Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov ESTTA Tracking number: ESTTA971455 Filing date: 05/05/2019 IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD Proceeding 91230917 Party Defendant RLP Ventures, LLC Correspondence RLP VENTURES LLC Address PO BOX 2605 NEW YORK, NY 10108-2605 UNITED STATES
[email protected] no phone number provided Submission Other Motions/Papers Filer's Name Ramona Prioleau Filer's email
[email protected] Signature /Ramona Prioleau/ Date 05/05/2019 Attachments Opposition to Motion and Cross-Motions.pdf(239948 bytes ) Declaration Exhibits.pdf(5761623 bytes ) IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD MATCH GROUP, LLC (successor-in- interest to TINDER, INC.) Opposer, Opposition No. 91230917 v. RLP VENTURES, LLC Applicant. OPPOSITION TO MOTION FOR PROTECTIVE ORDER AND CROSS- MOTIONS TO COMPEL DEPOSITIONS AND EXTEND TESTIMONY PERIOD I. INTRODUCTION Applicant RLP Ventures, LLC (“Applicant”) hereby responds to and opposes the Motion for Protective Order of Match Group, LLC (“Opposer”). Applicant opposes the Motion for Protective Order on the grounds that Opposer: (i) lacks standing to make a motion on behalf of the individuals noticed for deposition; (ii) a motion for a protective order is an improper response to a notice of testimonial deposition under Trademark Trial and Appeal Board Manual of Procedure (“TBMP”) §§ 521 and 526; and (iii) the Opposer has provided misleading information in its motion for protective order. As a general matter, Applicant opposes the Motion for Protective Order also on the grounds that Applicant’s Notices of Deposition (i) are clear; (ii) seek clearly relevant information, that is tied to the specific grounds for opposition asserted by Opposer; and (iii) are not intended to harass the individuals noticed for deposition.