Natural Bridge Caverns, Inc.

Mailed: July 24, 2026
UNITED STATES PATENT AND TRADEMARK OFFICE
Trademark Trial and Appeal Board
————
In re Natural Bridge Caverns, Inc.
————
Serial Nos. 97438479, 97438507, 97546721 & 97546743
————
Edward B. Marvin of Jackson Walker LLP,
for Natural Bridge Caverns, Inc.
Danielle Anderson, Trademark Examining Attorney, Law Office 113,1
Myriah Habeeb, Managing Attorney.
————
Before Goodman, Stanley, and Lavache,
Administrative Trademark Judges.
Opinion by Lavache, Administrative Trademark Judge:
Applicant Natural Bridge Caverns, Inc. filed four applications seeking
registration on the Principal Register of the proposed standard-character mark
NATURAL BRIDGE CAVERNS for the following services:
1 The applications were reassigned from the original examining attorney to the above-named
examining attorney during prosecution. In this opinion, we refer to both examining attorneys
involved with the applications as the Examining Attorney.
THIS OPINION IS NOT A
PRECEDENT OF THE TTAB

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Rental of cabins, in International Class 36;2
Provision of recreational vehicle parking facilities, in International
Class 39;3
Entertainment services, namely, arranging and conducting special
events at a theme park; rental of theme park facilities for special events,
in International Class 41;4 and
Providing campground facilities and rental of temporary
accommodations;5 providing social meeting, banquet and social function
facilities,6 in International Class 43.
In all four applications, the Trademark Examining Attorney refused registration
of the proposed mark under Trademark Act Section 2(e)(1), 15 U.S.C. § 1052(e)(1), on
the ground that it is merely descriptive of Applicant’s identified services. After the
Examining Attorney issued a final refusal under Section 2(e)(1) in all the
applications, Applicant appealed and moved to consolidate the applications7 for
2 Application Serial No. 97438479, filed June 1, 2022, based on an allegation of a bona fide
intention to use the mark in commerce, under Trademark Act Section 1(b),
15 U.S.C. § 1051(b).
3 Application Serial No. 97438507, filed June 1, 2022, based on an allegation of a bona fide
intention to use the mark in commerce, under Trademark Act Section 1(b), 15 U.S.C. §
1051(b).
4 Application Serial No. 97546743, filed August 12, 2022, based on an allegation of use in
commerce under Trademark Act Section 1(a), 15 U.S.C. § 1051(a), claiming 1964 as both the
date of first use anywhere and the date of first use in commerce.
5 Application Serial No. 97438507. See note 3.
6 Application Serial No. 97546721, filed August 12, 2022, based on an allegation of use in
commerce under Trademark Act Section 1(a), 15 U.S.C. § 1051(a), claiming 1964 as both the
date of first use anywhere and the date of first use in commerce.
7 See Motion to Consolidate, 4 TTABVUE.
Unless otherwise noted, the TTABVUE and Trademark Status and Document Retrieval
(TSDR) citations in this opinion refer respectively to entries in the Board’s electronic docket
and to the downloadable pdf. version of the electronic application file for Serial No. 97438479.
For TTABVUE citations, the number preceding the TTABVUE designation is the docket

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purposes of briefing and final decision on appeal. The Board granted the motion8 and
the appeal has been fully briefed.9 For the reasons explained below, we affirm the
refusal to register the proposed mark in all four applications.
I. Relevant Law
Section 2(e)(1) of the Trademark Act bars registration of a mark that is merely
descriptive when used on or in connection with an applicant’s identified services, and
the mark has not otherwise acquired distinctiveness. See 15 U.S.C. §§ 1052(e)(1),
1052(f). A term is merely descriptive “if it immediately conveys knowledge of a
quality, feature, function, or characteristic of the . . . services with which it is used.”
In re Chamber of Com. of the U.S., 675 F.3d 1297, 1300 (Fed. Cir. 2012) (quoting In
re Bayer AG, 488 F.3d 960, 963 (Fed. Cir. 2007)); see also In re TriVita, Inc., 783 F.3d
872, 874 (Fed. Cir. 2015).
entry number and any numbers following indicate the relevant page numbers within the
docket entry.
8 See Board Order, 5 TTABVUE; TRADEMARK TRIAL AND APPEAL BOARD MANUAL OF
PROCEDURE (TBMP) § 1214 (2026) (“When an applicant has filed an ex parte appeal to the
Board in two or more co-pending applications, and the cases involve common issues of law or
fact, the Board, upon request by the applicant or examining attorney or upon its own
initiative, may order the consolidation of the appeals for purposes of briefing, oral hearing,
and/or final decision.”).
9 Applicant’s Appeal Brief, 7 TTABVUE; Examining Attorney’s Brief, 9 TTABVUE;
Applicant’s Reply Brief, 10 TTABVUE. While Applicant filed a single appeal brief addressing
all four applications, the Examining Attorney filed a separate appeal brief for each
application, as permitted under Board procedure. See TBMP § 1214 (“Although cases
consolidated prior to briefing may be presented on the same brief, they do not have to be. The
applicant (and/or the examining attorney) may file a different brief in each case if the
applicant (and/or the examining attorney) so desires.”). Applicant followed suit by filing four
separate reply briefs “due to minor variations in the PTO’s arguments and the evidence it
cites in its . . . Briefs.” Applicant’s Reply Brief, 12 TTABVUE 2 n.1.

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Descriptiveness must be assessed not in the abstract, but “in relation to the goods
[or services] for which registration is sought, the context in which it is being used,
and the possible significance that the term would have to the average purchaser of
the goods [or services] because of the manner of its use or intended use.” Bayer, 488
F.3d at 964 (citing In re Abcor Dev., 588 F.2d 811, 813 (CCPA 1978)). Here, we must
consider the perception of the average consumers of cabin rentals; RV parking
facilities; campground facilities; temporary accommodations; social meeting, banquet
and social function facilities; and special events at theme parks.
Evidence of the relevant purchasers’ understanding of a term or phrase in
connection with particular services “may be obtained from any competent source,
such as purchaser testimony, consumer surveys, listings in dictionaries, trade
journals, newspapers[,] and other publications.” Real Foods Pty Ltd. v. Frito-Lay N.
Am., Inc., 906 F.3d 965, 974 (Fed. Cir. 2018) (quoting Royal Crown Co. v. Coca-Cola
Co., 892 F.3d 1358, 1366 (Fed. Cir. 2018)). “These sources may include [w]ebsites,
publications and use . . . ‘in advertising materials directed to the goods [or services].’”
In re N.C. Lottery, 866 F.3d 1363, 1368 (Fed. Cir. 2017) (quoting Abcor, 588 F.2d at
814). Evidence of an applicant’s own usage beyond those noted above may also be
considered when determining descriptiveness. See In re Omniome, Inc., No.
87661190, 2019 TTAB LEXIS 414, at *14.
II. Analysis
With a proposed mark like NATURAL BRIDGE CAVERNS, we first consider the
meaning of the mark’s component terms and then determine whether the proposed
mark, as a whole, is merely descriptive. DuoProSS Meditech Corp. v. Inviro Med.

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Devices Ltd., 695 F.3d 1247, 1255 (Fed. Cir. 2012). That is, we assess whether the
combination of component terms in the mark “conveys any distinctive source-
identifying impression contrary to the descriptiveness of the individual parts.” In re
Fat Boys Water Sports LLC, No. 86490930, 2016 TTAB LEXIS 150, at *14-15 (quoting
In re Oppedahl & Larson LLP, 373 F.3d 1171, 1175 (Fed. Cir. 2003)). If each
component “retains its merely descriptive significance in relation to the goods [or
services], the combination results in a composite that is itself merely descriptive.” Fat
Boys, 2016 TTAB LEXIS 150, at *15 (citing In re Tower Tech., Inc., No. 75709532,
2002 TTAB LEXIS 300, at *10).
As to the component terms here, the Examining Attorney has submitted
dictionary evidence indicating that a “natural bridge” is “a rock formation in which
the central bottom part has been completely eroded away, leaving a structure that
looks like a bridge,”10 and that a “cavern” is a “cave,”11 which, in turn, is defined as
“a natural chamber or series of chambers in the earth or in the side of a hill or cliff.”12
The record also includes the following excerpts from third-party websites using
the term “natural bridge” to refer to a type of natural rock formation:
• An article in the online version of the Columbia Daily Tribune
(columbiatribune.com) describes the “natural bridges . . . of
Missouri” and explains that the “massive formations” “might be the
10 September 4, 2024 Nonfinal Office Action at TSDR 7 (excerpt from online version of
MERRIAM-WEBSTER DICTIONARY).
11 Id. at 29 (excerpt from online version of MERRIAM-WEBSTER DICTIONARY).
12 April 15, 2025 Subsequent Final Office Action at TSDR 150 (excerpt from online version of
MERRIAM-WEBSTER DICTIONARY).

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remains of a cave that collapsed, with only a portion of the ceiling
still standing.”13
• A webpage on the U.S. Forest Service website (fs.usda.gov) notes
that “among the many natural features of the Ozark Natural Forest
is the huge stone arch that forms a natural bridge at Alum Cove
National Recreation Trail” and that the “natural arch is all that
remains of what was a quartz sandstone cave.”14
• The Muddy Camper website (muddycamper.com) lists a “Natural
Bridges Attraction” in Washington, which is a “unique natural
attraction featuring a collapsed lava tube that has left behind two
natural bridges and several small cave openings.”15
• A document on mexicancaves.org describes “La Cueva de las Quilas
(The Cave of the Parrots)” in Ciudad Valles, Mexico, where one “will
find a cavern with a natural bridge.”16
• The website for the Courtwood Inn (courtwoodinn.com) advertises
the “Natural Bridges in Calaveras County,” California, where one
will “find water flowing out of a vast cave carved into the ground
. . . a natural bridge,” along with “magical rock formations and
mesmerizing, colorful caverns.”17
• The Kentucky Hiker Project website (kentuckyhiker.org) includes
an entry for the Carter Caves Natural Bridge with photos of a large
bridge-like rock formation, which is described as “the only natural
bridge in Kentucky with an active roadway in use above it.”18
Other evidence of record shows the term “caverns” being used to refer to cave
systems. For example:
• The website for the Raccoon Mountain Caverns & Campground
(raccoonmountain.com) advertises “Tennessee’s Highest-Rated
13 Id. at 14-19 (emphasis added).
14 Id. at 69 (emphasis added).
15 Id. at 72-73 (emphasis added).
16 Id. at 79-80 (emphasis added).
17 Id. at 87-88 (emphasis added).
18 Id. at 139-143 (emphasis added).

Serial Nos. 97438479, 97438507, 97546721 & 97546743
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Cave Tour,” which features “caverns [that] boast an incredibly
well-preserved landscape with countless natural formations” and
“one of the most geologically active caverns in the south.”19
• The website for Dixie Caverns (dixiecaverns.com) in Salem,
Virginia uses “cave tours” and “cavern tours” interchangeably and
includes photos of caves featured in the cavern tours.20
• The website for the Endless Caverns Resort (endlesscaverns.com)
in Newmarket, Virginia advertises its “cavern tours” with a photo
of a cave environment, noting that “[o]ur caverns have been
thrilling visitors with underground treasures for generations” and
indicating that “[f]riendly and experienced cavern guides will bring
you through six miles of this subterranean masterpiece.”21
• The website smokehole.com includes information about “Cavern
Tours” of the Smoke Hole Caverns, which “provide visitors with a
peek into the scenery below the surface” and includes various
photos of the cave environment inside the caverns.22
Based on the record, we find that NATURAL BRIDGE describes a naturally
occurring bridge-like rock formation and CAVERNS describes a system of
subterranean chambers, i.e., caves. And, when these terms are combined, the
resulting combination, NATURAL BRIDGE CAVERNS, connotes a cave system
featuring a naturally occurring rock formation with a bridge-like structure.
Again, however, we must consider this connotation not in the abstract but based
on the relevant consumers’ understanding of the term as used in connection with
Applicant’s identified services. See Bayer, 488 F.3d at 964. That is, “we must assume
that prospective consumers will encounter the term in relation to the identified
19 Id. at 55 (emphasis added).
20 Id. at 59-61 (emphasis added).
21 Id. at 101-104 (emphasis added).
22 Id. at 162-165 (emphasis added).

Serial Nos. 97438479, 97438507, 97546721 & 97546743
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services and determine whether those consumers will understand the term to convey
information about the services.” Grand Canyon West Ranch, LLC v. Hualapai Tribe,
No. 91162008, 2008 TTAB LEXIS 33, at *11.
To reiterate, the services here are:
Rental of cabins, in International Class 36;
Provision of recreational vehicle parking facilities, in International
Class 39;
Entertainment services, namely, arranging and conducting special
events at a theme park; rental of theme park facilities for special events,
in International Class 41; and
Providing campground facilities and rental of temporary
accommodations; providing social meeting, banquet and social function
facilities, in International Class 43.
The Examining Attorney asserts that NATURAL BRIDGE CAVERNS is merely
descriptive of these services because the phrase describes a key aspect or
characteristic of them, namely, that they are provided in connection with an
attraction consisting of a cave system featuring a naturally occurring bridge-like rock
formation.23
23 Examining Attorney’s Brief, 9 TTABVUE 10. The Examining Attorney also asserts that
Applicant “has already conceded that [NATURAL BRIDGE CAVERNS] is not inherently
distinctive because the records in Applicant’s prior registrations show that Applicant
“claimed acquired distinctiveness under Trademark Act Section 2(f) [15 U.S.C. § 1052(f)]
unconditionally and not in the alternative.” Id. at 12. However, we have not treated these
prior Section 2(f) claims, which applied to different goods and services, as a concession that
the proposed mark is not inherently distinctive as to the identified services in the instant
applications. Cf. In re Am. Furniture Warehouse CO, No. 86407531, 2018 TTAB LEXIS 122,
at *6-7 (noting that a Section 2(f) claim in a prior registration could be viewed as a concession
that the proposed mark lacked inherent distinctiveness where the services in the prior
registration included those identified in the subject application).

Serial Nos. 97438479, 97438507, 97546721 & 97546743
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In support, the Examining Attorney points to Applicant’s own website indicating
that “Natural Bridge Caverns is one of the world’s premier show caverns” with an
“amazing 60-foot limestone bridge.”24 The Examining Attorney also relies on
Applicant’s responses to a request for information,25 indicating that:
• Applicant’s “property contains a rock formation in which the central
bottom part has been eroded away, leaving a structure that looks
like a bridge.”
• “Applicant anticipates it will likely offer recreational vehicle
parking facilities, campground facilities, and cabins for rent on the
same property where Applicant’s NATURAL BRIDGE CAVERNS
theme park operates and where the cave system named by
Applicant’s founder (i.e., NATURAL BRIDGES CAVERNS) is
located.”
• “Applicant anticipates its recreational vehicle parking facilities,
campground facilities, and cabin rentals will be marketed to
consumers interested in viewing large caves and, more specifically,
to those who may be interested in visiting Applicant’s NATURAL
BRIDGE CAVERNS theme park and viewing the NATURAL
BRIDGE CAVERNS cave system . . . .”26
• Applicant’s social meeting, banquet and social function facilities,
and theme park special event services “sometimes take place inside
a room within the NATURAL BRIDGE CAVERNS cave system” or
“in proximity to” “a rock formation in which the central bottom part
has been eroded away, leaving a structure that looks like a
bridge.”27
• The typical consumer of Applicant’s social meeting, banquet and
social function facilities, and theme park special event services, “is
24 September 4, 2024 Nonfinal Office Action at TSDR 22-23.
25 See Examining Attorney’s Brief, 9 TTABVUE 3.
26 March 4, 2025 Response to Nonfinal Office Action, Ser. No. 97438479, at TSDR 10-12;
March 4, 2025 Response to Nonfinal Office Action, Ser. No. 97438507, at TSDR 10-13.
27 March 4, 2025 Response to Nonfinal Office Action, Ser. No. 97546721 at TSDR 11; March
4, 2025 Response to Nonfinal Office Action, Ser. No. 97546743, at TSDR 11.

Serial Nos. 97438479, 97438507, 97546721 & 97546743
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any consumer looking to hold a group event at Applicant’s
NATURAL BRIDGE CAVERNS theme park.”28
The record also contains evidence showing that it is common for cabin rentals,
temporary accommodations, campground facilities, RV parking facilities, social
function facilities, and special events to be offered in connection with, or near, cavern
and natural bridge attractions. For instance:
• Kartchner Caverns State Park, advertised on azstateparks.com,
offers cave tours and cabin rentals.29
• Jellystone Park at Natural Bridge, advertised on sunoutdoors.com,
offers campgrounds and RV parking near the Natural Bridge
Caverns in Virginia.30
• Raccoon Mountain Caverns & Campground (raccoonmountain.com)
offers cave tours, cabin rentals, temporary accommodations,
campgrounds, and RV parking.31
• Dixie Caverns (dixiecaverns.com) offers cavern tours,
campgrounds, and RV parking.32
• The Natural Bridges Campground in Utah, listed on recreation.gov,
offers campgrounds and RV parking near “three of the largest
natural bridges in the United States.”33
• The Natural Bridges attraction in Washington, advertised on
muddycamper.com, features “two natural bridges and several small
cave openings” and is near several campgrounds.34
28 March 4, 2025 Response to Nonfinal Office Action, Ser. No. 97546721, at TSDR 12. March
4, 2025 Response to Nonfinal Office Action, Ser. No. 97546743, at TSDR 12.
29 April 15, 2025 Subsequent Final Office Action at TSDR 10-12.
30 Id. at 28-35.
31 Id. at 53-58.
32 Id. at 59-63.
33 Id. at 64-68.
34 Id. at 73.

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• The Endless Caverns Resort (endlesscaverns.com) offers cavern
tours, temporary accommodations, cabin rentals, campgrounds,
and RV parking.35
• The Caverns in Tennessee (thecaverns.com) feature a cave system,
temporary accommodations, campgrounds, RV parking, special
events,36 and private event hosting and facilities.37
• The Cave of the Winds Mountain Park (caveofthewinds.com)
features cave tours and special event hosting and facilities.38
• The Shenandoah Caverns (shenandoahcaverns.com) feature cavern
tours and private event hosting and facilities.39
• The Luray Caverns (luraycaverns.com) offer cavern tours, private
event hosting and facilities, and temporary accommodations.40
• The Glenwood Caverns Adventure Park (glenwood-caverns.com)
offers cavern tours as well as special events and private event
hosting and facilities.41
• The Wonder World Cave and Adventure Park (wonder-
worldpark.com) features cave tours and private event hosting and
facilities.42
• The Historic Penn’s Cave & Wildlife Park (pennscave.com) offers
cave tours and special event hosting and facilities.43
35 Id. at 81-85.
36 Id. at 114-121.
37 April 15, 2025 Subsequent Final Office Action, Ser. No. 97546743, at TSDR 99-100.
38 Id. at 96-97.
39 Id. at 105-110.
40 Id. at 111-117, 119-127.
41 Id. at 151-155.
42 Id. at 156-164.
43 Id. at 165-169, 175-180.

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In view of the evidence of record, we agree with the Examining Attorney that “a
consumer knowing that applicant’s services are being offered for the purposes of
viewing a cavern with a natural bridge will immediately understand the wording
NATURAL BRIDGE CAVERNS as conveying information about the services, namely
that applicant’s rental cabins[,] [parking facilities, temporary accommodations,
campgrounds, social function facilities, and theme-park special event services] are for
the purpose of accessing” a cave system featuring a naturally occurring bridge-like
rock formation.44
In reaching this determination, we have considered Applicant’s contention that
the Examining Attorney’s reasoning amounts to an impermissible per se rule—
namely, that any service or product Applicant offers from premises where its cavern
is located would necessarily be merely descriptive.45 We agree that descriptiveness
cannot be established by a mechanical rule and “cannot be based on a ‘per se’ rule.”
See Nature’s Way Prods. v. Nature’s Herbs, Inc., No. 92016634, 1989 TTAB LEXIS 5,
at *11-12. Mere physical proximity of an attraction to an unrelated good or service
would not, by itself, necessarily render a term describing the features of that
attraction merely descriptive of the good or service. Thus, to paraphrase Applicant’s
example,46 a term describing a nearby cavern may not immediately convey
information about snack foods because the purchasers of these goods would not
44 Examining Attorney’s Brief, 9 TTABVUE 10.
45 See Applicant’s Brief, 7 TTABVUE 20-21; Applicant’s Reply Brief, 12 TTABVUE 3.
46 Applicant’s Reply Brief, 12 TTABVUE 3.

Serial Nos. 97438479, 97438507, 97546721 & 97546743
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necessarily understand the cavern to be a feature, characteristic, or purpose of those
goods.
In this case, our determination does not rest on such a per se rule, but on the
specific relationship between the proposed mark and the particular services identified
in each application, as established by this record. The services at issue—cabin
rentals, RV parking facilities, campground facilities, temporary accommodations,
social meeting and banquet facilities, and theme-park special event services—are not
merely co-located with Applicant’s cavern attraction. They are, by Applicant’s own
account, offered for the purpose of, or as a means of accessing, that attraction. In
Applicant’s own words, these services are “marketed to consumers interested in
viewing large caves,” take place “inside a room within the NATURAL BRIDGE
CAVERNS cave system” or “in proximity to” its bridge-like rock formation, and are
directed to consumers “looking to hold a group event at Applicant’s NATURAL
BRIDGE CAVERNS theme park.”47 The third-party evidence of record likewise shows
that accommodations, campgrounds, parking facilities, event facilities, and similar
services are routinely offered specifically to provide access or proximity to cavern and
natural-bridge attractions. This record thus establishes a direct nexus between the
proposed mark and a feature, characteristic, or fundamental purpose of these
services—not a categorical rule that everything offered on Applicant’s premises is
descriptive. Where such a nexus is shown, the term is merely descriptive; where it is
47 See supra notes 26-28 and accompanying text.

Serial Nos. 97438479, 97438507, 97546721 & 97546743
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absent, it is not. Cf. Grand Canyon West Ranch, 2008 TTAB LEXIS 33, at *13-15
(mark describing the “fundamental purpose or object of the identified services”).
For the same reasons, we reject Applicant’s argument that NATURAL BRIDGE
CAVERNS cannot be merely descriptive as applied to the identified services because
“Applicant does not seek to register [the proposed mark] in connection with cave
systems, or cave tours.”48 Applicant is correct that we must determine descriptiveness
based on the services as they are identified in the application. See Bayer, 488 F.3d at
964. However, the wording comprising the proposed mark need not actually appear
in the identification of services for us to find mere descriptiveness. It is sufficient that
the proposed mark merely describes a feature, characteristic, or purpose of the
identified services. See In re Friends in the West, No. 74584732, 1997 TTAB LEXIS
213, at *5 (“It is sufficient . . . if the designation or term simply describes one
significant attribute of the services.).
Here, the wording used to identify Applicant’s various services is broad enough to
include such services offered in connection with an attraction consisting of a cave
system featuring a naturally occurring bridge-like rock formation. See In re Country
Oven, Inc., No. 87354443, 2019 TTAB LEXIS 381, at *4 (“Where the identification of
services is broad, the Board ‘presume[s] that the services encompass all services of
the type identified.’” (quoting Sw. Mgmt., Inc. v. Ocinomled, Ltd., No. 76393986, 2015
TTAB LEXIS 176, at *60-61)). Again, Applicant’s own responses to the Examining
Attorney’s request for information confirm that Applicant’s services are, in fact,
48 Applicant’s Appeal Brief, 7 TTABVUE 14.

Serial Nos. 97438479, 97438507, 97546721 & 97546743
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provided in connection with such an attraction. Thus, the proposed mark describes a
significant aspect or fundamental purpose of the identified services. Cf., e.g., Grand
Canyon West Ranch, 2008 TTAB LEXIS 33, at *13 (finding GRAND CANYON WEST
merely descriptive because it indicated that the “purpose of applicant’s airport, air
transportation and other transportation services [was] to bring visitors to the west
rim of the Grand Canyon”).49
Nonetheless, Applicant asserts that a recent decision of the U.S. Court of Appeals
for the Federal Circuit, In re Bayou Grande Coffee Roasting Co., 160 F.4th 1370 (Fed.
Cir. 2025), dictates a reversal of the refusal here. In Bayou Grande, the Court found
that the mark KAHWA cannot be generic or merely descriptive of cafés and coffee
shops “[b]ecause there is no record evidence showing any café or coffee shop in the
United States has ever sold kahwa,” which is a specific type of green tea. Id. at 1376.
Applicant thus argues that we cannot find NATURAL BRIDGE CAVERNS to be
merely descriptive because “there is no record evidence that others include both a
natural bridge and caverns as part of offering the Subject Services.”50 This argument
is unavailing. In contrast to Bayou Grande, the record here contains ample evidence
49 We are not convinced by Applicant attempts to distinguish Grand Canyon West Ranch from
this case. See Applicant’s Reply Brief, 12 TTABVUE 7-8. Simply put, we find that the former
case is relevant here because it demonstrates, at the very least, that a phrase may be found
merely descriptive where the record shows that the phrase describes the “fundamental
purpose or object of the identified services.” Grand Canyon West Ranch, 2008 TTAB LEXIS
33, at *13. Here, the record establishes that the identified services are offered for the
fundamental purpose of providing access or proximity to an attraction consisting of a cave
system featuring a naturally occurring bridge-like rock formation, and that the relevant
consumers would associate the services with such an attraction.
50 Applicant’s Appeal Brief, 7 TTABVUE 15.

Serial Nos. 97438479, 97438507, 97546721 & 97546743
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that the identified services actually are offered in connection with attractions
consisting of, or including, natural bridges or caverns. And Bayou Grande does not
establish a new legal principle requiring that each piece of evidence must show the
descriptiveness of every component term within a proposed mark. In any event,
Applicant’s responses to the Examining Attorney’s request for information indicate
that Applicant’s services will be offered in connection with an attraction featuring
both a natural bridge and caverns.
We are also unpersuaded by Applicant’s argument that the evidence does not
establish the descriptiveness of NATURAL BRIDGE CAVERNS because the evidence
“included a mere three instances of someone other than Applicant using the full
phrase.”51 The fact that Applicant may be the first or only user to adopt the phrase
does not mean that it is not merely descriptive, nor does it somehow render the phrase
distinctive. See In re Fallon, No. 86882668, 2020 TTAB LEXIS 464, at *32-33 (“‘The
fact that Applicant may be the first or only user of a term does not render that term
distinctive’ if . . . it has been shown to be merely descriptive of the goods [or services]
identified in the application.”) (quoting Fat Boys, 2016 TTAB LEXIS 150, at *10); In
re Swatch Grp. Mgmt. Servs. AG, No. 85485359, 2014 TTAB LEXIS 131, at *29 n.50
(“Being ‘the first and only one to adopt and use the mark sought to be registered does
not prove that the mark is not descriptive.’”) (quoting In re Bailey Meter Co., 102 F.2d
843, 844 (CCPA 1939)).
51 Id. at 11.

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Applicant’s contention that NATURAL BRIDGE CAVERNS has an incongruous,
and thus distinctive, meaning because it refers to “a natural bridge type of cavern,
but there is no such recognized type of cavern”52 also lacks merit. The record
establishes that natural bridges and caverns are often associated and may be part of
the same geological formation. Indeed, Applicant’s own caverns feature a natural
bridge. Thus, it is not accurate to say that such caverns are not “recognized.” And we
fail to see why the phrase NATURAL BRIDGE CAVERNS should be considered
incongruous, even if it is not commonly used, given that it aptly describes the features
of such a formation.
Similarly, we reject Applicant’s argument that the proposed mark requires the
type of “multi-stage reasoning applicable to a suggestive mark” because “[f]irst,
consumers must deduce that NATURAL BRIDGE CAVERNS describes a cavern that
‘features’ a natural bridge rather than a type of cavern that does not exist,” and
“[s]econd, consumers must make a mental leap to get from words that describe such
a cavern to the words additionally describing the location of Applicant’s Subject
Services.”53 Applicant’s arguments rest on the faulty premise that the mark is to be
considered in the abstract. However, “[w]hether consumers could guess what the
product [or service] is from consideration of the mark alone is not the test.” Hangzhou
Mengku Tech. Co. v. Shanghai Zhenglang Tech. Co., No. 91272143, 2024 TTAB
LEXIS 575, at *24 (quoting In re Am. Greetings Corp., No. 73284539, 1985 TTAB
52 Id. at 12 (emphasis omitted).
53 Applicant’s Reply Brief, 12 TTABVUE 10.

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LEXIS 97, at *3-4). Again, the mark must be considered “in relation to the goods or
services for which registration is sought, the context in which the mark is used, and
the possible significance that the mark is likely to have to the average purchaser
encountering the goods or services in the marketplace.” Hangzhou Mengku Tech.,
2024 TTAB LEXIS 575, at *23-24. In view of the record here, we find no basis for
concluding that the relevant consumers would need to engage in a multi-stage
reasoning process to determine the significance of NATURAL BRIDGE CAVERNS
when applied to Applicant’s services.
Applicant also asserts that “the weight of evidence shows consumers would
perceive NATURAL BRIDGE CAVERNS as a unitary phrase denoting applicant or
it its brand.”54 To the extent that Applicant is arguing that NATURAL BRIDGE
CAVERNS has acquired distinctiveness among the relevant consumers as a source
indicator for its cavern attraction, we note, as the Examining Attorney does,55 that
Applicant has not made a claim of acquired distinctiveness as to the proposed mark
in connection with the identified services in any of the involved applications, nor has
Applicant otherwise presented any evidence that would support such a claim.56
Lastly, Applicant notes that, if any doubt exists as to whether the proposed marks
are merely descriptive, the doubt must be resolved in Applicant’s favor.57 While we
54 Applicant’s Appeal Brief, 7 TTABVUE 11 (converted to standard capitalization).
55 Examining Attorney’s Brief, 9 TTABVUE 11-12.
56 See Applicant’s Reply Brief, 12 TTABVUE 7 (“Here, Applicant does not seek registration
under Section 2(f).”).
57 Id. at 10.

Serial Nos. 97438479, 97438507, 97546721 & 97546743
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agree with that general proposition, it is not a thumb on the scale that displaces a
conclusion the record otherwise compels. See In re Berkeley Lights, Inc., No.
88895703, 2022 TTAB LEXIS 382, at *30 (“To be sure, when the Board has doubt on
the issue of descriptiveness, it resolves such doubt in favor of the applicant. But the
‘rule of doubt’ applies only where the Board expresses some doubt.” (citations
omitted)).
Here, we have no doubt as to our conclusion. The dictionary evidence establishes
a single, settled meaning for each component term, and the record contains no
evidence that either “natural bridge” or “caverns”—or the combination—carries any
alternative or ambiguous significance in relation to the identified services. The third-
party evidence demonstrates that accommodations, campgrounds, parking facilities,
event facilities, and similar services are routinely offered to provide access or
proximity to cavern and natural-bridge attractions. And Applicant’s own responses
to the request for information confirm that its services are offered for the purpose of,
or as a means of accessing, precisely such an attraction. On this record, the
descriptive significance of the proposed mark as applied to Applicant’s services is not
a matter of degree or close judgment; it follows directly from the evidence, including
Applicant’s own admissions. Because our conclusion rests on that evidence rather
than on any unresolved uncertainty, the rule of doubt does not aid Applicant. See
Berkeley Lights, 2022 TTAB LEXIS 382, at *30.

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III. Conclusion
Two significant reasons for not registering merely descriptive marks are: “(1) to
prevent the owner of a mark from inhibiting competition in the sale of particular
goods [or services]; and (2) to maintain freedom of the public to use the language
involved, thus avoiding the possibility of harassing infringement suits by the
registrant against others who use the mark when advertising or describing their own
products.” In re Stereotaxis Inc., 429 F.3d 1039, 1042 (Fed. Cir. 2005) (quoting Abcor,
588 F.2d at 813). We have considered all the arguments58 and evidence of record here,
and conclude that NATURAL BRIDGE CAVERNS, when considered as a whole, is
merely descriptive of Applicant’s services. Thus, we agree with the Examining
Attorney that other entities in the marketplace who offer the same services in
connection with an attraction consisting of, or including, a cave system featuring a
58 Both Applicant and the Examining Attorney devote portions of their briefs to arguing
whether In re Pebble Beach Co., No. 73810571, 1991 TTAB LEXIS 14, applies to this case.
We agree with the Examining Attorney that Pebble Beach is inapposite here. It involved a
refusal under Trademark Act Section 2(e)(2), 15 U.S.C. § 1052(e)(2), specifically whether the
mark 17 MILE DRIVE was primarily geographically descriptive of the applicant’s goods and
services. See id. at *2. The Board found that it was not primarily geographically descriptive
and instead “function[ed] as a mark because it is through applicant’s efforts (whether directly
through advertising or indirectly through publicity) that the name given by applicant to part
of its land has come to be recognized as indicating a specific physical location.” Id. at *7.
Applicant asserts that Pebble Beach is thus relevant here, because “the PTO makes explicit
for the first time in its . . . Brief that NATURAL BRIDGE CAVERNS describes the location
where Applicant renders its services under Section 2(e)(1) even though it withdrew its
[previous] Section 2(e)(2) rejection.” Applicant’s Reply Brief, 12 TTABVUE 8. However,
Applicant misconstrues the Examining Attorney’s argument, which, in fact, reiterates that
the refusal is based on the “general descriptive meaning of the terms” in the proposed mark
and notes that “[t]he mere fact that applicant owns the land where the natural bridge and
caverns are located and chooses to use NATURAL BRIDGE CAVERNS to identify the
property does not itself make this wording distinctive.” Applicant’s Brief, 9 TTABVUE 11.

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naturally occurring bridge-like rock formation, should be free to use NATURAL
BRIDGE CAVERNS in advertising such services.59
Decision: We affirm the refusal to register Applicant’s proposed mark,
NATURAL BRIDGE CAVERNS, under Trademark Act Section 2(e)(1) in all four
applications.
59 See Examining Attorney’s Brief, 9 TTABVUE 12. Applicant argues “there is no competitive
need for other to use the phrase ‘natural bridge caverns.’” Applicant’s Brief, 7 TTABVUE 6.
For the reasons already stated, we find that the record shows otherwise. In any event, “there
is no requirement that the Examining Attorney prove that others have used the mark at
issue or that they need to use it, although such proof [is] highly relevant to an analysis under
Section 2(e)(1).” Fat Boys, 2016 TTAB LEXIS 150, at *10.