91291853•Coachella Music Festival, LLC v. Marjorie Ulysse
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WDJ September 22, 2026 Opposition No. 91291853 Coachella Music Festival, LLC v. Marjorie Ulysse Before Wellington, Larkin, and Casagrande, Administrative Trademark Judges. By the Board: This proceeding now comes before the Board for consideration of (1) Opposer’s motion for partial summary judgment on its claim that Applicant did not have a bona fide intent to use her SLAYCHELLA mark in commerce as of the filing date of her application, in violation of Trademark Act Section 1(b), 15 U.S.C. § 1051(b), and for discovery sanctions;1 (2) Applicant’s cross-motion for partial summary judgment on Opposer’s claim of likelihood of confusion under Trademark Act Section 2(d), 15 U.S.C. § 1052(d);2 and (3) Opposer’s motion to strike Applicant’s evidence in support of her opposition to Opposer’s motion for partial summary judgment.3 All three 1 18 TTABVUE. 2 22 TTABVUE. 3 25 TTABVUE. UNITED STATES PATENT AND TRADEMARK OFFICE Trademark Trial and Appeal Board P.O. Box 1451 Alexandria, VA 22313-1451 General Contact Number: 571-272-8500 THIS ORDER IS NOT A PRECEDENT OF THE TTAB
Opposition No. 91291853 2 motions are fully briefed.4 Applicant also has filed a motion for leave to amend her application without consent,5 which Opposer opposes.6 I. Opposer’s Motion for Discovery Sanctions a. Background and the Parties’ Arguments Opposer has moved pursuant to Rule 37(b)(2) and 37 C.F.R. § 2.120(h)(1) to preclude Applicant from entering into evidence at trial or on summary judgment certain documents for which Applicant failed to produce metadata as ordered by the Board, as well as certain documents Applicant has withheld while asserting she has produced all documents in her possession, custody, or control. In particular, Opposer seeks to preclude the following evidence first produced as attachments to Applicant’s response to Opposer’s motion for summary judgment:7 (1) the Declaration of Marjorie Ulysse;8 (2) Ulysse Declaration Exhibit A (whois data for website);9 (3) Ulysse Declaration Exhibit C (text message screenshots concerning draft website);10 (4) Ulysse Declaration Exhibit D (brochure for unrelated 2025 event);11 and (5) the Declaration of Adam Allen, who was not identified in Applicant’s initial disclosures, which she has not supplemented.12 4 Opposer filed its reply in support of its motion for summary judgment under seal. 24 TTABVUE. An unredacted version of the reply brief appears at 25 TTABVUE. 5 16 TTABVUE. 6 See 29 TTABVUE 3. 7 See 25 TTABVUE 4. 8 21 TTABVUE 19-21, ¶¶ 1-17. 9 Id. at 22-25. 10 Id. at 31-33. 11 Id. at 34-48. 12 Id. at 49-56, ¶¶ 1-9.
Opposition No. 91291853 3 In support of its motion Opposer avers as follows. The day discovery opened, Opposer served a request for production that sought all documents concerning Applicant’s bona fide intent to use the SLAYCHELLA mark as of the filing date of the opposed application.13 Opposer also requested all versions of Applicant’s website, including any portions that have used the opposed mark.14 In response, Applicant produced three screenshots of a draft website.15 However, Applicant did not provide the requested files in their native electronic format as requested by Opposer, an instruction to which Applicant had not objected.16 In both her discovery responses and later her opposition to Opposer’s motion to compel, Applicant asserted that she did not have custody of any metadata, such as the creation and revision dates for the produced draft website screenshots, or other draft website documents besides the three screenshots she had produced.17 On December 17, 2024, Opposer filed a motion to compel,18 which the Board granted on March 31, 2025.19 The Board ordered Applicant to produce certain metadata concerning her draft website, which would include creation and revision dates and the content of those revisions, by April 30, 2025, or to produce an affidavit stating that she does not have that metadata in her possession, custody, or control.20 Applicant subsequently produced an affidavit stating that Applicant “confirm[s] that 13 5 TTABVUE 15. 14 Id. 15 Declaration of Steven Lauridsen, counsel for Opposer, 18 TTABVUE 72, ¶ 6, Ex. 7. 16 See 5 TTABVUE 15-16. 17 9 TTABVUE 16; 5 TTABVUE 234-36 (Request for Production Nos. 49-50); 7 TTABVUE 10. 18 5 TTABVUE. 19 9 TTABVUE. 20 Id. at 16,
Opposition No. 91291853 4 the metadata sought by Opposer Coachella Music Festival, LLC (‘Opposer’) of my draft website for the SLAYCHELLA mark is not in my possession, custody, or control.”21 The declaration is silent as to who might have custody or control of the metadata.22 Applicant’s declaration also states that she has no other responsive documents and has produced all documents.23 Because Applicant’s declaration was silent on the issue of who had custody or control over the requested metadata, Opposer’s counsel followed up via email with Applicant’s counsel on April 30, 2025.24 On May 2, 2025, Applicant’s counsel responded, stating that “Applicant does not know where and under whose control the metadata presently is but is actively trying to gain access to her WIX website account25 to obtain additional information in order to supplement Applicant’s discovery responses.”26 Applicant’s counsel also stated that “[w]e have further attached to this email the native JPEG files of the pdfs previously produced as bates numbers SLAYCHELLA00012-00014. These JPEG screenshots were taken of Applicant’s WIX website account in response to Opposer’s discovery requests to identify Applicant’s intended use of the SLAYCHELLA mark.”27 Applicant’s counsel added that “[w]e are still searching for additional information about when that draft 21 Lauridsen Decl., 18 TTABVUE 73, ¶ 8, Ex. 8, Declaration of Marjorie Ulysse, ¶ 2. 22 See Lauridsen Decl., 18 TTABVUE 73, ¶ 8, Ex. 8, Declaration of Marjorie Ulysse, ¶¶ 1-4. 23 Lauridsen Decl., 18 TTABVUE 73, ¶ 8, Ex. 8, Declaration of Marjorie Ulysse, ¶¶ 3-4. 24 Lauridsen Decl. 18 TTABVUE 73, ¶ 9, Ex. 9. 25 WIX is “a cloud-based platform that allows a person to build professional sites without the need of coding experience.” Declaration of Marjorie Ulysse, 21 TTABVUE 19, ¶ 5. 26 Lauridsen Decl. 18 TTABVUE 73, ¶ 10, Ex. 10. 27 Id.
Opposition No. 91291853 5 webpage was first created, but we have been unable to do so up to this point. We will produce additional information if it becomes available.”28 According to Opposer, the WIX website explains how a user can readily access the sought-after metadata in their website account, including creation dates, revision dates, publication dates, and the content of any revisions.29 Opposer claims that, as a result, Applicant has always had access to the Board-ordered metadata and to all versions of her draft website. Opposer further argues that Applicant knew that WIX had control over the metadata. Opposer asserts that Applicant chose to remain silent concerning that fact despite the Board’s order to provide in detail in her affidavit information concerning where and in whose custody the metadata resides. Opposer contends that Applicant should not be rewarded for disobeying a Board order, and that she should therefore be precluded as a discovery sanction from relying on the purported draft website at trial or on summary judgment. Applicant counters that she has acted in good faith in her efforts to provide Opposer with the requested information. On August 12, 2024, Opposer served on Applicant its initial disclosures, and first sets of requests for production, interrogatories, and requests for admission.30 Applicant served objections and responses to each request and produced twenty-eight pages of documents comprising the TSDR status and file history for the involved application, screenshots of what Applicant asserts is a draft of her website as displayed in a web browser, and the 28 Id. 29 Id. at ¶ 11, Ex. 11. 30 9 TTABUVE 2-3.
Opposition No. 91291853 6 notice of opposition in this proceeding. During a discovery conference held on November 13, 2024, Opposer’s counsel requested that Applicant provide the native file with metadata intact for the SLAYCHELLA website, of which she had produced a screenshot.31 Applicant responded that she had produced all documents or information in her custody, possession, or control, and that she did not have such metadata. Opposer then filed its motion to compel, which was granted by the Board, after which Applicant produced the affidavit stating that Applicant “confirm[s] that the metadata sought by Opposer Coachella Music Festival, LLC (‘Opposer’) of my draft website for the SLAYCHELLA mark is not in my possession, custody, or control.”32 Applicant claims that, upon additional investigation conducted by Applicant’s counsel, it was determined that Lease My Marketing, a professional marketing company hired by Applicant,33 and not Applicant, was in control of the WIX platform and had access to the SLAYCHELLA page on Applicant’s website. Applicant’s counsel requested the metadata concerning the creation the web page, and Lease My Marking agreed to access the WIX platform and provide any information about the page.34 Lease My Marketing was unable to provide the metadata for the page, but was able to provide the site history, which shows publication, revisions, and removals of the 31 9 TTABVUE 4. 32 Lauridsen Decl., 18 TTABVUE 73, ¶ 8, Ex. 8, Declaration of Marjorie Ulysse, ¶ 2. 33 See Ulysse Decl., 22 TTABVUE 23, ¶ 14. 34 Declaration of Adam Allen, owner of Lease My Marketing, 21 TTABVUE 50, ¶ 3.
Opposition No. 91291853 7 page.35 That information was made available to Applicant on September 23 and 24, 2025.36 Applicant notes that Opposer did not undertake any independent efforts to obtain the information from the WIX platform, which Applicant contends Opposer could have done at any point in this proceeding given it knew the identity of the host platform. Rather, Applicant claims that Opposer seeks to profit from its lack of inquiry by preventing truthful, highly relevant information from being introduced in this proceeding. b. Analysis If a party fails to comply with an order of the Board relating to discovery, including an order compelling discovery, the Board may enter appropriate sanctions as defined in Trademark Rule 2.120(h)(1), 37 C.F.R. § 2.120(h)(1), and Fed. R. Civ. P. 37(b)(2), including entry of judgment. Benedict v. Super Bakery Inc., 665 F.3d 1263, 1268-69 (Fed. Cir. 2011) (affirming Board’s entry of judgment as a discovery sanction for repeated failures to comply with Board’s reasonable orders); MHW Ltd. v. Simex Aussenhandelsgesellschaft Savelsberg KG, No. 91093359, 2000 WL 33416861, at *2 (TTAB 2000); HighBeam Mktg., LLC v. Highbeam Rsch., LLC, No. 91162372, 2008 WL 219142, at *1 (TTAB 2008); TBMP § 527.01(a). Application of Fed. R. Civ. P. 37(b)(2) is triggered only by the violation of a discovery order. Fed. R. Civ. P. 37(b)(2)(A). The question of the proper sanction is left to the sound discretion of the Board. See Ingalls Shipbuilding, Inc. v. U.S., 857 F.2d 1448, 1450-51 (Fed. Cir. 1988). 35 See id. at 50-52, ¶¶ 5-8. 36 Id. at 52, ¶ 9.
Opposition No. 91291853 8 When considering which sanctions to impose, the Board may consider “(1) the willfulness of the non-compliant party or the reason for noncompliance; (2) the efficacy of lesser sanctions; (3) the prejudice to the other party; (4) the duration of the period of noncompliance; and (5) whether the non-compliant party has been warned of the consequence of his non-compliance.” Handwerker v. AT & T Corp., 211 F.R.D. 203, 208 (S.D.N.Y. 2002); see also Lee v. Max Int’l, LLC, 638 F.3d 1318, 1323 (10th Cir. 2011) (listing factors for dismissal as a sanction). Upon review of Applicant’s responses to Opposer’s inquiries regarding the website metadata, it is clear that Applicant did not willfully disobey the Board’s discovery order. Indeed, Applicant’s counsel affirmatively stated that he did not know where and under whose control the metadata was, and that he was still searching for the information and would provide it if it became available.37 Also, there is no other indication of Applicant’s non-compliance with the Board’s discovery order. Furthermore, it would be unduly harsh to exclude evidence produced for the first time on summary judgment, given that Applicant did not unequivocally refuse to produce the requested information during discovery, and that discovery responses may be supplemented at any time. See Vignette Corp. v. Marino, No. 91158854, 2005 WL 3395186, at *4 (TTAB 2005); see also Weatherford/Lamb, Inc. v. C&J Energy Servs., No. 92050101 2010 WL 4502073, at *3 (TTAB 2010) (declining to strike admissible declarations and attached exhibits, choosing “to evaluate all the declarants’ statements and exhibits for appropriate probative value, and to weigh the evidence 37 18 TTABVUE 154.
Opposition No. 91291853 9 in its totality”). There is also no prejudice to Opposer in view of the fact that discovery responses may be supplemented at any time. Therefore, to the extent Opposer seeks to exclude Applicant from offering as evidence information or documents produced subsequent to her April 30, 2025 affidavit in violation of the Board’s discovery order, Opposer’s motion for sanctions pursuant to Fed. R. Civ. P. 37(b)(2) is DENIED. II. Opposer’s Motion to Strike As Applicant points out, Opposer’s only reference in its motion to strike to such a motion is the statement “[i]n addition to seeking these self-executing preclusion sanctions [pursuant to Fed. R. Civ. P. 37(b)(2)], Coachella also moves to strike these materials by way of this brief.”38 The Board construes this as a motion pursuant to Fed. R. Civ. P. 37(c)(1), which provides that a party who fails to provide information requested during discovery may, upon motion or objection by his adversary, be precluded from using that information upon a motion for summary judgment, unless the failure was substantially justified or is harmless. Fed. R. Civ. P. 37(c)(1); Vignette Corp., 2005 WL 3395186, at *3. Opposer’s motions pursuant to Fed. R. Civ. P. 37(b)(2) and Fed. R. Civ. P. 37(c)(1) are based upon the same set of operative facts. Parties are required to supplement their respective initial disclosures and discovery responses “in a timely manner if the party learns that in some material respect the disclosure or response is incomplete or incorrect and if the additional or corrective information has not otherwise been made known to the other parties during the discovery process or in writing.” Fed. R. Civ. P. 26(e)(1)(A); Trademark 38 25 TTABVUE 5.
Opposition No. 91291853 10 Rules 2.116(a) and 2.120, 37 C.F.R. §§ 2.116(a) and 2.120. A party may supplement its discovery responses at any time, even after a summary judgment motion or during trial. Vignette Corp., 2005 WL 3395186, at *4. Subsections 37(b)(2) and 37(c)(1) of Fed. R. Civ. P. 37 differ in that 37(c)(1) may be triggered where the automatic, self-executing discovery provisions of Rule 26(a) and 26(e) are violated, whereas the imposition of sanctions under Rule 37(b)(2) requires the violation of a discovery order as a prerequisite. See Ortiz-Lopez v. Sociedad Espanola de Auxilio Mutuo Y Beneficiencia de Puerto Rico, 248 F.3d 29, 33 (1st Cir. 2001). The Board in Vignette Corp. held that absent “an outright statement that ... information would not be provided” in response to a discovery request, the Board need not exclude consideration of that information with respect to a motion for summary judgment. Vignette Corp., 2005 WL 3395186, at *4 (finding it would be “unduly harsh” to exclude evidence produced for the first time on summary judgment, absent an unequivocal refusal to produce the requested information during discovery, particularly in light of the fact that discovery responses may be supplemented at any time). The Board further explained that there is “no practical distinction between consideration of the information provided as part of a responsive brief to a summary judgment motion or information provided in supplemental responses to discovery that are submitted at the same time as a responsive brief.” Id. Here, in her responses to Opposer’s inquiries regarding the website metadata, Applicant did not state unequivocally that such information would not be provided.
Opposition No. 91291853 11 Rather, Applicant’s counsel affirmatively stated that he did not know where and under whose control the metadata was, and that he was still searching for the information and would provide it if it became available.39 Based on the record before us, Applicant should not be precluded from relying on the website information pursuant to Fed. R. Civ. P. 37(c)(1). See Vignette Corp., 2005 WL 3395186, at *4. Accordingly, to the extent Opposer seeks to strike evidence produced subsequent to Applicant’s April 30, 2025 affidavit, Opposer’s motion also is DENIED. III. Background – Cross-Motions for Summary Judgment Applicant Marjorie Ulysse, a United States citizen, is the owner of intent-to-use application Serial No. 98123640 for the standard character mark SLAYCHELLA for use in connection with the following goods and services: Key chains, in International Class 14; Mugs; Beverage glassware; Drinking cups; Heat-insulated containers for beverages; Insulated containers for beverage cans for domestic use, in International Class 21; Dresses; Pants; Shirts; Shoes; Skirts; Coats; Fashion hats; Men’s and women’s jackets, coats, trousers, vests; Suits, in International Class 25; and Arranging and conducting of seminars and workshops in the field of harassment; Educational and entertainment services, namely, providing motivational speaking services in the field of harassment; Educational and entertainment services, namely, providing motivational and educational speakers in the field of self- and personal improvement; Entertainment services, namely, providing podcasts in the field of fashion and culture; On-line journals, namely, blogs featuring fashion and culture; Providing continuing legal education courses, in International Class 41. Applicant filed her application on August 9, 2023. 39 18 TTABVUE 154.
Opposition No. 91291853 12 Opposer Coachella Music Festival, LLC, a Delaware limited liability company, has opposed registration, asserting claims of (1) likelihood of confusion under Trademark Act Section 2(d), 15 U.S.C. § 1052(d); (2) false association under Trademark Act Section 2(a), 15 U.S.C. § 1052(a); and (3) no bona fide intent to use the mark in connection with the goods and services identified in her application as of the application filing date under Trademark Act Section 1(b), 15 U.S.C. § 1051(b).40 In support of its claims Opposer pleads ownership of the following registrations: Reg. No. Mark Goods/Services 3196119 COACHELLA (Section 2(f)) Entertainment, namely, organizing and producing musical events, in International Class 41 3196128 COACHELLA VALLEY MUSIC AND ARTS FESTIVAL (Section 2(f), “MUSIC AND ARTS FESTIVAL” disclaimed) Entertainment, namely, organizing and producing musical events, in International Class 41 3196129 (Section 2(f)) Entertainment, namely, organizing and producing musical events, in International Class 41 3965563 COACHELLA VALLEY MUSIC AND ARTS FESTIVAL (Section 2(f)) Tote bags in International Class 18 4008651 COACHELLA VALLEY MUSIC AND ARTS FESTIVAL (Section 2(f)) Posters in International Class 16; and Halter tops; Hooded sweat shirts; Long- sleeved shirts; Scarves; Shirts; T-shirts; Tank tops, in International Class 25 40 See First Amended Notice of Opposition, 17 TTABVUE.
Opposition No. 91291853 13 4266400 (Section 2(f)) Posters in International Class 16; and Hooded sweat shirts; Long-sleeved shirts; Scarves; Shirts; T-shirts; Tank tops, in International Class 25 4270482 COACHELLA (Section 2(f)) Posters in International Class 16; Bottles, sold empty; Plastic water bottles sold empty, in International Class 21; and Hooded sweat shirts; Long-sleeved shirts; Scarves; Shirts; T-shirts; Tank tops, in International Class 25 5075233 CHELLA Long-sleeved shirts; Shirts; T-shirts, in International Class 25 5235903 (Section 2(f)) Hotel accommodation services; Providing campground facilities, in International Class 43 5235905 COACHELLA (Section 2(f)) Hotel accommodation services; Providing campground facilities, in International Class 43 5520063 CHELLA Arranging, organizing, conducting, and hosting social entertainment events; Entertainment, namely, production of musical events; Organizing cultural and arts events, in International Class 41 5557242 COACHELLA Jewelry; Jewelry charms, in International Class 14 Opposer also claims common law rights in the marks COACHELLA, COACHELLA (stylized), COACHELLA VALLEY MUSIC AND ARTS FESTIVAL, and CHELLA in connection with its Coachella Music Festival, related music and arts events, and related goods and services.41 41 See First Amended Notice of Opposition, 17 TTABVUE 2-4, ¶¶ 1-7; Declaration of Jason Bernstein, 18 TTABVUE 20, ¶ 7.
Opposition No. 91291853 14 IV. Summary Judgment Standard Summary judgment is an appropriate method of disposing of cases in which there are no genuine disputes as to material facts, thus allowing resolution as a matter of law. See Fed. R. Civ. P. 56(a). The burden is on the party moving for summary judgment to demonstrate the absence of any genuine dispute of material fact and that it is entitled to summary judgment as a matter of law. Fed. R. Civ. P. 56(c). In considering the propriety of summary judgment, all evidence must be viewed in the light most favorable to the non-movant, and all justifiable inferences are to be drawn in the non-movant’s favor. See Lloyd’s Food Prods., Inc. v. Eli’s, Inc., 987 F.2d 766, 767 (Fed. Cir. 1993). The Board does not resolve disputes of material fact when determining a motion for summary judgment but rather only ascertains whether disputes of material fact exist. See Univ. Book Store v. Bd. of Regents of Univ. of Wis. Sys., No. 91084223, 1994 WL 747886, at *4 (TTAB 1994); see also Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986) (“[A]t the summary judgment stage the judge’s function is not … to weigh the evidence and determine the truth of the matter but to determine whether there is a genuine issue for trial.”). When a moving party’s motion for summary judgment is supported by evidence sufficient to indicate that there is no genuine dispute as to any material fact and that the moving party is entitled to judgment as a matter of law, the burden shifts to the non-moving party to demonstrate the existence of at least one genuine dispute as to a material fact that requires resolution at trial. The non-moving party may not rest on the mere allegations of its pleadings and assertions of counsel, but must designate
Opposition No. 91291853 15 specific portions of the record or produce additional evidence showing the existence of a genuine dispute of material fact for trial. Consequently, factual assertions without evidentiary support are insufficient to defend against a motion for summary judgment. See, e.g., Hornblower & Weeks Inc. v. Hornblower & Weeks Inc., No. 91110043, 2001 WL 1512024, at *8 (TTAB 2001) (“[A]pplicant has produced no evidence, or raised any expectation that at trial it could produce evidence ....”); see also Johnston v. Ivac Corp., 885 F.2d 1574, 1578 (Fed. Cir. 1989) (“In light of IVAC’s evidence that limitations of the claims could not be found in its devices at all, AMEC had the burden of coming forward with sufficient countering evidence. Mere assertion of similarity in the accused and patented devices is insufficient to create a genuine factual issue.”). Nonetheless, the burden of the non-movant to respond arises only if the summary judgment motion itself is properly supported. Adickes v. S.H. Kress & Co., 398 U.S. 144, 160-61 (1970). If the summary judgment motion is not properly supported, “summary judgment must be denied even if no opposing evidentiary matter is presented.” Id. (quoting Fed. R. Civ. P. 56 Advisory Committee Notes to the 1963 amendments). A party may submit affidavits or declarations in support of, or in opposition to, a motion for summary judgment, provided that the declarations are “made on personal knowledge, set out facts that would be admissible in evidence, and show that the affiant or declarant is competent to testify on the matters stated.” Fed. R. Civ. P. 56(c)(4); Ava Ruha Corp. v. Mother’s Nutritional Ctr., Inc., No. 92056067, 2015 WL
Opposition No. 91291853 16 496141, at *2 (TTAB 2015). This is so even though affidavits and declarations are self-serving in nature and there is no opportunity for cross-examination of the affiant or declarant. See Paris Glove of Can. Ltd. v. SBC/Sporto Corp., No. 92044132, 2007 WL 2422997, at *9 n.8 (TTAB 2007), abrogated on other grounds by Safer, Inc. v. OMS Invs., Inc., No. 91176445, 2010 WL 985355 (TTAB 2010). Moreover, an affiant or declarant may testify based on his or her personal knowledge from a review of the contents of files and records. Ava Ruha Corp., 2015 WL 496141, at *2. Even if not supported by documentary evidence, an affidavit or declaration may nevertheless be given consideration if the statements contained therein are clear and uncontradicted. See, e.g., See Liqwacon Corp. v. Browning-Ferris Indus., Inc., No. 91058871, 1979 WL 24857, at *15 (TTAB 1979); GAF Corp. v. Anatox Analytical Servs., Inc., No. 91056180, 1976 WL 21153, at *1 (TTAB 1976). The Board will not presume missing facts, and conclusory assertions in declarations are not sufficient to support or undermine a claim. Lujan v. Nat’l Wildlife Fed’n, 497 U.S. 871, 888-89 (1990). If the affidavit or declaration raises a genuine dispute of material fact, the Board must deny the motion for summary judgment. Olde Tyme Foods, Inc. v. Roundy’s, Inc., 961 F.2d 200, 202 (Fed. Cir. 1992). V. Opposer’s Motion for Summary Judgment A. The Parties’ Arguments and Evidence Opposer asserts that there is no dispute of material fact that no documentary evidence exists to demonstrate Applicant’s bona fide intent to use the SLAYCHELLA mark in commerce in association with any of the goods or services identified in her
Opposition No. 91291853 17 application as of the application’s filing date, and Opposer is therefore entitled to judgment as a matter of law. Opposer first argues that the screenshots of Applicant’s website fail to evidence Applicant’s bona fide intent to use the mark in association with the goods and services identified in the application as of the application filing date. The SLAYCHELLA application claims goods such as clothing, keychains, and coffee mugs, as well as educational and entertainment services on a wide variety of topics including harassment, fashion, self improvement, and legal education.42 However, Opposer asserts that none of these goods or services are described or even alluded to on Applicant’s draft website.43 Opposer notes that there is no link to or mention of a store, nor is Applicant or any other featured individual wearing SLAYCHELLA branded clothing or drinking out of a SLAYCHELLA branded cup.44 Opposer further argues that there also is no mention of any seminar, class, or speaking event of any kind, or news alert on the release of a podcast or blog or even where one could be found.45 Opposer asserts that instead the screenshots use platitudes and buzzwords to paint an amorphous picture of a state of self. Opposer argues that the screenshots associate SLAYCHELLA with “a transformative state of…self,” a place “where you can redefine success on your own terms,” an invitation to “foster an environment where innovation and individuality thrive,” and “a community bound by shared 42 Declaration of Steven E. Lauridsen, counsel for Opposer, 18 TTABVUE 73, ¶ 5 Ex. 6. 43 See id. at ¶ 6, Ex. 7. 44 Id. 45 Id.
Opposition No. 91291853 18 values, aspirations, and experiences” rather than goods or educational and entertainment services.46 Opposer argues that, because the screenshots merely evidence an intent to reserve a right in the mark, they do not evidence Applicant’s bona fide intent to use the mark in commerce in connection with the goods and services identified in the SLAYCHELLA application. Opposer further argues that, by demonstrating a lack of documentary evidence concerning intent, it has shown that there is no genuine dispute of material fact concerning intent, and as a result Opposer is entitled to judgment as a matter of law. In support of its motion Opposer has submitted the declarations of Jason Bernstein, Vice President and Assistant General Counsel for AEG Presents, LLC, the parent company of Opposer,47 and Steven E. Lauridsen, counsel for Opposer.48 In response, Applicant has submitted her declaration49 and avers as follows. Applicant is an employment law litigator with over 20 years of experience with a particular focus on sexual harassment cases.50 Over the course of her career, she has earned the nickname “the harassment slayer.”51 In May 2023, Applicant decided to leave her law firm to join another.52 46 See id. 47 18 TTABVUE 19. 48 Id. at 72. 49 21 TTABVUE 19. 50 Id. at ¶ 2. 51 Id. at ¶ 3. 52 Id. at ¶ 4.
Opposition No. 91291853 19 In May of 2023, Applicant secured the domain name marjoriemesidor.com to create a landing page for her media posts and general information about her. Applicant hired a personal assistant to help her build a website.53 The initial templates of the website were built by her assistant using WIX, a cloud-based platform that allows a person to build professional websites without the need for coding experience.54 Applicant avers that, at the outset, the plan was to build a website that promoted Applicant as a subject matter expert, but Applicant also wanted to develop her brand name that highlighted other services that were more tangential to her legal professional services.55 Applicant decided on the name “Slaychella” for her brand that would promote her other, non-legal services, including setting up workshops, speakers, and seminars that focus on issues of harassment, as well as self-empowerment, since that is often part of the healing process for a survivor of harassment.56 Applicant claims that the reasons she selected the name are two-fold. First, Applicant wanted to build off her original professional nickname, “the harassment slayer,” hence the name “slay.” Second, Applicant wanted the brand to have a personal meaning as well, so she selected “chella,” which was a nickname given to her by her childhood friends.57 Under this brand name, Applicant anticipated offering seminars and workshops in the field of harassment, along with motivational speaking, podcasts, and 53 Id. at ¶ 4, Ex. A. 54 Id. at ¶ 5. 55 Id. at ¶ 6. 56 Id. at ¶ 7. 57 Id. at 20, ¶ 8.
Opposition No. 91291853 20 continuing legal education courses in the field of harassment.58 Applicant asserts that the goods that she intended to offer under the SLAYCHELLA Mark are typical merchandise products sold to promote and advertise the primary services offered under a trademark.59 To protect her developing brand, Applicant filed an intent-to-use application on August 9, 2023 seeking to register the SLAYCHELLA mark.60 At or around the same time, Applicant’s assistant put together an initial draft of the website that would be launched on marjoriemesidor.com. The website included a single page dedicated to SLAYCHELLA for promoting self-empowerment, uniqueness, and community.61 This subpage had a unique URL address of: www.marjoriemesidor.com/projects-8. Applicant asserts that the term “Projects” serves as a clear indication of the development of the webpage.62 The “Site History” from WIX associated with the SLAYCHELLA page shows that the page was published on August 13, 2023.63 On August 28, 2023, as part of her rebranding process, Applicant sent her colleagues, Susan Crumiller and Carrie Goldberg, a link to the website in progress, www.marjoriemesidor.com, which displayed the SLAYCHELLA tab.64 Ms. Goldberg gave specific feedback regarding the SLAYCHELLA page, and Applicant acknowledged that SLAYCHELLA was related more to her cultural coaching than to 58 Id. at ¶ 9, Ex. B. 59 Id. 60 Id. 61 Id. at ¶ 10. 62 Id. 63 Declaration of Adam Allen, owner of Lease My Marketing, 21 TTABVUE 50, ¶ 5. 64 Ulysse Decl., 21 TTABVUE 20, ¶ 11, Ex. C.
Opposition No. 91291853 21 legal services.65 After reviewing the website and considering feedback from Ms. Goldberg, Applicant decided that the SLAYCHELLA portion was out of place and needed its own website that would be separate and apart from the website dedicated to her professional legal services.66 Accordingly, Applicant planned to build a separate website focused on SLAYCHELLA, but her assistant was terminated in August 2023, and Applicant had very little time to devote to the project given her then-current role as a partner at her new firm.67 However, Applicant maintained the intent to develop the SLAYCHELLA brand.68 In April 2024, Applicant decided to leave her firm and pursue her own practice.69 Shortly thereafter, Applicant hired the marketing company Lease My Marketing to evaluate the existing draft website and to make necessary improvements, including removing the SLAYCHELLA subpage and focusing on remaking the portions of the website to better promote Applicant’s legal services.70 The official website, www.marjoriemesidor.com, was launched around May of 2024, and at that time, Applicant fully expected to shift focus to developing the SLAYCHELLA website and brand.71 However, on June 3, 2024, Opposer commenced an opposition proceeding seeking to prevent her from obtaining a registration for her mark, thereby derailing the plans 65 Id. at ¶ 11. 66 Id. at ¶ 12. 67 Id. at ¶ 13. 68 Id. 69 Id. at ¶ 14. 70 Id. 71 Id. at 21, ¶ 15.
Opposition No. 91291853 22 to move forward with the brand development.72 After the opposition was filed, Applicant decided to delay spending any more money on developing the brand since Applicant would now have to pay legal fees to respond to the opposition proceeding and did not want to commit substantial sums of money to the brand until knowing the outcome of the opposition proceeding.73 Outside of the website, Applicant has also utilized the mark SLAYCHELLA in connection with her law firm retreat, which was held in Garden City, New York on August 26-29, 2025.74 The name of the retreat was “Slaychella: Deliberate and Unafraid,” and included a retreat program with the branding prominently displayed.75 Subsequent to the filing of the Opposition, Applicant contacted Zavier Dinwiddie and Adam Allen with Lease My Marketing, with whom Applicant had been working on developing the www.marjariemesidor.com website and had control over and access to the WIX account. Mr. Allen was asked to determine the dates of publication of the SLAYCHELLA page published on www.marjoriemesidor.com. Mr. Allen accessed the Site History of WIX, which indicated the SLAYCHELLA page was published on August 13, 2023, and removed from the menu options on August 29, 2023.76 In its reply brief, Opposer argues that none of Applicant’s evidence establishes bona fide intent. First, Opposer argues that Applicant’s declaration consists of mere 72 Id. 73 Id. at ¶ 16. 74 Id. at ¶ 17, Ex. D. 75 See id. 76 Allen Decl., 21 TTABVUE 50-51, ¶¶ 5-7.
Opposition No. 91291853 23 statements of subjective intention that, without more, are insufficient to establish applicant’s bona fide intention to use the mark in commerce. Second, Opposer contends that Applicant’s assertion that the screenshots of her draft SLAYCHELLA subpage “clearly evidence an intent to use her Mark” is void of substantive argument. Rather, Opposer argues that the draft webpage depicts nothing more than a vague plan for, or conception of, how Applicant would actually use the SLAYCHELLA mark in commerce. Opposer contends that Applicant has provided no arguments as to how those screenshots depict her intent to use her mark in connection with the goods or services listed in her application, and Opposer notes that Applicant testifies via declaration that the website was built for her legal services. Finally, Opposer contends that Applicant’s proffered “retreat booklet” for a firm retreat she allegedly organized as evidence of her bona fide intent to use the SLAYCHELLA mark in commerce is collateral at best because it is not contemporaneous with the filing of the application. Opposer further argues that the record does not sufficiently demonstrate Applicant’s capacity to market or manufacture her claimed goods or services. Opposer asserts that there is no evidence showing that Applicant has ever marketed or manufactured drinkware, clothing, or keychains bearing the SLAYCHELLA mark or any other mark. Regarding Applicant’s claimed services, Opposer argues that her “20- years of experience as an employment law litigator,” her involvement in “presentations and marketing to her client base and buil[ding] her own practice,” and her internal firm retreat detailed in the retreat booklet do not demonstrate capacity
Opposition No. 91291853 24 because general statements of experience in an adjacent field do not suffice. Opposer contends that Applicant’s reliance on her alleged legal experience, without more, provides no explanation how Applicant’s experience demonstrates her ability to market her services in commerce. Opposer argues that Applicant’s vague and unclear statements of her experience in the legal profession, as opposed to a history of providing educational and speaking services, producing podcasts and online-journals, or selling branded products, do not sufficiently show marketing capacity. B. Analysis 1. Entitlement to a Statutory Cause of Action In every Board inter partes case, a plaintiff must first demonstrate that it is entitled to a statutory cause of action under Sections 13 or 14 of the Trademark Act. To establish such entitlement, a plaintiff must plead, and later prove, a real interest in the proceeding where the opposition or cancellation is within the zone of interests protected by statute, and a reasonable belief in damage that is proximately caused by continued registration of the mark. Corcamore, LLC v. SFM, LLC, 978 F.3d 1298. 1303-04 (Fed. Cir. 2020); see also Empresa Cubana Del Tabaco v. Gen. Cigar Co., 753 F.3d 1270, 1275 (Fed. Cir. 2014). The purpose of the requirement to show entitlement in Board proceedings is “to prevent litigation where there is no real controversy between the parties, where a plaintiff, petitioner or opposer, is no more than an intermeddler.” Lipton Indus., Inc. v. Ralston Purina Co., 670 F.2d 1024, 1028-29 (CCPA 1982).
Opposition No. 91291853 25 Opposer has submitted eleven registrations for the marks COACHELLA, COACHELLA VALLEY MUSIC AND ARTS FESTIVAL, and CHELLA,77 and these pleaded registrations form the basis of Opposer’s likelihood of confusion claim, thus establishing entitlement to oppose the SLAYCHELLA application. Cunningham v. Laser Golf Corp., 222 F.3d 943, 945 (Fed. Cir. 2000). Specifically, ownership of these registrations establishes both an interest in similar marks, such as that which Applicant seeks to register, and a reasonable belief in damage should the SLAYCHELLA mark be registered. See Corcamore, 978 F.3d at 1304-07. Accordingly, Opposer has standing to bring this opposition. Applicant does not challenge Opposer’s entitlement to a statutory cause of action.78 Having found that Opposer is entitled to oppose, we must determine if there are genuine disputes of material fact regarding Opposer’s claim of no bona fide intent to use her applied-for mark in commerce.79 77 Bernstein Decl., 18 TTABVUE 20, ¶ 8, Ex. 3 (TSDR pages and registration certificates for Opposer’s asserted registrations). 78 Once a plaintiff has shown entitlement to a statutory cause of action on one ground, it has the right to assert any other ground in a cancellation proceeding. Hole In 1 Drinks, Inc. v. Lajtay, No. 92065860, 2020 WL 859853, at *4 (TTAB 2020). Because Opposer has demonstrated its entitlement to its statutory cause of action on its likelihood of confusion claim, it may therefore assert its claim of no bona fide intent to use. 79 Proof of entitlement to a statutory cause of action is an element of Opposer’s case-in-chief and is required at trial. See Lipton Indus., Inc. v. Ralston Purina Co., 670 F.2d 1024, 1028 (CCPA 1982). A plaintiff must prove entitlement to a statutory cause of action for the entirety of the proceeding, from commencement until the end. El Roblar Inv. Prop. LLC v. Roe, No. 91272200, 2025 WL 2718983, at *22 (TTAB 2025) (citing Philanthropist.com, Inc. v. Gen. Conf. Corp. of Seventh-Day Adventists, No. 92065178, 2021 WL 2472776, at *4 (TTAB 2021)).
Opposition No. 91291853 26 2. No Bona Fide Intent to Use in Commerce Trademark Act Section 1(b), 15 U.S.C. § 1051(b), states that “a person who has a bona fide intention, under circumstances showing the good faith of such person, to use a trademark in commerce” may apply for registration of the mark. A determination of whether an applicant has a bona fide intention to use the mark in commerce is an objective determination based on all the circumstances. L’Oreal S.A. v. Marcon, No. 91184456, 2012 WL 1267956, at *11 (TTAB 2012). Where there is no evidence of an applicant’s bona fide intent to use the mark at issue on the claimed goods or services as of the filing date of the application, entry of summary judgment on a claim that the applicant had no bona fide intent to use the mark in commerce when it filed its involved application may be warranted. See Honda Motor Co. v. Winkelmann, No. 91170552, 2009 WL 962810, at *2 (TTAB 2009). “To raise a genuine issue of material fact, applicant must rely on specific facts that establish the existence of an ability and willingness to use the mark in the United States to identify its claimed [goods and services] at the time of the filing of the application.” Id. at *4. The evidentiary bar for showing bona fide intent to use is not high, but more is required than “a mere subjective belief.” M.Z. Berger & Co. v. Swatch AG, 787 F.3d 1368, 1375 (Fed. Cir. 2015). The objective evidence must indicate an intention to use the mark that is “firm” and “demonstrable.” Id. at 1375-76. In other words, Applicant’s evidence bearing on her bona fide intent must be “objective” in the sense that it is evidence in the form of real-life facts and by the actions of Applicant, not solely by Applicant’s uncorroborated testimony as to her subjective state of mind.
Opposition No. 91291853 27 Applicant’s “mere statement of subjective intention, without more, would be insufficient to establish [her] bona fide intention to use the mark in commerce.” Lane Ltd. v. Jackson Int’l Trading Co., No. 91092025, 1994 WL 740491, at *6 (TTAB 1994). Further, as the Board has held, the mere act of filing an intent-to-use application is insufficient to establish an applicant’s bona fide intention to use its mark in commerce for the identified goods or services. Rsch. in Motion Ltd. v. NBOR Corp., No. 91179284, 2009 WL 4694941, at *5 (TTAB 2009). An applicant’s ability, capacity, resources, and knowledge with respect to producing or providing the goods and services claimed in its application is an important consideration in determining its bona fide intent to use a mark. See Swatch AG v. M. Z. Berger & Co., No. 91187092, 2013 WL 5655834, at *15 (TTAB 2013) (“[W]e have previously stated, and hereby reaffirm, that an applicant’s capacity to market and/or manufacture the identified goods is evidence that weighs against a finding that an applicant lacked bona fide intent to use.”), aff’d, 787 F.3d 1368 (Fed. Cir. 2015); cf. Lincoln Nat’l Corp. v. Anderson, No. 91192939, 2014 WL 879506, at *9 (TTAB 2014) (applicant found not to have the ability, resources, or knowledge to provide his broadly identified services and thus lacked bona fide intent to use). Based upon our review of the parties’ arguments and the evidence of record, and drawing all justifiable inferences in favor of Applicant, the non-movant, we find that there exists a genuine dispute of material fact as to whether Applicant had a bona fide intent to use the applied-for mark in commerce in connection with the services identified in Class 41 on the date she filed her application. As a general rule, the
Opposition No. 91291853 28 factual question of intent regarding the filing an intent-to-use application is unsuited to disposition on summary judgment. See Commodore Elecs. Ltd. v. CBM K.K., No. 91086336, 1993 WL 156479, at *5 (TTAB 1993) (citing Copelands’ Enters., Inc. v. CNV, Inc., 945 F.2d 1563, 1567 (Fed. Cir. 1991)). Moreover, the standard of proof for summary judgment, i.e., the absence of a genuine dispute of any material fact, is more stringent than the preponderance of evidence standard for trial. See Anheuser-Busch, LLC v. Innvopak Sys. Pty Ltd., No. 91194148, 2015 WL 5316485, at *6 n.6 (TTAB 2015). Here, Applicant has provided testimony by way of her declaration and depictions of her website which evidence a dispute of material fact regarding her intent to use her mark in connection with her identified services in Class 41. While the record does not show that Applicant took concrete steps to launch all of the services in her application, it does not necessarily indicate the absence of a genuine dispute of material fact that Applicant lacked a bona fide intent to use her mark in commerce in connection with the identified services as of the application filing date. See Monster Energy Co. v. Tom & Martha LLC, No. 91250710, 2021 WL 5822294, at *8 (TTAB 2021). Applicant’s affidavit therefore is sufficient to raise a genuine dispute of material fact as to whether Applicant possessed the requisite bona fide intent to use the subject mark in commerce in connection with her Class 41 services when she filed the involved application. Opposer’s motion for summary judgment with regard to Applicant’s services in Class 41 therefore is DENIED.
Opposition No. 91291853 29 In contrast, with regard to Applicant’s identified goods in Classes 14, 21 and 25, Applicant has failed to provide any evidence at all of an intent to use her mark in connection with these goods. Applicant asserts that “[t]he goods that Applicant intended to offer under the SLAYCHELLA Mark are typical merchandise products sold to promote and advertise the primary services offered under a trademark.”80 Although Applicant references Paragraph 9 of her declaration in support of this assertion, her declaration makes no mention of these goods,81 and Applicant has not otherwise provided any evidence supporting her bona fide intent to use her mark in connection with the identified goods in Classes 14, 21 and 25. See Cai v. Diamond Hong, Inc., 901 F.3d 1367, 1371 (Fed. Cir. 2018) (“Attorney argument is no substitute for evidence.”) (citation omitted). As a result, Opposer’s motion for summary judgment on its claim of no bona fide intent to use Applicant’s mark in connection with the identified goods in Classes 14, 21 and 25 is GRANTED. To summarize, Opposer’s motion for summary judgment on its claim of lack of bona fide intent to use the mark is GRANTED in connection with Applicant’s goods in Classes 14, 21 and 25, and is DENIED with regard to Applicant’s services in Class 41. VI. Applicant’s Cross-motion for Summary Judgment A. The Parties’ Arguments and Evidence Applicant asserts that there is no genuine dispute of material fact as to likelihood of confusion in this case. Applicant argues that, under the likelihood of confusion 80 21 TTABVUE 4. 81 See Ulysse Decl., 21 TTABVUE 20, ¶ 9.
Opposition No. 91291853 30 factors set forth in In re E.I. DuPont de Nemours & Co., 476 F.2d 1357, 1361 (CCPA 1973) (“DuPont”), no likelihood of confusion can be found as a matter of law, as Opposer’s COACHELLA registrations are weak, the parties’ marks are vastly dissimilar, and the parties’ goods and services are marketed to completely different consumers. Applicant first argues that Opposer’s COACHELLA marks are weak geographically descriptive marks entitled to a narrow scope of protection and that Opposer has admitted that the relative fame of its marks stems almost entirely from the associations with its music festival. Applicant further asserts that differences exist in sound, appearance, and commercial impression between the respective marks. Finally, Applicant argues that several other parties are using the “Coachella” mark to emphasize the source of its goods and services as emanating from the Coachella Valley in California, further underscoring that “Coachella” is a weak term and that Opposer’s Coachella Registrations are entitled only to a narrow scope of protection. Applicant also provides fourteen third party registrations in support of this assertion.82 Applicant further contends that the respective services of the parties are not related and marketed to different consumers. In support of her assertions Applicant has submitted her declaration,83 the declaration of Adam Allen, owner of Lease My Marketing,84 and the declaration of Adriano Pacifici, counsel for Applicant.85 82 See Pacifici decl., 22 TTABVUE 56, ¶ 4, Exs. C and D. 83 Declaration of Marjorie Ulysse, 22 TTABVUE 22. 84 22 TTABVUE 53. 85 Id. at 56.
Opposition No. 91291853 31 In response, Opposer argues that its COACHELLA marks are strong and famous, as Opposer has extensively advertised and promoted its COACHELLA marks over the past twenty-five years, and Opposer’s music festival has enjoyed extensive third- party media coverage.86 Opposer further argues that its COACHELLA marks and Applicant’s SLAYCHELLA mark are similar in appearance, sound and meaning, and that Applicant has failed to show there is no dispute of material fact concerning the relatedness of the services. In support of its assertions Opposer has submitted the declaration of Jason Bernstein, Vice President and Assistant General Counsel for AEG Presents, LLC, parent company of Opposer,87 and the declaration of Steven E. Lauridsen, counsel for Opposer.88 B. Analysis In determining the issue of likelihood of confusion and whether there is any genuine dispute of material fact, we consider all of the DuPont factors for which there is evidence and argument. See DuPont, 476 F.2d at 1361; see also In re Mighty Leaf Tea, 601 F.3d 1342, 1346 (Fed. Cir. 2010) (“Not all of the DuPont factors are relevant to every case, and only factors of significance to the particular mark need be considered.”); Cunningham v. Laser Golf Corp., 222 F.3d 943, 946 (Fed. Cir. 2000) (same). On this record, drawing all justifiable inferences in favor of Opposer, the non- moving party, we find that Applicant has not carried her burden of establishing that 86 See Bernstein Decl., 25 TTABVUE 29-33, ¶¶ 5-25. 87 25 TTABVUE 29. 88 Id. at 288.
Opposition No. 91291853 32 no genuine disputes of material fact exist regarding this claim. Upon careful consideration of the parties’ declarations, evidence, and arguments, we find, at a minimum, that there are at least genuine disputes of material fact regarding the similarity or dissimilarity of the parties’ respective marks; the relatedness of the services as described in the applications and registrations; and the conditions under which and buyers to whom sales are made. Thus, Applicant’s motion for summary judgment on the claim of likelihood of confusion is DENIED.89 VII. Applicant’s Motion to Amend Application Applicant’s opposed motion for leave to amend her application without consent is DENIED AS MOOT with regard to deletion of the goods in Classes 14, 21, and 25, and DEFERRED with regard to amendment of the services in Class 41 until final decision. See Heil Co. v. Tripleye GmbH, No. 91277359, 2024 WL 4925901, at *39 (TTAB 2024) (unconsented motion to amend identification of goods and services deferred until trial), appeal dismissed, 2025 WL 401210 (Fed. Cir. 2025); TBMP § 514.03. VIII. Proceedings Resumed Proceedings are resumed. Discovery and trial dates are reset as follows: Expert Disclosures Due 11/21/2026 Discovery Closes 12/21/2026 89 The fact that we have identified in this order only a few material facts that are genuinely in dispute should not be construed as a finding that these are necessarily the only issues that remain for trial. The parties are also reminded that evidence submitted in support of or in opposition to a motion for summary judgment is of record only for consideration of that motion. To be considered at final hearing, any such evidence must be properly introduced during the appropriate trial period. See, e.g., Levi Strauss & Co. v. R. Joseph Sportswear Inc., No. 91081072, 1993 WL 444262, at *1 n.2 (TTAB 1993); TBMP § 528.05(a).
Opposition No. 91291853 33 Plaintiff’s Pretrial Disclosures Due 2/4/2027 Plaintiff’s 30-day Trial Period Ends 3/21/2027 Defendant’s Pretrial Disclosures Due 4/5/2027 Defendant’s 30-day Trial Period Ends 5/20/2027 Plaintiff’s Rebuttal Disclosures Due 6/4/2027 Plaintiff’s 15-day Rebuttal Period Ends 7/4/2027 Plaintiff’s Opening Brief Due 9/2/2027 Defendant’s Brief Due 10/2/2027 Plaintiff’s Reply Brief Due 10/17/2027 Request for Oral Hearing (optional) Due 10/27/2027 Generally, the Federal Rules of Evidence apply to Board trials. Trial testimony is taken and introduced out of the presence of the Board during the assigned testimony periods. The parties may stipulate to a wide variety of matters, and many requirements relevant to the trial phase of Board proceedings are set forth in Trademark Rules 2.121 through 2.125. These include pretrial disclosures, matters in evidence, the manner and timing of taking testimony, and the procedures for submitting and serving testimony and other evidence, including affidavits, declarations, deposition transcripts and stipulated evidence. Trial briefs shall be submitted in accordance with Trademark Rules 2.128(a) and (b). Oral argument at final hearing will be scheduled only upon the timely submission of a separate notice as allowed by Trademark Rule 2.129(a).
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