Paycom Payroll, LLC

THIS OPINION IS NOT A
PRECEDENT OF THE TTAB
Hearing: October 7, 2025 Mailed: February 19, 2026
UNITED STATES PATENT AND TRADEMARK OFFICE
_____
Trademark Trial and Appeal Board
_____
In re Paycom Payroll, LLC
_____
Serial No. 97876391
_____
Zachary A.P. Oubre of McAfee & Taft,
for Paycom Payroll, LLC.
Alison Pollack, Trademark Examining Attorney, Law Office 106.
Mary Sparrow, Managing Attorney.
_____
Before Pologeorgis, Lebow and Brock,
Administrative Trademark Judges.
Opinion by Lebow, Administrative Trademark Judge:
Applicant, Paycom Payroll, LLC, seeks to register the standard-character mark
GLOBAL HCM
on the Principal Register for a variety of goods and services and services in the field
of “human capital management” as set forth below:
Downloadable MP3 files and podcasts in the field of human
resources management; Downloadable computer software,
namely, mobile applications, for use in managing data and data
applications in the field of human resources management, human
capital management, and payroll processing (International Class
9);

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Human resources management and human resources
management in the nature of human capital management;
Payroll processing and preparation services; Tax filing services;
Human resources analysis and consulting services regarding
human capital management tools; Consulting services in the field
of human resources development, namely, for the promotion of
employee retention, career growth, and increased productivity for
employees and employers; Tracking, comparing and monitoring
employee expenses for others for cost accounting purposes;
Providing business services to employers, namely, payroll
processing, human resources management, human resources
management in the nature of human capital management, and
travel and business expense management services; providing
business services in the nature of timekeeping services for others,
in particular employee time and attendance record keeping for
the purpose of tax filing and human resources and human capital
management and analysis; tax reporting, namely, tax filing;
business advisory and consulting services relating to software for
aiding in compliance with statutory, industry or best practice
provisions; computerized database management services;
statistical information services for business purposes; providing
electronic payroll tax preparation; Providing business
management, employment record keeping, statistical
information, payroll processing, and financial recordkeeping for
human resources and human capital management and analysis;
Personnel recruitment consultancy services in the nature of
assistance with tools for recruitment and applicant tracking;
Providing on-line employment placement services, namely,
matching resumes and potential employers via a global computer
network; Financial record-keeping for pension accruement and
payment purposes; disseminating the advertisements of others
via a global computer network; business investigations;
conducting business surveys; business research; business
auditing; Conducting employee surveys for others for purposes of
improving employee performance and morale; Business
administration of employee benefit plans concerning legal
services; Employment hiring, recruiting, placement, staffing and
career networking services; Testing to determine employment
skills for training purposes; Business services, namely,
timekeeping services for others; providing a web site featuring
information for employee benefits brokers and consultants in the
field of payroll processing, payroll preparation in the nature of tax
deposit filing and reporting, human resources management,
human resources management in the nature of human capital

Serial No. 97876391
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management, business management, employee timekeeping
services for others, in particular time and attendance record-
keeping for payroll purposes, financial pension record-keeping for
administration of pension funds, employee recruiting and
outsourcing services; data processing services (International
Class 35);
Payroll tax debiting services; Tax payment processing services;
Financial transaction services, namely, providing secure
commercial transactions and payment options; Administration of
employee benefits plans concerning insurance and finance;
Providing financial services to employers, namely, payroll tax
debiting and, employee financial benefits plans administration,
workers compensation claims administration, insurance agency,
financial administration of employee pension plans and
retirement funds plans financial administration; Insurance
claims administration; Financial affairs and monetary affairs,
namely, financial information, management and analysis
services; Administration of employee benefit plans concerning
insurance and finance; Workers compensation claims
administration; Financial administration of employee pension
plans and retirement plans; Providing a web site featuring
information for employee benefits brokers and consultants in the
field of insurance and employee financial benefits plans
administration and employee health care insurance benefits
plans reform (International Class 36);
Educational services, namely, providing podcasts and non-
downloadable webinars in the field of human resources
management, human capital management, and technology;
Educational and training services, namely, providing online
classes, seminars, and workshops in the field of human resources
management and human capital management; Providing an
online educational classroom environment featuring instruction
for employers in the field of payroll processing, tax deposit filing
and reporting, employee time and attendance record keeping,
pension record keeping, employee leasing, submitting and
tracking vendor invoices; employee training services in the field
of career development; providing on line non downloadable
electronic publications, namely, newsletters, white papers, case
studies and magazines in the field of human resources, payroll
administration, pre-employment and benefits administration,
computer security and information technology, career
development, disaster planning and computer system security;

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providing a website featuring resources, namely, a website
featuring non-downloadable publications in the nature of
whitepapers and blog articles in the field of human resources
(International Class 41); and
Software as a service (SAAS) services featuring software for use
in managing data and data applications in the field of human
resources management and human capital management,
employee on-boarding, employee records, payroll preparation and
processing, payroll tax debiting, benefits administration,
performance management, compensation management,
succession planning, talent management, and time and labor
management; Providing temporary use of online non-
downloadable software for providing employers with a compatible
interface between payroll processing software and software for
financial management and management of human resources;
Providing temporary use of online non-downloadable computer
software in the field of accounting for preparing and processing
business employee payroll for employers, and for printing payroll
documents, namely, reports, checks, and tax forms; Providing
temporary use of non-downloadable computer software for
performing employee and personnel related services, namely,
payroll processing, preparation, and administration, payroll tax
calculation and preparation, monitoring tax regulation
compliance, electronically processing payroll, tax filing and
reporting, printing payroll reports, checks, and tax forms,
employee benefits administration, managing human resources
documents, providing employee risk and safety training,
providing information about employee counseling and support
programs, administering employee pension and retirement funds
and employee flexible spending accounts, administering workers
compensation claims and payments, processing and storing
employee recruiting documents, conducting pre-employment
background screening, processing employee time and attendance
records, scheduling appointments, providing information for new
employee assimilation, employee recordkeeping management,
recording and tracking employee performance management,
database management of compensation, providing information
about employee job training and professional development and
succession planning; providing a web site featuring technology
that enables employee benefits brokers and consultant users to
view online videos in the field of benefits administration, payroll
processing, tax deposit filing and reporting, human resources
management, human capital management, business

Serial No. 97876391
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management, employee time and attendance record keeping,
pension record keeping, employee recruiting, pre-employment
background screening, outsourcing, health care reform and
unemployment compensation management services; Providing a
web based system and online portal featuring non-downloadable
software for employee benefits brokers and consultants to use in
employee benefits administration, pension record keeping, and
unemployment compensation management; Application service
provider services, namely, hosting, managing, developing, and
maintaining software applications of others in the field of
employment to allow off-site field employees to submit time and
labor data to employers via wireless communication and wireless
delivery of content to handheld computers and mobile electronic
devices; personnel recruitment tools and software, namely,
providing temporary use of online, non- downloadable personnel
recruitment software and software development tools for use in
data and database management (International Class 42). 1
After the Trademark Examining Attorney issued a final refusal to register
GLOBAL HCM on the ground that it is merely descriptive of the identified goods and
services under Section 2(e)(1) of the Trademark Act, 15 U.S.C. § 1052(e)(1), Applicant
filed a request for reconsideration, and an appeal.2 The request for reconsideration
was denied, and the appeal resumed.3 Both Applicant and the Examining Attorney
filed briefs,4 a hearing was conducted on October 7, 2025,5 and the appeal is now
1 Application Serial No. 97876391 was filed on April 6, 2023, under Section 1(b) of the
Trademark Act, 15 U.S.C. § 1051(b), based on Applicant’s alleged bona fide intent to use the
mark in commerce.
2 See December 1, 2023 Final Office Action; February 29, 2024 Request for Reconsideration;
1 TTABVUE (Notice of Appeal).
3 See 4 TTABVUE (Reconsideration Letter); 5 TTABVUE (Order Resuming Appeal).
Citations to the prosecution file refer to the USPTO’s Trademark Status & Document
Retrieval (“TSDR”) system and identify the documents by title, date, and page in the
downloadable .pdf version. Citations to the briefs and other materials in the appeal record
refer to the Board’s TTABVUE online docket system.
4 6 TTABVUE (Applicant’s Brief); 8 TTABVUE (Examining Attorney’s Brief).
5 14 TTABVUE.

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ready for final decision.6 For the reasons discussed below, we affirm the refusal.
I. Mere Descriptiveness – Applicable Law
“One basis for refusing a trademark registration is when ‘a mark which ... when
used on or in connection with the goods [or services] of the applicant is merely
descriptive … of them.’ 15 U.S.C. § 1052(e)(1).” Curtin v. United Trademark Holdings,
Inc., 137 F.4th 1359, 1361 (Fed. Cir. 2025). “A mark is merely descriptive if it
immediately conveys knowledge of a quality, feature, function, or characteristic of the
goods or services with which it is used.” Brooklyn Brewery Corp. v. Brooklyn Brew
Shop, LLC, 17 F.4th 129, 146 (Fed. Cir. 2021) (quoting Coach Servs., Inc. v. Triumph
Learning LLC, 668 F.3d 1356, 1378 (Fed. Cir. 2012) and In re Bayer
Aktiengesellschaft, 488 F.3d 960, 963 (Fed. Cir. 2007)) (internal punctuation omitted).
In contrast, a mark is suggestive if the evidence shows that “imagination, thought
and perception” are required to arrive at the features, qualities, or characteristics in
question. See, e.g., In re N.C. Lottery, 866 F.3d 1363, 1367 (Fed. Cir. 2017); Earnhardt
v. Kerry Earnhardt, Inc., 864 F.3d 1374, 1378 (Fed. Cir. 2017).
“A term ‘need not immediately convey an idea of each and every specific feature
of the [services] in order to be considered merely descriptive; it is enough if it
describes one significant attribute, function or property of the [services].’” In re Korn
Ferry, No. 90890949, 2024 TTAB LEXIS 224, at *5 (quoting In re Fat Boys Water
Sports LLC, 2016 TTAB LEXIS 150, at *5). And “[i]t is well-established that
6 The Examining Attorney also made final a refusal to register the mark on the ground that
the identification of goods and services was indefinite, but withdrew that ground for refusal
in her brief. See 8 TTABVUE 2-3.

Serial No. 97876391
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‘[d]escriptiveness of a mark is not considered in the abstract,’” but instead “must be
‘considered in relation to the particular 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 because of the manner of its
use or intended use.’” Coach Servs., 668 F.3d at 1378 (quoting Bayer, 488 F.3d at 963-
64).
A term, letters, an initialism, or an acronym is merely descriptive when it is a
recognized abbreviation for the goods or services in the application, or is otherwise
understood as being “substantially synonymous” with the merely descriptive words
it represents. In re Thomas Nelson, Inc., Serial No. 76681269, 2011 TTAB LEXIS 9,
at *14-15 (TTAB 2011) (citing Modern Optics, Inc. v. Univis Lens Co., 234 F.2d 504,
506 (CCPA 1956) (holding NKJV substantially synonymous with merely descriptive
term “New King James Version” and thus merely descriptive of bibles)); see also In re
BetaBatt Inc., Serial No. 77036122, 2008 TTAB LEXIS 59, at *9-11 (TTAB 2008)
(holding DEC substantially synonymous with merely descriptive term “direct energy
conversion” and thus merely descriptive of a type of batteries and battery related
services).
We “consider the commercial impression of a mark as a whole[.]” Real Foods Pty
Ltd. v. Frito-Lay N. Am., Inc., 906 F.3d 965, 974 (Fed. Cir. 2018) (italics omitted).
“Where a mark consists of multiple words, the mere combination of descriptive words
does not necessarily create a non-descriptive word or phrase.” Zuma Array, 2022
TTAB LEXIS 281, at *8 (quoting In re Omniome, Inc., No. 87661190, 2019 TTAB

Serial No. 97876391
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LEXIS 414, at *12). “[I]f 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.” Omniome, 2019 TTAB LEXIS 414, at *12. Only where the
combination of merely descriptive terms creates a unitary mark, or a mark with a
unique, incongruous, or otherwise nondescriptive meaning in relation to the goods or
services is the mark registrable as suggestive. See In re Oppedahl & Larson LLP, 373
F.3d 1171, 1174 (Fed. Cir. 2004) (citing In re Nat’l Data Corp., 753 F.2d 1056, 1058
(Fed. Cir. 1985)).
Refusals for mere descriptiveness, like other refusals, are based on evidence
bearing on public perception of the mark. See, e.g., In re Slokevage, 441 F.3d 957, 960
(Fed. Cir. 2006); In re Nett Designs, Inc., 236 F.3d 1339, 1341 (Fed. Cir. 2001).
Evidence that a term is merely descriptive to the relevant purchasing public may be
obtained from any competent source, Nett Designs, 236 F.3d at 1341, such as
dictionaries, newspapers, or surveys. Bayer, 488 F.3d at 964. It also may be obtained
from websites and publications. N.C. Lottery, 866 F.3d at 1368. “The determination
of whether a mark is merely descriptive is a question of fact.” DuoProSS Meditech
Corp. v. Inviro Med. Devices, Ltd., 695 F.3d 1247, 1252 (Fed. Cir. 2012).
II. The Examining Attorney’s Evidence and Arguments
As noted above, the Application identifies a variety of goods and services in the
field of “human capital management.” According to the Examining Attorney:
The evidence in the record shows that the wording “GLOBAL
HCM” is commonly used in connection with human capital
management software and human capital management
consulting, finance and training services, and that competitors

Serial No. 97876391
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use the wording “GLOBAL HCM” to describe a feature of their
human capital management software and human capital
management, consulting, finance and training services. Thus, the
wording “GLOBAL HCM” immediately conveys to consumers that
Applicant provides human capital management goods and
services on a global or worldwide scale.7
The Examining Attorney cites inter alia to the follow evidence of record for support
(emphasis added):
• An entry from THE AMERICAN HERITAGE Dictionary defines “global” as
”[o]f, relating to, or involving the entire earth; worldwide; [e.g.,] global
war; global monetary policies”; “comprehensive; total.”8
• Four third-party registrations of the marks RE GLOBAL and Design,
GLOBAL PMI PARTNERS and Design, BLUEBACK GLOBAL, and
MANNING GLOBAL for goods or services that the Examining Attorney
asserts are the same or similar to Applicant’s goods or services; which
disclaim the term GLOBAL.9
• An entry from the website Acronym Finder (acronymfinder.com)
indicates that that “HCM stands for Human Capital Management,”
and explains that this definition “appears very frequently and is found
in the following Acronym Finder categories: ● Business, finance, etc.”10
• Gartner (garner.com) provides an information technology glossary that
defines “Human Capital Management (HCM)” as “a set of practices
related to people resource management” that are “focused on the
organizational need to provide specific competencies and are
implemented in three categories: workforce acquisition, workforce
management and workforce capitalization.”11
7 8 TTABVUE 6 (Examining Attorney’s Brief).
8 May 24, 2023 Office Action, at TSDR 11.
9 December 1, 2023 Final Office Action, at 3, 9-15, 20-21. A fifth registration for the mark
GLOBAL PAYROLL CALCULATOR that disclaimed “GLOBAL” was not considered because
it was cancelled. See Made in Nature, LLC v. Pharmavite LLC, No. 91223352, 2022 TTAB
LEXIS 228, at *31 (“A cancelled or expired registration has no probative value other than to
show that it once issued.”).
10 May 24, 2023 Office Action, at TSDR 13.
11 Id. at 24-25.

Serial No. 97876391
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• Oracle (oracle.com) provides software as a service (SAAS) that it refers
to as “Oracle Human Capital Management (HCM),” a “complete
cloud solution that connects every human resource process—and every
person—across [one’s] enterprise.” This software allows companies to
“[e]ffectively manage a global workforce,” namely to “[p]lan, manage,
and optimize global people process with one common data source.”12
“The term HCM can refer both to a business strategy and to a set of
modern IT applications and other technologies that are used to
implement that strategy.”13
And under the heading “HCM—A brief history,” Oracle explains:
The term “human capital” was first used in the 1950s and 60s as
computing began to accelerate the automation that had begun in
the industrial age. …
Not surprisingly, the term returned to prominence with the rise
of the internet in the late 1990s. New technologies were rapidly
automating a whole new set of business process. While the
internet changed the how employers and managers collaborated.
All of this change meant that workforce leaders had to transform
how they went about attracting, retaining, and engaging talent in
an evolving set of job roles.
This decade could be called The Golden age of HCM. ….14
• Ceridian (ceridian.com) refers to its Dayforce software for providing a
“global people platform” to “Empower people, simplify compliance, and
unlock workforce intelligence” as “Global HCM Software.”15
• Goldman Sachs (goldmansachs.com) explains on its website, under the
heading “Human Capital Management,” that “Human Capital
Management (HCM) takes a strategic approach to attracting,
developing and managing a global workforce.”16
• The Global HCM Institute (ghcinstitute.com) provides consulting,
12 Id. at 17-23.
13 Id. at 30.
14 Id. at 34.
15 Id. at 16.
16 Id. at 46-47.

Serial No. 97876391
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training, certification, and applied research in the field of HCM. “As a
member of HCI, USA we have an international recognition in human
capital management field.”17
• ADP (adp.com) answers the question, “What is human capital
management (HCM)?” According to ADP, “Human capital
management (HCM) is the process of hiring the right people,
managing workforces effectively and optimizing productivity,” which
“has evolved from a mostly administrative function to a critical enable
of business value.” Among other things, “HCM technology … can help
you: … ● improve regulatory compliance[.] Global and local monitoring
capabilities may allow you s stay current with changing regulations.” 18
• ClearCourse Consulting describes itself on LinkedIn describes itself as
“Human Capital Management Experts.” In a November 8, 2023 article
on LinkedIn titled “Navigating the Global HCM vendor Selection
Process: Pitfalls to Watch For.”19 The article explains:
The process of selecting a global HCM vendor is a substantial
undertaking that can significantly impact your organization’s
ability to manage its workforce efficiently and effectively. By
being aware of the potential pitfalls and taking steps to mitigate
them, you can increase your chances of a successful vendor
selection process and a seamless global HCM implementation.
Prioritizing factors such as compliance, scalability, cultural
adaptation, integration, user experience, data security, and total
cost of ownership will lead to a more informed decision and a
better long-term outcome for your organization. Remember that
careful planning and consideration can make all the difference in
your global HCM journey.20
Based on the foregoing, the Examining Attorney contends that “the relevant
public understands that the wording ‘HCM’ identifies an acronym for “Human
Capital Management,” and that “GLOGAL HCM” is highly descriptive in relationship
17 December 1, 2023 Final Office Action, TSDR 30-36.
18 Id. at 37-44.
19 Id. at 45-49.
20 Id. at 49.

Serial No. 97876391
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to Applicant’s goods and services … .”21
Notably, while the Examining Attorney argues that “Applicant’s mark is merely
descriptive of Applicant’s goods and services,”22 and, more specifically, that “the
wording ‘GLOBAL HCM’ immediately conveys to consumers that Applicant provides
human capital management goods and services on a global or worldwide scale,”23 the
Examining Attorney does not discuss the identification of goods and services on a
class-by-class basis to ensure that the mark is indeed descriptive of at least one good
or services in each class of the application. But to refuse registration of the application
in its entirety, the Examining Attorney must show that the subject mark is merely
descriptive of at least one of each of the goods and services in each class of the
application. In re Chamber of Commerce of the U.S., 675 F.3d 1297, 1301 (Fed. Cir.
2012) (citing In re Stereotaxis Inc., 429 F.3d 1039, 1041 (Fed. Cir. 2005)).
Fortuitously for the Examining Attorney, it is obvious from Applicant’s
identification of goods and services, itself, in Classes 9, 35, 41 and 41 that HCM is
descriptive of a characteristic, function, feature, purpose or use of at least one good
or services in each such class:
Class 9 identifies goods including “Downloadable computer software,
namely, mobile applications, for use in managing data and data
applications in the field of human resources management, human
capital management, and payroll processing (International Class 9);
Class 35 identifies services including “Human resources management
and human resources management in the nature of human capital
21 8 TTABVUE 8-9 (Examining Attorney’s Brief).
22 Id. at 1.
23 Id. at 6.

Serial No. 97876391
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management; Human resources analysis and consulting services
regarding human capital management tools; Providing business
services to employers, namely, payroll processing, human resources
management, human resources management in the nature of human
capital management; providing business services in the nature of
timekeeping services for others, in particular employee time and
attendance record keeping for the purpose of tax filing and human
resources and human capital management and analysis; and human
resources management in the nature of human capital
management”;
Class 41 identifies services including “Educational services, namely,
providing podcasts and non-downloadable webinars in the field of
human resources management, human capital management, and
technology; Educational and training services, namely, providing online
classes, seminars, and workshops in the field of human resources
management and human capital management; and
Class 42 identifies services including “Software as a service (SAAS)
services featuring software for use in managing data and data
applications in the field of human resources management and human
capital management.
It is less obvious that HCM describes a characteristic, function, feature, purpose,
or use of the services in Class 36, which identifies:
Payroll tax debiting services; Tax payment processing services;
Financial transaction services, namely, providing secure commercial
transactions and payment options; Administration of employee benefits
plans concerning insurance and finance; Providing financial services to
employers, namely, payroll tax debiting and, employee financial benefits
plans administration, workers compensation claims administration,
insurance agency, financial administration of employee pension plans
and retirement funds plans financial administration; Insurance claims
administration; Financial affairs and monetary affairs, namely,
financial information, management and analysis services;
Administration of employee benefit plans concerning insurance and
finance; Workers compensation claims administration; Financial
administration of employee pension plans and retirement plans;
Providing a web site featuring information for employee benefits brokers
and consultants in the field of insurance and employee financial benefits
plans administration and employee health care insurance benefits plans
reform.

Serial No. 97876391
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But we nevertheless find that it does. Specifically, the third-party evidence of record
describes HCM (or “human capital management”) as an integrated business strategy
and technology suite for acquiring, managing, compensating, and optimizing a global
workforce:
• Gartner defines HCM as practices focused on workforce acquisition,
workforce management, and workforce capitalization.24
• Oracle positions its HCM cloud solution as connecting ever HR process
across the enterprise, expressly including the ability to ‘plan, manage, and
optimize global people process[es]” and to manage a global workforce.25
• Goldman Sachs describes HCM as a strategi approach to “attracting,
developing and managing a global workforce.”26
• ADP explains that HCM has evolved into a critical enabler of business value
through technology that improves regulatory compliance, with “global and
local monitoring capabilities” for changing regulations.27
• Ceridian markets its Dayforce platform as “Global HCM Software” that
empowers people, simplifies compliance, and unlocks workforce
intelligence.28
• And the ClearCourse Consulting article and the Global HCM institute
further treat HCM as the overarching field encompassing global vendor
selection, compliance, scalability, and workforce-related financial and
administrative functions.29
Thus, the acronym HCM (or “human capital management”) is descriptive of the
24 See note 9 supra.
25 See note 10 supra.
26 See note 14 supra.
27 See note 16 supra.
28 See note 13 supra.
29 See notes 15 and 18, supra.

Serial No. 97876391
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employee compensation services identified in Class 36.
III. Applicant’s Evidence and Argument
Applicant acknowledges the test set forth in Thomas Nelson, 2011 TTAB LEXIS
at *14-15, for determining whether a mark or term is an abbreviation, acronym, or
initialism for the merely descriptive wording that it represents:30
A mark consisting of an abbreviation, acronym, or initialism will be
considered substantially synonymous with descriptive wording if: (1) the
applied-for mark is an abbreviation, acronym, or initialism for specific
wording; (2) the specific wording is merely descriptive of applicant’s
goods and/or services; and (3) a relevant consumer viewing the
abbreviation, acronym, or initialism in connection with applicant’s goods
and/or services will recognize it as an abbreviation, acronym, or
initialism of the merely descriptive wording that it represents.
Id. at *15. Applicant does not dispute that the first two prongs of that test—that HCM
is an acronym for the wording “Human Capital Management” (Prong 1) and that
“Human Capital Management” is merely descriptive of the goods or services
identified in the application (Prong 2)—have been satisfied in this case.31 Applicant,
instead, maintains that “the evidence of record fails to support the Examining
Attorney’s conclusion with respect to the third prong of this test,”32 which is that
relevant consumers of Applicant’s goods and services will recognize HCM as an
acronym for “Human Capital Management.”
Applicant argues that the Examining Attorney’s reliance on the Acronym Finder
30 6 TTABVUE 6 (Applicant’s Brief).
31 Notwithstanding Applicant’s apparent concession as to the first two prongs of the Thomas
Nelson test, we review infra HCM’s descriptiveness as to the goods and services in each class
of the application.
32 Id.

Serial No. 97876391
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website is “misplaced” because:
[Acronym Finder] shows at least 34 possible meanings for HCM. Among
these are “High Capacity Multiplexing,” “Horizontal Connection
Module,” and “Handset Configuration Manager,” all of which are used
in relation to software and data and are pertinent here as Applicant’s
Services include software and data processing services. The Examining
Attorney’s evidence also reflects that HCM is a known acronym for the
heart disease “hypertrophic cardiomyopathy,” which acronym has
become even more well-known following a thirteen-billion-dollar
campaign by Bristol Myers to advertise treatment for the same.33
But it is Applicant’s argument that is misplaced. “Descriptiveness of a mark is not
considered in the abstract. Rather, it is considered in relation to the particular goods
[and 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 because of the manner of its use or intended use.” Bayer, 488 F.3d at 964
(citing In re Abcor Dev. Corp., 588 F.2d 811, 813 (CCPA 1978)). A word, phrase or
acronym may have different meanings in different contexts, but the question here is
what HCM means to relevant consumers who see it used in connection with
Applicant’s goods or services pertaining to Human Capital Management. Id.
Applicant asserts that “[t]he Examining Attorney’s conclusion mistakenly reasons
that, because HCM is an acronym for ‘human capital management,’ it is necessarily
substantially therewith.”34 For support, Applicant Modern Optics, where the Federal
Circuit’s predecessor, the Court of Customs and Appeals, found the record
“unconvincing” in showing that “CV” is substantially synonymous with “continuous
33 Id. at 7 (emphasis in original).
34 Id.

Serial No. 97876391
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vision.”35 Modern Optics, 234 F.2d at 506. In doing so, the Court cautioned that “[i]t
does not follow, however, that all initials of combinations of descriptive words are ipso
facto unregistrable.”36 This is a strawman argument, as the Examining Attorney does
not contend, as Applicant claims, that because HCM is an acronym for “human capital
management,” it is per se unregistrable. Rather, as the Examining Attorney notes in
her response:
In this case, Applicant’s goods and services include downloadable
computer software, namely, mobile applications, for use in managing
data and data applications in the field of human capital management,
human resources management in the nature of human capital
management, educational services, namely, providing podcasts and
nondownloadable webinars in the field of human capital management,
and Software as a service (SAAS) services featuring software for use in
managing data and data applications in the field of human capital
management. Thus, consumers would interpret “HCM” to mean
“Human Capital Management” in relation to the relevant goods and
services rather than the other meanings on AcronymFinder.com, such
as Ho Chi Minh City or Hypertrophic Cardiomyopathy.37
Modern Optics emphasized that “each case must be decided on the basis of the
particular facts involved.” 234 F.2d at 506.
Applicant contends that while the Examining Attorney’s third-party evidence
shows use of both “human capital management” and “HCM,” “none of these additional
references use the acronym HCM alone without the phrase ‘human capital
management.’”38 Applicant asserts that “this too supports Applicant as there would
35 Id.
36 Id. at 8.
37 8 TTABVUE 9 (Applicant’s Brief).
38 6 TTABVUE 8 (Applicant’s Brief).

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be no need to identify the full wording ‘human capital management’ if the acronym
HCM is substantially synonymous with the phrase as the Examining Attorney
concludes.”39 According to Applicant, “[t]his was the reasoning of In re Life cycle Eng.,
Inc., No. 85692710, [2014 TTAB LEXIS 319] (non-precedential),” where “the Board
found the evidence of record failed to show RBAM was substantially synonymous with
‘risk-based-asset-management’ because ‘the examples of use that [were] of record
never show[ed] the expression RBAM alone [without] ‘risk-based asset
management[.]” Id. at *22.
But as the Examining Attorney points out, the facts here are not analogous to Life
Cycle Eng.:
In this case, the evidence shows “HCM” frequently used without the
phrase “Human Capital Management” nearby. Indeed, Oracle uses
“HCM Products” and “HCM for Industries” as a header on their website
page and The Global HCM Institute uses “HCM” in its business name.
Websites and webpages, dictionaries, and publications are generally
competent sources for determining how the public perceives the mark in
connection with applicant’s goods and/or services.40
Excerpts of these uses are shown below:
41
39 Id.
40 8 TTABVUE 10 (Examining Attorney’s Brief).
41 May 24, 2023 Office Action, at TSDR 17.

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42
We recognize that, when a long phrase is used repeatedly in an article, it is a
common practice to indicate to the reader that subsequent references will be by
certain initials or by a single word. But in many of the third-party pages and articles
of record, HCM is clearly not being used solely as the author’s shorthand for “human
capital management,” but rather as an alternative for that term. For instance, the
Ceridian website mentioned above, which does not use parentheses when it mentions
human capital management, does not use HCM and the spelled-out terms together,
and otherwise uses HCM prominently:
42 December 1, 2023 Final Office Action, at TSDR 30.

Serial No. 97876391
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43
Other pages, such as the Oracle website, use acronyms or initialisms in
parentheses for abbreviations that are commonly understood, such as “HR,” thus
undercutting the suggestion that the acronym is used in parentheses merely to
educate the reader on the author’s shorthand.44 Oracle also uses the reverse order;
that is, putting “human capital management” in parentheses, followed by HCM, to
explain HCM software:
45
Separately, Applicant argues that “[t]he Examining Attorney has failed to support
the conclusion that GLOBAL is merely descriptive.”46 According to Applicant, the
Court of Customs and Patent Appeals (predecessor to the Court of Appeals for the
43 Id. at 22-29.
44 Id. at 30.
45 Id. at 33 (initial caps in original).
46 6 TTABVUE 10 (Applicant’s Brief).

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Federal Circuit) was instructive in this regard, holding “the word ‘Globe’ is not
merely a geographical name or term in the sense in which the phrase is used in the
statute.”47 See Champion Spark Plug Co. v. Globe-Union Mfg. Co., 88 F.2d 970, 972
(CCPA 1937). “Said another way,” continues Applicant, “because ‘globe’ has no
specific geographic significance, it cannot be merely descriptive of any location.”48
This argument is unavailing, as we need not reach back to the 1930s to know that
“global”—which means “”[o]f, relating to, or involving the entire earth; worldwide;
[e.g.,] global war; global monetary policies” “comprehensive; total”49—is a different
word that “globe,” which is just “something spherical or rounded: such as … a
spherical representation of the earth, a celestial body, or the heavens.”50 We find that
the GLOBAL is clearly descriptive of Applicant’s goods and services in the field of
human capital management that are provided globally, or comprehensively.
Applicant contends that GLOBAL cannot be descriptive because it has multiple
meanings:
Additionally, GLOBAL is only merely descriptive if it “immediately
conveys knowledge of a quality, feature, function, or characteristic of”
Applicant’s Services. [TRADEMARK MANUAL OF EXAMINING Procedure]
TMEP §1209.01(b) (emp. added). That is not the case here as GLOBAL
could signify several meanings within Applicant’s Services,
including that the services are offered worldwide, or a
consumer’s placement of personnel around the world, or use of
47 Id (emphasis in original).
48 Id.
49 May 24, 2023 Office Action, at TSDR 11.
50 https://www.merriam-webster.com/dictionary/globe (accessed February 17, 2026). See
University of Notre Dame du Lac v. J. C. Gourmet Food Imports Co., No. 91061847, 1982
TTAB LEXIS 146, at *7 (“[T]he Board may take judicial notice of use of a term in
dictionaries.”).

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services from different global locations. Consequently, there is no
immediately conveyed meaning of GLOBAL in relation to Applicant’s
Services.51
This too is an unavailing argument, as well as a concession that GLOBAL has three
descriptive meanings when applied to Applicant’s goods and services in the field of
human capital management. “That a term may have meanings in different contexts
is not controlling on the question of descriptiveness.” In re NextGen Mgmt., No.
85050089, 2012 TTAB LEXIS 448, at *8 (citing In re RiseSmart Inc., No. 85050089,
2012 TTAB LEXIS 448, at *8). See also In re Bright-Crest, Ltd., No. 73131713, 1979
TTAB LEXIS 80, at *8-9 (“[T]he fact that a term may have meanings other than the
one the Board is concerned with is not controlling on the question.”); TRADEMARK
MANUAL OF EXAMINING PROCEDURE § 1209.03(e) (Nov. 2025). “It is well settled that
so long as any one of the meanings of a term is descriptive, the term may be
considered to be merely descriptive.” In re Chopper Indus., 1984 TTAB LEXIS 118, at
*5-6. Because the standard for determining mere descriptiveness assumes that the
relevant public knows what the goods or services are, see, e.g., DuoProSS Meditech,
695 F.3d at 1254, our analysis must focus on the definition relevant to the goods and
services identified in the application. See, e.g., In re IP Carrier Consulting Grp., No.
78542726, 2007 TTAB LEXIS 66, at *18-19.
Applicant argues that the Examining Attorney’s third-party registration evidence
is not probative because “none of the [third-party] registrations relied upon [by the
51 6 TTABVUE 10 (Applicant’s Brief).

Serial No. 97876391
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Examining Attorney] claim rights in connection with human capital management.”52
“At most,” asserts Applicant, these third-party registrations show other applicants
for other services chose not to contest mere descriptiveness rejections.”53 We disagree.
The four third-party registrations submitted by the Examining Attorney are highly
probative of the descriptiveness of GLOBAL in the field of human capital
management. The relevant inquiry is whether the services fall within the HCM field
established by the record evidence; they plainly do. Each registration covers services
that constitute core components of HCM as defined in the record (workforce
acquisition, management, compensation, benefits/financial administration, and
global operations), even though the exact phrase “human capital management” does
not appear:
• RE GLOBAL and Design (Reg. No. 7489220) recites services that
include human resources management and business management
consulting (Class 35);
• GLOBAL PMI PARTNERS (Reg. No. 7028212) recites services that
include human resources management, consultancy, and related
training (Classes 35, 41);
• BLUEBACK GLOBAL (Registration No. 6675878) recites services
that include payroll administration and management, human
resources management, accounting, tax and regulatory compliance
services, and SaaS for HR and financial transactions (Classes 35, 42);
and
• MANNING GLOBAL (Reg. No. 6458157) recites services that
include human resources management and personnel recruitment,
financial valuations of employment compensation, and related
training and IT services (Classes 35, 41, 42).
52 Id.
53 Id.

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By expressly disclaiming GLOBAL in each registration, the owners conceded that the
term is, at a minimum, merely descriptive when used in connection with these HCM-
related services. See In re Pollio Dairy Prods. Corp., No. 73596577, 1988 TTAB
LEXIS 45, at *3-4 n.4 (“By its disclaimer of the word LITE, applicant has conceded
that the term is merely descriptive as used in connection with applicant's goods.”)
(citing State Oil Refining Corp. v. Quaker Oil Corp., 161 USPQ 547 (TTAB 1969),
aff’d, 453 F.2d 1296 (CCPA 1972)). Third-party registrations showing disclaimers of
a term for similar or overlapping services are competent evidence of descriptiveness.
Stereotaxis, 429 F.3d at 1041; TMEP § 1209.03(a) (Nov. 2025).
Having found that GLOBAL and HCM are each merely descriptive of at least one
or more goods and services in each class of the application, we further find that their
combination does not create a unitary mark with a unique, incongruous, or otherwise
nondescriptive meaning in relation to those goods and services. Rather, each
component retains its merely descriptive significance when used together in the field
of human capital management. See In re Omniome, Inc., 87661190, 2019 TTAB
LEXIS 414, at *12 (“[I]f 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.”); In re Oppedahl & Larson LLP, 373 F.3d 1171, 1174 (Fed. Cir.
2004). The composite GLOBAL HCM immediately conveys to relevant consumers—
employers and employee-benefits brokers and consultants—that Applicant offers
human capital management goods and services on a global or comprehensive scale.

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IV. Conclusion
In sum, the record demonstrates that HCM is a widely recognized acronym for the
merely descriptive phrase “human capital management,” and that relevant
consumers will immediately understand it as such when encountered in connection
with Applicant’s identified goods and services. There term GLOBAL is likewise
merely descriptive of the worldwide or comprehensive scope of those offerings, as
shown by dictionary definitions and third-party usage in the HCM field. When the
two terms are combined, each retains its descriptive significance, yielding a composite
mark that is itself merely descriptive. Applicant’s arguments to the contrary are
unpersuasive for the reasons set forth above.
Decision: The refusal to register is affirmed under Section 2(e)(1) of the
Trademark Act.