showing third-party use
of NO LAW DEGREE REQUIRED in connection with providing business and legal
information in online publications and in connection with non-attorney positions in
the legal field is not relevant to all three classes of Applicant’s services.
21 6 TTABVUE 12, 15-16.

Serial No. 98051678
- 13 -
Applicant also contends that the substance of the third-party uses is not
relevant,22 and again we disagree. The third-party uses are offered to demonstrate
how the prospective purchaser of Applicant’s services of providing business and legal
information will perceive the proposed mark NO LAW DEGREE REQUIRED, and
the third-party uses do so using the term NO LAW DEGREE REQUIRED in
connection with providing business and legal information via online publications and
jobs in the legal field. We find the evidence of third-party use relevant to corroborate
that Applicant’s own use as shown in the specimens does not function as a mark, and
the record as a whole is sufficient to support the refusal as to each class in the
application.23
Applicant also argues that NO LAW DEGREE REQUIRED has non-informational
meanings, is not informational in all contexts, and the USPTO has “consistently”
registered similar marks.24 On the first point, Applicant contends that the “other”
meanings include:
the legal content has been created to be easily understood by someone without
a law degree,
the otherwise complex content is in fact accessible to the public,
the information has been simplified and is understandable, a person can
understand legal concepts.25
22 6 TTABVUE 12-15.
23 We also note that Applicant’s submission of multiple copies of the same webpage excerpt
as the specimens for its three classes of services is a recognition of the overlap between the
services.
24 6 TTABVUE 7.
25 6 TTABVUE 16-17.

Serial No. 98051678
- 14 -
Applicant does not cite a source for these meanings, and we find no significant
difference between them. Applicant provides no examples of NO LAW DEGREE
REQUIRED being used in any way but to convey that its business and legal
information services are directed to non-lawyers, and this is the same meaning
conveyed by the third-party examples provided by the Examining Attorney.
We agree with the second point, that NO LAW DEGREE REQUIRED may not be
informational in all contexts, without finding the point particularly relevant.
Whether, for example, the consumer of canned peas would see NO LAW DEGREE
REQUIRED on the can and perceive it as a mark is not the issue before us. Instead,
we assess the evidence that the term as used by Applicant will be perceived as a mark
by the relevant consumers of Applicant’s business and legal information services. See
In re Phoseon Tech., Inc., No. 77963815, 2012 TTAB LEXIS 306, at *19 (“The critical
question in determining whether SEMICONDUCTOR LIGHT MATRIX, as used in
the specimens of record, functions as a trademark is the commercial impression it
makes on the relevant public (e.g., whether the term sought to be registered would
be perceived as a mark identifying the source of the goods or merely as an
informational phrase)”); In re Melville Corp., No. 73393117, 1986 TTAB LEXIS 164,
at *4-5 (“In an environment where consumers are accustomed to the use by
merchants of similar informational phrases, we believe that consumers are not likely
to view applicant’s slogan [BRAND NAMES FOR LESS] as a service mark but rather
as a merchandising slogan using common ordinary words merely to convey
information about applicant’s [retail clothing store] services.”); In re Wakefern Food

Serial No. 98051678
- 15 -
Corp., No. 73259667, 1984 TTAB LEXIS 119, at *6 (“We fully agree with the
Examining Attorney that this relatively common merchandising slogan [WHY PAY
MORE! for supermarket services] does not act or function as a mark which identifies
and distinguishes applicant’s services from those of others … [but] would be perceived
as an expression suggesting that applicant’s stores offer lower food prices than others
while the SHOP RITE sign is likely to be seen as the sole indicator of origin.”).
Finally, on Applicant’s third point, as we discuss below, we are not persuaded
that the refusal of NO LAW DEGREE REQUIRED should be reversed in view of
third-party registrations for different marks identifying different goods and
services.
C. Third-Party Registrations of Other Marks
Applicant cites third-party registrations for marks with the phrase NO [blank]
REQUIRED as evidence that such marks are capable of functioning as marks and
obtained approval from the USPTO:26
26 6 TTABVUE 18. Because they do not demonstrate that the USPTO considered the phrase
registrable, we do not consider the third-party registrations in which the relevant terms were
disclaimed. (Reg. Nos. 6158769 and 4620120). April 6, 2025 Request for Reconsideration at
TSDR 90, 99. See Dena Corp. v. Belvedere Int’l, 950 F.2d 1555, 1560 (Fed. Cir. 1991) (“Under
the Lanham Act, an applicant with an ‘otherwise registrable’ composite mark may, by
disclaimer, avoid rejection due to an ‘unregistrable component’ of the mark.”). Nor do we
consider cancelled registrations (Reg. No. 4613132) or pending applications (App. Ser. Nos.
98551681, 97730210, 97603939, and 98817876). Id. at TSDR 62, 66, 68, 97. See Action Temp.
Servs Inc. v. Labor Force Inc., 870 F.2d 1563, 1566 (Fed. Cir. 1989) (“A cancelled
registration is not evidence of any presently existing rights in the mark shown or that
it was ever used.”); Weider Publ’ns, LLC v. D&D Beauty Care Co., No. 91199352, 2014 TTAB
LEXIS 2, at *43, appeal dismissed per stipulation, No. 14-1461 (Fed. Cir. Oct. 10, 2014) (The
“third-party applications submitted by applicant are of no probative value; they merely serve
to show the filing of each application.”).

Serial No. 98051678
- 16 -
Applicant relies on the third-party registrations summarized below:27
Reg. No.
3325418
issued
10/30/07
NO JACKET
REQUIRED
Containers, namely disposable beverage
cups
Reg. No.
3759315
issued
03/09/10
NO PASSPORT
REQUIRED
Clothing, namely, shirts and sweatshirts
Reg. No.
3960084
issued
05/10/11
NO SYRUP REQUIRED Frozen breakfast food, namely waffles
Reg. No.
4847775
issued
11/03/15
NO APPROVAL
REQUIRED
Clothing, namely, tops, bottoms, headwear,
Shirts; T-Shirts; Tank tops; Hooded
sweatshirts; Sweatshirts; Pajamas; Boxer
briefs; Panties; Hats
Reg. No.
6903115
issued
11/15/22
THINK OUTSIDE. NO
BOX REQUIRED.
Hats
Reg. No.
6329415
issued
04/20/21
Beef; frozen appetizers consisting primarily
of chicken or seafood
Frozen foods, namely, grain and bread
based appetizers, hors d'oeuvres, and
canapés; pastries
Reg. No.
6804298
issued
07/26/22
CELEBRITY NOT
REQUIRED
Alcoholic beverages, except beer
Reg. No.
6945456
issued
01/10/23
Planning and arranging of wedding
ceremonies
27 April 6, 2025 Request for Reconsideration at TSDR 62-102.

Serial No. 98051678
- 17 -
Reg. No.
6999995
issued
03/14/23
Popcorn; Processed unpopped popcorn;
Unpopped popcorn on the cob; Flavor-
coated popped popcorn
Reg. No.
7579818
issued
11/26/24
NO BITES REQUIRED Flea and tick treatment preparations for
pets, namely, sprays, powders, and mists;
insecticides for domestic use, namely, flea
and tick preparations in the form of sprays,
powders, and mists for use on yards,
domestic areas, pet habitats, carpets,
upholstery, and pet bedding; medicated
grooming products for pets, namely,
medicated shampoos
Reg. No.
7642524
issued
01/07/25
THE UNIVERSITY
EXPERIENCE NO
CAMPUS REQUIRED
Educational services, namely, providing
courses of instruction at the university
level, namely, at the undergraduate,
graduate and post-graduate program level
and distribution of course material in
connection therewith
We find these marks distinguishable. In the field of business and legal
information, there is a requirement for a law degree in conveying certain types of
business and law information. We take judicial notice that a law degree, or juris
doctor, is “a degree conferred by a law school usually after three years of full-time
study.”28 As applied to Applicant’s various business and legal information services,
NO LAW DEGREE REQUIRED conveys factual information relevant to the
28 Merriam-Webster.com Dictionary, https://www.merriam-webster.com/dictionary/
Juris%20Doctor. Accessed 15 Jan. 2026. The Board may take judicial notice of dictionary
definitions, including online dictionaries that exist in printed format or have regular fixed
editions. In re Cordua Rests. LP, No. 85214191, 2014 TTAB LEXIS 94, at *6 n.4, aff’d, 823
F.3d 594 (Fed. Cir. 2016).

Serial No. 98051678
- 18 -
prospective consumer of the services. We do not have similar facts regarding the
requirements of the goods and services listed in the third-party registrations, and so
lack the necessary context to assess why these registrations issued. As a result, we
are not persuaded that the third-party registrations support registration of
Applicant’s mark.
Applicant also contends that some third-party registrations “are more applicable
than others,” and directs our attention to four third-party registrations for NO [blank]
REQUIRED marks and webpage excerpts showing use of the registered term.
Reg. No. 6449410 issued 08/10/2129
NO GYM REQUIRED for “exercise machines”
Reg. No.5062667 issued 10/18/1630
NO PASSPORT REQUIRED for “Providing a web site featuring travel
information and commentary”
Reg. No.5052126 issued 10/04/1631
NO RECIPE REQUIRED for “providing an online website that provides
cooking and culinary information”
Reg. No. 5693316 issued 03/05/1932
NO BOSS REQUIRED for “Providing online professional and business
networking services and employment information in the fields of employment
hiring, recruitment, job resources and job listings” and “Computer services,
namely, creating an on-line community for registered users to organize groups
and events, participate in discussions, share information and resources, get
feedback from their peers and engage in social, business and community
networking; providing temporary use of a non-downloadable web application
and mobile web application for registered users to organize groups and events,
participate in discussions, share information and resources, get feedback from
their peers and engage in social, business and community networking”
29 Id. at TSDR 84.
30 Id. at TSDR 87.
31 Id. at TSDR 92.
32 Id. at TSDR 76.

Serial No. 98051678
- 19 -
The addition of the evidence of use33 of the same phrases registered in the four
registrations does not support Applicant’s argument that the USPTO registers the
phrase NO [blank] REQUIRED when it conveys information about the goods and
services. There is no evidence, and Applicant does not argue, that any of the four
registrants had any connection to the uses, or that any of the uses were known to the
Examining Attorney at the time the marks were approved for registration. The
evidence that a term was used in an informational way is not relevant to the record
before the USPTO when the term was approved for registration as a mark.
In sum, the evidence of record supports the failure to function refusal because the
specimens show that Applicant uses NO LAW DEGREE REQUIRED to convey the
information that prospective customers for its business consultation services,
educational courses, and legal information services do not need legal training, and
third-party uses show the term used for the same purpose for closely related goods
and services also offering business and legal information.34
III. Decision:
The refusal to register Applicant’s proposed mark NO LAW DEGREE REQUIRED
is affirmed in all classes.
33 Id. at TSDR 23-61.
34 In view of this determination, we need not reach the commonplace message basis for the
informational refusal.