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ESTTA1113776 02/11/2021 in the UNITED STATES PATENT and TRADEMARK OFFICE BEFORE the TRADEMARK TRIAL and APPEAL BOARD Proceeding

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ESTTA1113776 02/11/2021 in the UNITED STATES PATENT and TRADEMARK OFFICE BEFORE the TRADEMARK TRIAL and APPEAL BOARD Proceeding Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov ESTTA Tracking number: ESTTA1113776 Filing date: 02/11/2021 IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD Proceeding 91246479 Party Plaintiff Paramount International Export Ltd Correspondence DANIELLE CRIONA Address ROLL LAW GROUP PC 11444 WEST OLYMPIC BLVD, 7TH FLOOR LOS ANGELES, CA 90064 UNITED STATES Primary Email: [email protected] 310-966-8771 Submission Plaintiff's Notice of Reliance Filer's Name Michael M. Vasseghi Filer's email [email protected], [email protected] Signature / Michael M. Vasseghi / Date 02/11/2021 Attachments Not Reliance.pdf(466255 bytes ) Chia Affidavit -redacted-public version - 1 of 2.pdf(5112008 bytes ) Chia Affidavit redacted-public version - 2 of 2.pdf(6071194 bytes ) IN THE UNITED STATES PATENT AND TRADEMARK OFFICE TRADEMARK TRIAL AND APPEAL BOARD PARAMOUNT INTERNATIONAL Opposition No. 91246479 EXPORT, LTD., Mark: FIJI FIRE Opposer, Application Ser. No.: 88003425 v. JENNIFER M. VAN WALDEN TA FIJI FIRE HOT SAUCE, Applicant. NOTICE OF RELIANCE {3167545.1} Opposer PARAMOUNT INTERNATIONAL EXPORT, LTD. (“PARAMOUNT”) submits of record in connection with this opposition proceeding copies of the documents set forth below. {3167545.1} EXHIBIT DATE DOCUMENT RELEVANCE 1. 2021-02-05 TSDR Printout of status of FIJI mark, Registration Number Ownership of trademark 2703620. 2. 2021-02-05 TSDR Printout of status of FIJI (stylized) mark, Ownership of trademark Registration Number 3282520. Date: February 11, 2021 PARAMOUNT INTERNATIONAL EXPORT, LTD. By: / Michael M. Vasseghi, Esq. / Michael M. Vasseghi, Esq. 11444 West Olympic Blvd., 7th Floor Los Angeles, California 90064 Telephone: (310) 966-8400 Facsimile: (310) 966-8810 [email protected] 3 EXHIBIT 1 2/5/2021 Status Search SN 2703620 For assistance with TSDR, email [email protected] and include your serial number, the document you are looking for, and a screenshot of any error messages you have received. STATUS DOCUMENTS MAINTENANCE Back to Search Print Generated on: This page was generated by TSDR on 2021-02-05 18:55:22 EST Mark: FIJI US Serial Number: 76162278 Application Filing Date: Nov. 10, 2000 US Registration Number: 2703620 Registration Date: Apr. 08, 2003 Register: Principal Mark Type: Trademark TM5 Common Status LIVE/REGISTRATION/Issued and Active Descriptor: The trademark application has been registered with the Offic Status: The registration has been renewed. Status Date: Apr. 30, 2013 Publication Date: Jan. 14, 2003 Mark Information Mark Literal Elements: FIJI Standard Character Claim: No Mark Drawing Type: 1 - TYPESET WORD(S) /LETTER(S) /NUMBER(S) Acquired Distinctiveness In whole Claim: Related Properties Information Claimed Ownership of US 2164851 Registrations: Goods and Services Note: The following symbols indicate that the registrant/owner has amended the goods/services: Brackets [..] indicate deleted goods/services; Double parenthesis ((..)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and Asterisks *..* identify additional (new) wording in the goods/services. For: NATURAL, SPRING AND ARTESIAN WATER FOR DRINKING Privacy - Terms https://tsdr.uspto.gov/#caseNumber=2703620&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=documentSearch 1/3 2/5/2021 Status Search SN 2703620 International Class(es): 032 - Primary Class U.S Class(es): 045, 046, 048 Class Status: ACTIVE Basis: 1(a) First Use: May 16, 1997 Use in Commerce: May 17, 1997 Basis Information (Case Level) Filed Use: Yes Currently Use: Yes Filed ITU: No Currently ITU: No Filed 44D: No Currently 44E: No Filed 44E: No Currently 66A: No Filed 66A: No Currently No Basis: No Filed No Basis: No Current Owner(s) Information Owner Name: FIJI WATER COMPANY PTE. LTD. Owner Address: 11444 WEST OLYMPIC BLVD., 10TH FLOOR LOS ANGELES, CALIFORNIA UNITED STATES 90064 Legal Entity Type: PRIVATE COMPANY LIMITED BY SHARES State or Country Where SINGAPORE Organized: Attorney/Correspondence Information Attorney of Record Docket Number: 106340 Correspondent Correspondent LATUNDA POWELL, TRADEMARK ADMINISTRATOR Name/Address: ROLL LAW GROUP P.C. 11444 W. OLYMPIC BLVD., 10TH FL. LOS ANGELES, CALIFORNIA UNITED STATES 90064 Domestic Representative - Not Found Prosecution History Date Description Proceeding Number Jan. 13, 2021 AUTOMATIC UPDATE OF ASSIGNMENT OF OWNERSHIP Jul. 30, 2018 NOTICE OF SUIT Mar. 23, 2018 NOTICE OF SUIT Apr. 10, 2014 COUNTERCLAIM OPP. NO. 999999 214967 Jan. 06, 2014 NOTICE OF SUIT Apr. 30, 2013 NOTICE OF ACCEPTANCE OF SEC. 8 & 9 - MAILED Apr. 30, 2013 REGISTERED AND RENEWED (FIRST RENEWAL - 10 YRS) 66607 Privacy - Terms https://tsdr.uspto.gov/#caseNumber=2703620&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=documentSearch 2/3 2/5/2021 Status Search SN 2703620 Apr. 30, 2013 REGISTERED - SEC. 8 (10-YR) ACCEPTED/SEC. 9 GRANTED 66607 Apr. 26, 2013 CASE ASSIGNED TO POST REGISTRATION PARALEGAL 66607 Apr. 08, 2013 TEAS SECTION 8 & 9 RECEIVED Apr. 08, 2013 TEAS CHANGE OF CORRESPONDENCE RECEIVED Jun. 02, 2008 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED Jun. 02, 2008 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED May 07, 2008 REGISTERED - SEC. 8 (6-YR) ACCEPTED & SEC. 15 ACK. 70132 Apr. 29, 2008 ASSIGNED TO PARALEGAL 70132 Apr. 10, 2008 TEAS SECTION 8 & 15 RECEIVED Feb. 11, 2008 CASE FILE IN TICRS May 10, 2006 AUTOMATIC UPDATE OF ASSIGNMENT OF OWNERSHIP Apr. 08, 2003 REGISTERED-PRINCIPAL REGISTER Jan. 14, 2003 PUBLISHED FOR OPPOSITION Dec. 25, 2002 NOTICE OF PUBLICATION Nov. 12, 2002 APPROVED FOR PUB - PRINCIPAL REGISTER Oct. 28, 2002 CORRESPONDENCE RECEIVED IN LAW OFFICE Oct. 28, 2002 PAPER RECEIVED Sep. 05, 2002 FINAL REFUSAL MAILED Jun. 10, 2002 ASSIGNED TO EXAMINER 73730 Oct. 02, 2001 CORRESPONDENCE RECEIVED IN LAW OFFICE Oct. 09, 2001 CORRESPONDENCE RECEIVED IN LAW OFFICE Apr. 02, 2001 NON-FINAL ACTION MAILED Mar. 27, 2001 ASSIGNED TO EXAMINER 73726 TM Staff and Location Information TM Staff Information - None File Location Current Location: GENERIC WEB UPDATE Date in Location: Apr. 30, 2013 Assignment Abstract Of Title Information Proceedings Privacy - Terms https://tsdr.uspto.gov/#caseNumber=2703620&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=documentSearch 3/3 EXHIBIT 2 2/5/2021 Status Search SN 3,282,520 For assistance with TSDR, email [email protected] and include your serial number, the document you are looking for, and a screenshot of any error messages you have received. STATUS DOCUMENTS MAINTENANCE Back to Search Print Generated on: This page was generated by TSDR on 2021-02-05 19:00:08 EST Mark: FIJI US Serial Number: 78718517 Application Filing Date: Sep. 22, 2005 US Registration Number: 3282520 Registration Date: Aug. 21, 2007 Register: Principal Mark Type: Trademark TM5 Common Status LIVE/REGISTRATION/Issued and Active Descriptor: The trademark application has been registered with the Offic Status: The registration has been renewed. Status Date: Sep. 22, 2017 Publication Date: Jun. 05, 2007 Mark Information Mark Literal Elements: FIJI Standard Character Claim: No Mark Drawing Type: 5 - AN ILLUSTRATION DRAWING WITH WORD(S) /LETTER(S)/ NUMBER(S) INSTYLIZED FORM Color(s) Claimed: Color is not claimed as a feature of the mark. Acquired Distinctiveness In whole Claim: Related Properties Information Claimed Ownership of US 2703620, 2703802, 2714973 and others Registrations: Goods and Services Note: Privacy - Terms https://tsdr.uspto.gov/#caseNumber=3,282,520&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=statusSearch 1/4 2/5/2021 Status Search SN 3,282,520 The following symbols indicate that the registrant/owner has amended the goods/services: Brackets [..] indicate deleted goods/services; Double parenthesis ((..)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and Asterisks *..* identify additional (new) wording in the goods/services. For: Drinking Water; Natural Artesian Water International Class(es): 032 - Primary Class U.S Class(es): 045, 046, 048 Class Status: ACTIVE Basis: 1(a) First Use: May 17, 1997 Use in Commerce: May 17, 1997 Basis Information (Case Level) Filed Use: Yes Currently Use: Yes Filed ITU: No Currently ITU: No Filed 44D: No Currently 44E: No Filed 44E: No Currently 66A: No Filed 66A: No Currently No Basis: No Filed No Basis: No Current Owner(s) Information Owner Name: FIJI WATER COMPANY PTE. LTD. Owner Address: 11444 WEST OLYMPIC BLVD., 10TH FLOOR LOS ANGELES, CALIFORNIA UNITED STATES 90064 Legal Entity Type: PRIVATE COMPANY LIMITED BY SHARES State or Country Where SINGAPORE Organized: Attorney/Correspondence Information Attorney of Record Attorney Name: Danielle M Criona Docket Number: 107059 Attorney Primary Email [email protected] Attorney Email Authorized: Yes Address: Correspondent Correspondent Danielle M Criona Name/Address: Roll Law Group P.C. 11444 W. OLYMPIC BLVD., 7TH FLOOR LOS ANGELES, CALIFORNIA UNITED STATES 90064 Correspondent e-mail: [email protected] [email protected] Correspondent e-mail Yes Authorized: Domestic Representative - Not Found Prosecution History Privacy - Terms https://tsdr.uspto.gov/#caseNumber=3,282,520&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=statusSearch 2/4 2/5/2021 Status Search SN 3,282,520 Date Description Proceeding Number Jan. 13, 2021 AUTOMATIC UPDATE OF ASSIGNMENT OF OWNERSHIP Jul. 30, 2018 NOTICE OF SUIT Mar. 23, 2018 NOTICE OF SUIT Sep. 22, 2017 NOTICE OF ACCEPTANCE OF SEC. 8 & 9 - E-MAILED Sep. 22, 2017 REGISTERED
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