Kamiwaza Corp

THIS OPINION IS NOT A
PRECEDENT OF THE TTAB
Mailed: September 24, 2026
UNITED STATES PATENT AND TRADEMARK OFFICE
_____
Trademark Trial and Appeal Board
_____
In re Kamiwaza Corp
_____
Serial No. 99388183
_____
Daniel W. Roberts of Law Offices of Daniel W. Roberts LLC,
for Kamiwaza Corp.
Doritt Carroll, Trademark Examining Attorney, Law Office 116,
Heather Schubert, Managing Attorney.
_____
Before Larkin, Allard, and Lavache,
Administrative Trademark Judges.
Opinion by Allard, Administrative Trademark Judge:
Kamiwaza Corp (“Applicant”) seeks registration on the Principal Register of the
mark RE-BAC (in standard characters) for goods identified as “Downloadable
computer software for use in computer access control,” in International Class 9.1
1 Application Serial No. 99388183 was filed on September 11, 2025, under Section 1(a) of the
Trademark Act, 15 U.S.C. § 1051(a), based on Applicant’s claim of first use anywhere and
first use in commerce since September 11, 2025.

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The Trademark Examining Attorney refused registration of the proposed mark
under Section 2(e)(1) of the Trademark Act, 15 U.S.C. § 1052(e)(1), on the ground that
the proposed mark is merely descriptive of Applicant’s identified goods.
After the refusal was made final, Applicant requested reconsideration, which the
Examining Attorney denied.2 Applicant then filed a notice of appeal.3 The matter is
fully briefed.4 For the reasons discussed below, we affirm the refusal.
I. Mere Descriptiveness – Applicable Law
Merely descriptive terms are unregistrable under Section 2(e)(1) of the
Trademark Act.5 15 U.S.C. § 1052(e)(1). “A term 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.” 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)). “A mark ‘need not recite each feature of the relevant goods or services in detail
to be descriptive,’ it need only describe a single feature or attribute.” Id. at 1300
(quoting In re Dial-A-Mattress Operating Corp., 240 F.3d 1341, 1346 (Fed. Cir. 2001)).
2 March 25, 2026 Denial of Request for Reconsideration.
Page references herein to the application record refer to the online database of the USPTO’s
Trademark Status & Document Retrieval (“TSDR”) system.
3 1 TTABVUE.
References to the briefs on appeal refer to TTABVUE, the Board’s online docketing system.
The number preceding “TTABVUE” corresponds to the docket entry number; the number(s)
following “TTABVUE” refer to the page number(s) of that particular docket entry.
4 Applicant’s brief appears at 4 TTABVUE, the Examining Attorney’s brief appears at 6
TTABVUE, and Applicant’s reply brief appears at 7 TTABVUE.
5 A descriptive term that has acquired distinctiveness may be registered under Section 2(f) of
the Trademark Act, 15 U.S.C. § 1052(f). However, acquired distinctiveness is not at issue in
this appeal.

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See also In re Oppedahl & Larson LLP, 373 F.3d 1171, 1173 (Fed. Cir. 2004) (“A mark
may be merely descriptive even if it does not describe the ‘full scope and extent’ of the
applicant’s goods or services.”) (quoting Dial-A-Mattress, 240 F.3d at 1346).
Whether a term is merely descriptive is determined not in the abstract, but in
relation to the goods for which registration is sought, the context in which it is being
used on or in connection with the goods, and the possible significance that the term
would have to the average purchaser of the goods because of the manner of its use. In
re Abcor Dev. Corp., 588 F.2d 811, 814 (CCPA 1978); In re Omniome, Inc., No.
87661190, 2019 TTAB LEXIS 414, at *11 (TTAB 2019). In other words, the question
is whether someone who knows what the goods are will understand the mark to
convey information about them. In re TriVita, Inc., 783 F.3d 872, 874 (Fed. Cir. 2015);
DuoProSS Meditech Corp. v. Inviro Med. Devices, Ltd., 695 F.3d 1247, 1254 (Fed. Cir.
2012). Conversely, a mark is suggestive if it requires imagination, thought, and
perception to arrive at the qualities or characteristics of the goods. Omniome, 2019
TTAB LEXIS 414, at *10-11 (citing Earnhardt v. Kerry Earnhardt, Inc., 864 F.3d
1374, 1378 (Fed. Cir. 2017) (contrasting merely descriptive from suggestive marks)
and citing In re Franklin Cty. Hist. Soc’y, No. 77699113, 2012 TTAB LEXIS 326, at
*3-4 (TTAB 2012) (same)).
That a term may have different meanings in different contexts is not controlling.
In re RiseSmart, Inc., No. 85050089, 2012 TTAB LEXIS 448, at *8 (TTAB 2012). The
question is whether someone who is familiar with Applicant’s goods will understand

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the applied-for mark to directly convey information about them. DuoProSS, 695 F.3d
at 1254.
Evidence that a term is merely descriptive to the relevant purchasing public “may
be obtained from any competent source, such as dictionaries,” Bayer, 488 F.3d at 964,
as well as “advertising material directed to the goods[,]” Abcor Dev., 588 F.2d at 814.
It also may be obtained from websites and publications. In re N.C. Lottery, 866 F.3d
1363, 1368 (Fed. Cir. 2017); In re Nett Designs, Inc., 236 F.3d 1339, 1341-42 (Fed. Cir.
2001). Evidence that a term is merely descriptive similarly may come from an
applicant’s own usage. See, e.g., Chamber of Com., 675 F.3d at 1301 (content of
applicant’s website, along with articles discussing the activities of chambers of
commerce, constituted substantial evidence supporting the Board’s mere
descriptiveness finding). Additionally, evidence that a term is descriptive may be
found in its third-party usage in connection with products or services similar or
related to those at issue. Coach Servs., Inc. v. Triumph Learning LLC, 668 F.3d 1356,
1378 (Fed. Cir. 2012).
Where, as here, the applied-for mark is an acronym, we must consider whether it
is readily understood by relevant purchasers to be substantially synonymous with
the merely descriptive wording it represents. See Modern Optics, Inc. v. Univis Lens
Co., 234 F.2d 504, 506 (CCPA 1956); Baroness Small Ests., Inc. v. Am. Wine Trade,
Inc., No. 92051369, 2012 TTAB LEXIS 1224, at *25-26 (TTAB 2012) (holding CMS
not substantially synonymous with the grape varietals cabernet, merlot, and syrah
and therefore not merely descriptive for wine); In re Thomas Nelson, Inc., No.

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76681269, 2011 TTAB LEXIS 9, at *14-19 (TTAB 2011) (holding NKJV substantially
synonymous with merely descriptive term “New King James Version” and thus
merely descriptive of bibles). A mark consisting of an acronym 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) the 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.
Thomas Nelson, 2011 TTAB LEXIS 9, at *15.6
II. Analysis
We consider each part of the three-part inquiry in turn.
A. Is RE-BAC an Acronym for “Relationship-Based Access Control”?
The record shows that the proposed mark RE-BAC is an acronym for
“Relationship-Based Access Control,” as exemplified by the following excerpts of
third-party evidence:
• Wikipedia explains that “[i]n computer systems security, Relationship-
based access control (ReBAC) defines an authorization paradigm where
a subject’s permission to access a resource is defined by the presence of
6 The Thomas Nelson decision uses the term “abbreviation” in its three-part test, but it
concerned the initialism NKJV for the “New King James Version” of the bible. In the present
case, the applied-for mark RE-BAC is allegedly an acronym for “Relationship-Based Access
Control.” The Thomas Nelson three-part inquiry is the proper analysis whether the applied-
for mark is alleged to be an abbreviation, an initialism or an acronym for an allegedly merely
descriptive word or phrase. TRADEMARK MANUAL OF EXAMINING PROCEDURE (TMEP)
§ 1209.03(h) (May 2026) and cases cited therein.

Serial No. 99388183
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relationships between those subjects and resources.” It adds that “[i]n
contrast to role-based access control (RBAC), … ReBAC …, allows defining
more fine-grained permissions.”7
• Workos.com asks: “What is Relationship-Based Access Control
(ReBAC)?” and answers: “Relationship-Based Access Control
(ReBAC) is an authorization model that grants access based on user-
resource relationships, offering a more dynamic approach compared to
RBAC [Role-Based Access Control] and ABAC [Attribute-Based Access
Control].”8
• Auth0.com explains that “[t]his whole system, where your permissions
change based on your specific connection to a repo, a pull request, or an
organization is the core idea behind Relationship-Based Access Control
(ReBAC). It’s an authorization model based on how users work together.”9
• Amazon explains on its AWS Security Blog (https://aws.amazon.com) that
“Relationship-based access control (ReBAC) offers a more nuanced
approach [to effectively capturing the relationship between entities] by
using the relationships between the users and resources to make decisions
about permitted actions, thus addressing scenarios more efficiently than
other models.”10
• Permify.co states, in an article titled “Relationship Based Access
Control (ReBAC)” that “Permify was defined and structured as a true
Relationship Based Access Control (ReBAC) solution ….”11
• Aserto.com states that “Relationship-Based Access Control (ReBAC)
is a new take on the Access Control List (ACL) paradigm of cascading access
to each resource in a hierarchy, such as directories and files. ReBAC
generalizes this model into a relationship graph between subjects and
objects via relations. ReBAC models can be traversed as a graph to
determine whether a user or group has a certain permission on a
resource.”12
7 February 5, 2026 Office Action at TSDR 3 (footnotes omitted) (emphasis in original and
added).
8 Id. at TSDR 6 (emphasis added).
9 Id. at TSDR 4 (emphasis added).
10 Id. at TSDR 7 (emphasis added).
11 March 25, 2026 Denial of Request for Reconsideration at TSDR 2 (emphasis added).
12 Id. at TSDR 4 (emphasis added).

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• According to the Okta.com blog: “There are a few methods for implementing
authorization, two of the most popular being role-based access control
(RBAC) and relationship-based access control (ReBAC).”13
• Descope.com states that “Relationship-Based Access Control (ReBAC)
is part of Descope’s Fine-Grained Authorization (FGA) system ….”14 It also
states that “ReBAC introduces relationship-based access control to
handle scenarios where access depends on the specific relationships
between users and resources, not just their roles. You can use ReBAC as a
replacement for RBAC when you need more granular control, or as a
complement to RBAC when you need both role-based and relationship-
based authorization.”15
We acknowledge that the proposed mark RE-BAC includes a hyphen and that the
evidence discussed above (and other evidence discussed below) sometimes shows that
the acronym is displayed as “ReBAC,” i.e., without a hyphen. We do not consider the
acronym including a hyphen (RE-BAC) to create a different commercial impression
compared to the version without a hyphen (ReBAC). See, e.g., Mini Melts, Inc. v.
Reckitt Benckiser LLC, No. 91173963, 2016 TTAB LEXIS 151, at *15 (TTAB
2016) (“[T]he hyphen in Applicant’s mark MINI-MELTS does not distinguish it from
Opposer’s mark [MINI MELTS].”); Charrette Corp. v. Bowater Commc’n Papers Inc.,
No. 92016167, 1989 TTAB LEXIS 52, at *6 (TTAB 1989) (marks PRO-PRINT and
PROPRINT identical but for hyphen and confusion likely).
Moreover, Applicant itself uses both the hyphenated (RE-BAC) and unhyphenated
(REBAC) versions in its materials, as shown by the following excerpt from its website:
13 Id. at TSDR 5 (emphasis added).
14 Id. at TSDR 6 (emphasis added).
15 March 2, 2026 Final Office Action at TSDR 8 (emphasis added).

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Beyond RBAC → Re-BAC
A unified graph engine powers agents with attribute-
driven, ephemeral permissions, delegation chains, and full
auditability for 5th Industrial scale Contextual
Authorization …. Enterprise security for AI extends this
concept to relationship-based access control (ReBAC),
recognizing that agent permissions depend not just on their
role but on their relationships with data, systems, and
other agents.16
B. Is “Relationship Based Access Control” Merely Descriptive of the
Identified Goods?
Under the second part of the inquiry we must assess whether “Relationship Based
Access Control” is merely descriptive of Applicant’s goods. See Thomas Nelson, 2011
TTAB LEXIS 9, at *15. As explained above, we must determine descriptiveness from
the perspective of a relevant consumer who is familiar with the goods. See, e.g., Bayer,
488 F.3d at 963-64 (descriptiveness evaluated from perspective of “average purchaser
of the goods”). The goods identified in the application are “Downloadable computer
software for use in computer access control.” We find that relevant consumers are
persons with technical knowledge, experience, or background with software who want
software with suitable access controls.
Applicant’s own website touts that its software is superior in part because it
employs a “Relationship-Based Access Control” methodology to control user access.
For example, it states that “Kamiwaza is a distributed AI platform with contextual
authorization and relationship based access controls (ReBAC) built in.”17 And
16 Id. at TSDR 8 (bold and highlighting added).
17 March 2, 2026 Final Office Action at TSDR 7 (emphasis added).

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screen captures of Applicant’s website describe its implementation of “Relationship
Based Access Control (ReBAC)” methodology:
18
18 Id. (emphasis added).

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19
Applicant’s website also states:
• “Start with familiar RBAC patterns and evolve to advanced ReBAC and
contextual controls without platform migration.”20
• “Our ReBAC enforces mission context and prevents mosaic effects across
compartmentalized information.”21
• “Enterprise security for AI extends this concept to relationship-based
access control (ReBAC), recognizing that agent permissions depend not just
on their role but on their relationships with data, systems, and other agents.”22
The above evidence shows that the wording “Relationship Based Access Control”
is merely descriptive of Applicant’s downloadable computer software because
Applicant’s software employs this methodology of granting access.
19 Id. (emphasis added).
20 Id. (emphasis added).
21 Id. (emphasis added).
22 Id. at TSDR 9 (emphasis added).

Serial No. 99388183
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C. Is the Relevant Consumer Who Sees RE-BAC in Connection with
Applicant’s Identified Goods Likely to Recognize RE-BAC as an
Acronym for “Relationship Based Access Control”?
A relevant consumer who sees RE-BAC used with Applicant’s computer software
for granting access will recognize that RE-BAC is an acronym for “Relationship Based
Access Control.” The third-party evidence and Applicant’s own materials, both
discussed above, leave no doubt on this point. One need only notice how Applicant
and the third parties directly link the acronym ReBAC or its equivalent RE-BAC with
the phrase “Relationship Based Access Control” by displaying the two in close
proximity to each other when discussing the same.
We find that each part of the three-part inquiry has been met and, as a result, we
find that Applicant’s proposed mark RE-BAC is substantially synonymous with the
descriptive wording “Relationship Based Access Control,” that Applicant’s identified
goods employ the “Relationship Based Access Control” methodology of controlling
access, and that consumers seeing the acronym RE-BAC will recognize it as an
acronym for Relationship Based Access Control. As a result, Applicant’s RE-BAC
mark is merely descriptive of the identified goods.
D. Applicant’s Arguments
Applicant argues that
The Examining Attorney’s brief confirms the central
problem Applicant is seeking to address through this
appeal: that the refusal rests on the existence of a technical
concept, not on evidence that relevant purchasers
encountering RE-BAC as a trademark would immediately
perceive it as merely descriptive of Applicant’s software.

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Put more simply, the existence of a concept is not the same
thing as proof of immediate descriptive perception when
encountered as a trademark.
….
Applicant does not dispute that such a concept exists.
However, that is not the controlling question. Under TMEP
§ 1209.03(h), the Office must show that the applied-for
mark is substantially synonymous with merely descriptive
wording and that relevant consumers would recognize the
acronym, without explanation, as representing that
wording.
….
First, as just noted, the cited evidence consists primarily
of explanatory articles, tutorials, and materials defining a
technical authorization model. Those materials show that
the term “ReBAC” can be explained. They do not show that
purchasers encountering RE-BAC as a mark immediately
understand it as a product descriptor for downloadable
software, let alone downloadable software from the
Applicant. 23
We disagree. As an initial matter, the record is not limited to “explanatory articles,
tutorials, and materials defining a technical authorization model,”24 as Applicant
argues. Evidence of descriptiveness “may be obtained from any competent source,”
Bayer, 488 F.3d at 964, and it is well settled that for purposes of analyzing
descriptiveness, we may consider Applicant’s own materials showing how the mark
is used. N.C. Lottery, 866 F.3d at 1367. Indeed, Applicant’s own “materials may be …
‘the most damaging evidence’ in indicating how the relevant purchasing public
perceives a term.” In re Zuma Array Ltd., No. 79288888, 2022 TTAB LEXIS 281, at
23 7 TTABVUE 2 (emphasis added).
24 Id.

Serial No. 99388183
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*18 (TTAB 2022) (quoting In re Mecca Grade Growers, LLC, No. 86358219, 2018
TTAB LEXIS 64, at *24-25 (TTAB 2018)).
Moreover, Applicant’s argument that the Office must show that relevant
consumers must recognize the acronym “without explanation”25 mischaracterizes the
analysis set out by our precedent, as there is no such requirement. In any event,
Applicant’s own materials rely on the presumption that consumers would
immediately recognize the acronym and that it is synonymous with the descriptive
wording “Relationship Based Access Control.”
Having found that the acronym RE-BAC is merely descriptive of Applicant’s
computer software, Applicant’s argument that the evidence fails to show that
purchasers encountering RE-BAC as a mark would not immediately understand it as
a product descriptor for downloadable software, let alone downloadable software from
the Applicant,26 is not persuasive. The fact that Applicant may be the first to use the
term as a mark does not make the term inherently distinctive when the only
significance projected by the term is descriptive. Thomas Nelson, 2011 TTAB LEXIS
9, at *19 (citing In re Hunter Fan Co., No. 78195616, 2006 TTAB LEXIS 140, at *8-9
(TTAB 2006) (“[A] word need not be in common use in an industry to be descriptive,
and the mere fact that an applicant is the first to use a descriptive term in connection
with its goods, does not imbue the term with source-identifying significance.”)).
25 Id. See also 4 TTABVUE 5.
26 7 TTABVUE 2.

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Applicant argues that RE-BAC is capable of “any number of technical or
suggestive constructions (e.g., Rule-Evaluated Boundary Access Control;
Relationship-Enhanced Boundary Authorization; Regulated Enterprise
Backend Access Control; …), underscoring that even with respect just to software,
the mark does not convey a single, immediate descriptive meaning.”27 Applicant’s
argument is unavailing because it relies on the mistaken premise that the term is to
be considered in the abstract. “Whether consumers could guess what the product 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 (TTAB
2024) (quoting In re Am. Greetings Corp., No. 73284539, 1985 TTAB LEXIS 97, at *3-
4 (TTAB 1985)). Again, the term must be considered “in relation to the goods or
services for which registration is sought, the context in which the [term] is used, and
the possible significance that the [term] is likely to have to the average purchaser
encountering the goods or services in the marketplace.” Hangzhou Mengku, 2024
TTAB LEXIS 575, at *23-24. In view of the record here, we find no basis for
concluding that the relevant consumers seeking computer software featuring certain
computer access controls would need to engage in multi-stage reasoning to determine
the significance of RE-BAC when applied to such goods. Knowing that the goods are
“Downloadable computer software for use in computer access control,” and given the
above-discussion of Applicant’s own use, consumers would not perceive the mark as
“any number of technical or suggestive constructions [such as] Rule-Evaluated
27 4 TTABVUE 5 (italics in original, bold here).

Serial No. 99388183
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Boundary Access Control”28 but rather merely descriptive of the goods, i.e., computer
software for controlling access employing a Relationship Based Access Control model.
In other words, we have no doubt that “someone who knows what the goods . . . are
will understand the mark to convey information about them.” In re Fallon, No.
86882668, 2020 TTAB LEXIS 464, at *21-22 (TTAB 2020).
Applicant contends that the hyphen between RE and BAC is “not commonly used
or recognized as a descriptive acronym by relevant purchasers” and “naturally reads
as ‘re-back’ – suggesting restoration, reenablement, or bringing access back.”29 “That
meaning,” Applicant adds, “is not descriptive of the identified goods, but instead
suggestive of a result or capability.”30 The Examining Attorney argues that “‘Re-back’
is not in fact a word.”31 She adds that
nothing in the applicant’s materials discussing its product
encourages purchasers to read the mark this way. It might
be different if the applicant advertised its software by
saying something like “return to a time when controlling
access was easy,” but none of the evidence of record makes
such a statement. Because of this, there is little reason to
believe that consumers looking for authentication software
would read the mark as anything other than what it is --
software that uses the RE-BAC model of controlling
access.32
We agree with the Examining Attorney. Applicant’s argument is simply unsupported
by the record and unpersuasive.
28 4 TTABVUE 5 (italics in original).
29 Id. at 7.
30 Id. 7.
31 6 TTABVUE 7.
32 Id. at 7.

Serial No. 99388183
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Applicant also argues that its proposed mark is a double entendre and therefore
registrable: “The hyphen visually separates the term and supports the alternate
double entendre ‘re-back’ commercial impression.”33 We disagree. A double entendre
is a word or expression capable of more than one interpretation and is unitary by
definition. TMEP § 1213.05(c). A mark that is in fact a double entendre will not be
refused registration as merely descriptive if one of its meanings is not merely
descriptive in relation to the goods. Id. However, the multiple meanings that make
an expression a double entendre must be well-recognized by the public and readily
apparent from the mark itself in the context of the identified goods. See Robinson v.
Hot Grabba Leaf, LLC, No. 92060394, 2019 TTAB LEXIS 96, at *30-31 (TTAB 2019),
cancellation order vacated on default judgment, No. 0:19-cv-61614-DPG (S.D. Fla.
Dec. 17, 2019); In re Calphalon Corp., No. 86356713, 2017 TTAB LEXIS 98, at *30-
31 (TTAB 2017). Here, Applicant cites no evidence that the relevant public would find
that the claimed double entendre is “readily apparent” from the mark, and we find it
unpersuasive in light of Applicant’s own use of ReBAC followed by the parenthetical
“(Relationship Based Access Control)” in its own materials and consistent with
industry usage. We find Applicant’s mark is merely descriptive, and that there is no
double entendre to render the mark not so.
33 7 TTABVUE 4. See also 4 TTABVUE 7-8.

Serial No. 99388183
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Decision:
The refusal to register Applicant’s proposed mark RE-BAC (Serial No. 99388183)
on the ground of mere descriptiveness under Section 2(e)(1) of the Trademark Act, 15
U.S.C. § 1052(e)(1), is affirmed.