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Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov ESTTA Tracking number: ESTTA1103027 Filing date: 12/19/2020

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD Proceeding 92067079 Party Defendant Puma SE Correspondence CHRISTIAN G STAHL Address QUARLES & BRADY LLP 300 N LASALLE STREET, STE 4000 CHICAGO, IL 60654 UNITED STATES Primary Email: [email protected] Secondary Email(s): [email protected], [email protected], [email protected] 312-715-5000

Submission Defendant's Notice of Reliance Filer's Name Christian G. Stahl Filer's email [email protected], [email protected], [email protected], [email protected] Signature /Christian G. Stahl/ Date 12/19/2020 Attachments 2020-12-19 PUMAs 18th Notice of Reliance.pdf(23956 bytes ) Ex. R-1 - Catwoman_DC Comics.pdf(757225 bytes ) Ex. R-2 - _ Wiki _ Fandom.pdf(908803 bytes ) Ex. R-3 - CT Scan v CAT scan_Diffizi.pdf(4258896 bytes ) Ex. R-4 - Cat Scan.pdf(239363 bytes ) Ex. R-5 -Catastrophe Bond_Investipedia.pdf(5108376 bytes ) Ex. R-6 - Catastrophe Bond_Artemis.pdf(1936843 bytes ) Ex. R-7 - World Cat.pdf(5259545 bytes ) Ex. R-8 - Catboat_Wikipedia.pdf(321349 bytes ) Ex. R-9 - Cat Insurance Plans - ASPCA.pdf(4799776 bytes ) Ex. R-10 - Alleycat.org.pdf(628189 bytes ) IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

In the Matter of Registration No. 4,220,096: Registered October 9, 2012

CATERPILLAR INC.,

Petitioner,

v. Cancellation No. 92067079

PUMA SE,

Registrant.

PUMA SE’S EIGHTEENTH NOTICE OF RELIANCE UPON WEBSITES SHOWING EVIDENCE OF VARIOUS USES OF THE TERM CAT PURSUANT TO 37 C.F.R. § 2.122(e) AND TBMP § 704.08(b)

Pursuant to Rule 2.122(e) of the Trademark Rules of Practice and Section 704.08(b) of the Trademark Trial and Appeal Board Manual of Procedure, Registrant PUMA SE hereby submits, makes of record in connection with this cancellation proceeding, and notifies Petitioner

Caterpillar Inc., of Registrant’s reliance upon the attached printouts of websites showing

evidence of various uses of the term “cat.” These websites are relevant to show how the term

“cat” is used in ordinary parlance as well as the nature and extent of the public’s exposure to and

perception of the term “cat.” These websites are also relevant to the lack of a likelihood of

confusion. True and correct printouts of the following websites are attached hereto as Exhibits

R-1 to R-10. Each printout identifies on its the date on which the document was accessed

and printed, as well as the applicable URL identifying the online source of the document.

QB\66278973.1

Exhibit No. Description R-1 https://www.dccomics.com/characters/catwoman (accessed and printed on December 19, 2020) R-2 https://batman.fandom.com/wiki/Catwoman_(Dozierverse) (accessed and printed on December 19, 2020) R-3 https://diffzi.com/ct-scan-vs-cat-scan/ (accessed and printed on December 19, 2020) R-4 https://www.foundationforpn.org/what-is-peripheral-neuropathy/evaluation- and-tests/computerized-axial-tomography-scan/ (accessed and printed on December 19, 2020) R-5 https://www.investopedia.com/terms/c/catastrophebond.asp#:~:text=CAT%20 bonds%20are%20a%20type,protected%20by%20the%20bond%E2%80%94oc curs. (accessed and printed on December 19, 2020) R-6 https://www.artemis.bm/library/what-is-a-catastrophe-bond/ (accessed and printed on December 19, 2020) R-7 https://worldcat.com/ (accessed and printed on December 19, 2020) R-8 https://en.wikipedia.org/wiki/Catboat#:~:text=A%20catboat%20is%20a%20sa ilboat,hull%20length%20at%20the%20waterline. (accessed and printed on December 19, 2020) R-9 https://www.aspcapetinsurance.com/cat-insurance/ (accessed and printed on December 19, 2020) R-10 https://www.alleycat.org/ (accessed and printed on December 19, 2020)

Dated: December 19, 2020

Respectfully submitted,

/Christian G. Stahl/ Christian G. Stahl QUARLES & BRADY LLP 300 N. LaSalle Street, Suite 4000 Chicago, Illinois 60654 Tel: (312) 715-5000 Fax: (312) 632-1916 E-mail: [email protected]

Johanna M. Wilbert QUARLES & BRADY LLP 411 East Wisconsin Ave., Suite 2040 Milwaukee, Wisconsin 53202 Tel: (414) 277-5000 Fax: (414) 271-3552 E-mail: [email protected]

2 QB\66278973.1

Otto Hinks QUARLES & BRADY LLP Renaissance One, Two North Central Avenue Phoenix, AZ 85004 Tel: (602) 229-5251 Fax: (602) 229-5690 E-mail: [email protected]

Attorneys for Registrant, PUMA SE

3 QB\66278973.1

CERTIFICATE OF SERVICE

I hereby certify that a true and complete copy of the foregoing PUMA SE’S EIGHTEENTH

NOTICE OF RELIANCE UPON WEBSITES SHOWING EVIDENCE OF VARIOUS

USES OF THE TERM CAT PURSUANT TO 37 C.F.R. § 2.122(e) AND TBMP § 704.08(b) has been served on Caterpillar Inc. by forwarding said copy on December 19, 2020, via email to:

Naresh Kilaru Christopher P. Foley Laura K. Johnson FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue, N.W. Washington, D.C.DC 20001 Telephone: (202) 408-4000

[email protected] [email protected] [email protected] [email protected] [email protected]

Attorneys for Petitioner Caterpillar Inc.

By: /Christian G. Stahl/ Christian G. Stahl QUARLES & BRADY LLP 300 N. LaSalle Street, Suite 4000 Chicago, Illinois 60654 Tel: (312) 715-5000 Fax: (312) 632-1916 E-mail: [email protected]

Attorney for Registrant PUMA SE

4 QB\66278973.1

EXHIBIT R-1 screenshot-www.dccomics.com-2020.12.19-16_08_11 https://www.dccomics.com/characters/catwoman 19.12.2020

EXHIBIT R-2 12/19/2020 Catwoman | Batman Wiki | Fandom

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LEGAL "Purr-fect." Catwoman ―Catwoman Season 1 and 2 Movie Season 3 Catwoman was an arch-nemesis of Batman.

She was a seductive villainess who often stole the heart of the Caped Crusader and always wanted him for her own partner, but her criminal persona always allowed him to see through her seductions and never stopped him from carrying out his criminal apprehending duty. General Information

Real name: Unrevealed

Aliases: The Princess of Plunder The Queen of Crime Kitanya Irenia Tatanya Kerenska Alisoff (aka Ms. Kitka, disguise) Miss Matthews (disguise) Miss Klutz, dance teacher. (Catwoman arranged dance lessons for so she could learn more about the layout Recent Wiki Activity of ) (Burtonverse) Portrayed by: (Seasons 1 and 2) Degrassigirl07 Lee Meriwether (Batman: The 16 hours ago Movie) Eckhardt Eartha Kitt (Season 3) Degrassigirl07 16 hours ago Appearances: Batman 1960s series Batman: The Movie Stranger 18 hours ago Batman: Return of the Caped Crusaders Batman: The Animated Series Batman vs. Two-Face 18 hours ago (film) Contents Phantom Stranger 18 hours ago 1 Biography 1.1 United Underworld movement 2 Weapons and Equipment 3 Known Associates 4 Known Hideouts 5 Appearances 5.1 Batman 5.1.1 Season 1 5.1.2 Season 2 5.1.3 Season 3 5.2 Films 6 Behind the scenes 7 Trivia 8 Gallery 8.1 Still photos 8.2 Screencaps 9 External links https://batman.fandom.com/wiki/Catwoman_(Dozierverse) 1/13 12/19/2020 Catwoman | Batman Wiki | Fandom

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The Joker Biography Catwoman is one of City's most prominent villains, ranking near the with Joker, and for the most criminal activity. Dressed in a sleek, black bodysuit with cat ears and a cat medallion around her neck, Catwoman has the appearance and grace of the animal from which she gets her name. Indeed, at times she has been known to meow, and when Batman is close by her voice takes on a distinctive purr.

It is easy to see that Catwoman is attracted to Batman in a strong physical way. Whenever they come face to face she tries to coax him to admit his feelings for her, at times attempting to entice him into a more personal encounter. Even attracted to Batman as she is, she cannot abide his crime-fighting behaviour. The fact they are on opposite sides of the law will undoubtedly keep them apart.

Her capers are usually related to cats in some way. Whether it be a form of ancient treasure or jewellery in the shape of a cat, cat-gut strings from antique violins, or the legendary treasure of Captain Manx, Catwoman will hatch a scheme which will usually involve trying to rid of its caped protectors. Though she is attracted to Batman, she has the sense to realize he is a hindrance in her plans. Batman believes that Catwoman has the nine lives of a cat because during her attempts to try and escape from capture she has fallen into a bottomless pit or off the roof of a waterfront warehouse and survived.

She has a pet cat named Hecate who she sometimes takes on her crimes and occasionally even helps her. United Underworld movement In the 1966 Batman movie, she was pretending to be a Russian woman named Ms. Kitka, and teamed up with the other three main criminals: the Joker, the Penguin, and the Riddler, devising a plan to take over the world. Batman Catwoman once threatened the entire world fell in love with Ms. with three other prominent criminals. Kitka, and was unaware until the end that she was really the Catwoman (believing her to be kidnapped, and with the Catwoman "threatening to kill her" at one point). During the final battle at the end, on top of the submarine, the Catwoman was ironically the only one who wasn't knocked into the water, sneaking up on Batman and and knocking them both off, first Robin then Batman. Sneaking back into the submarine she tripped and fell down. Her mask fell off, and Batman and Robin realized that she was Ms. Kitka all along. Robin puts her in batcuffs and she is captured along with the other criminals.

She has been known to team up with other master criminals. Her partners in crime include Freddy the Fence, Ma Parker and the , though she had planned to double-cross him when the caper was finished. Even though the Joker and the Penguin had feelings for her, she refused them both because she hated Joker's green hair and disliked Penguin's size.

She has been known at times to keep pussy willows in her hideout. Throughout the day she will take time out for a cat nap and she has a fondness for milk. She also is allergic to dogwood.

She was also one of six arch-criminals freed from prison by Dr. Cassandra Spellcraft to form her new invisible gang, but this brief cameo appearance was by a stand-in. Weapons and Equipment - a special weapon that looks like an ordinary cat o'nine tails which squirts deadly gas from its handle.

https://batman.fandom.com/wiki/Catwoman_(Dozierverse) 2/13 12/19/2020 Catwoman | Batman Wiki | Fandom

FandomShopADVERTISEMENT Fandom IG GalaxyQuest Medallion - A piece of jewellery that she always wears around her neck. It has a hidden communicator, a watch and an alarm as a reminder of when to take her cat naps. Catamizer - a specialized gun which is filled with catasonic acid. Though the catamizer has never been used, it will 'catalyze' the victim. Catwoman's Amazing Maze - located in the catacombs of her subterranean suite 6, this maze is a giant replication of the maze used to carry out experiments on rats and mice. According to Catwoman, once inside it could take the rest of your life to get out, that is unless you find the center of the maze which means you will never get out. She had placed her traitorous henchwoman Katalina (AKA Police Woman Mooney) and Robin in the maze. Both of them became trapped in the center of the maze, trapped that is until Batman entered the maze and led them to safety. See in the dark glasses - she liked using them because 'cats can always see in the dark'. Sonic beam blast gun - fires a concentrated sound wave that can destroy whatever it hits Voice-stealing box - when opened and pointed at a person, that person would lose the power of speech as it was transferred into the box. Recent conversations that person had could then be replayed by opening the box and listening. Catwoman later revealed under questioning that the person's voice could be returned by drinking a mixture of sweet basil, garlic salt, and goat's milk. Sneeze bombs - explode in a puff of red smoke, leave everyone in the room sneezing. Cataphrenic - A chemical created by Catwoman. It can be kept under fingernails so that when a person is scratched, they are infected with the drug. It reverses all normal moral and ethical standards, turning them into the complete opposite of the person they used to be. As side effects, it causes amnesia and fainting spells. Catwoman used this to brainwash Robin into serving her. She even did this on Batman only for the Bat-Antidote Pill that Batman passed off as an aspirin to negate it's effects. Catillac - Catwoman's car. Remote Control Cat-radio Old Kit Bag - A bag used to carry things. Eau de Chat (Water of Cat) - A poisonous perfume. Hair-raising bomb - Destroys the hairdos of any women in the area. Kitty Car - A green vehicle made to look like a cat. Cat Lily perfume - Not known to have any criminal uses, but probably smells nice. Cat's whiskers - Thin ropes used to tie someone up, they contract when in contact with body heat. Known Associates Just as Batman and Robin do not go at crime-fighting alone, Catwoman needs fellow partners in crime to assist her with her malicious schemes. Her pet cat was named Hecate. Felix and Leo (portrayed by Ralph Manza and Jock Mahoney) - Catwoman's henchmen. Felix was in charge of brushing Catwoman's pussy willows. Henchman (portrayed by Alex Sharp) - Catwoman's henchmen. Joker - Member of the United Underworld and later teamed up with Catwoman and helped her find a cache of gunpowder hidden for a hundred years. Penguin - Member of the United Underworld Riddler - Member of the United Underworld Bluebeard (portrayed by Gil Perkins) - Member of the United Underworld Morgan (portrayed by Dick Crockett)- Member of the United Underworld Quetch (portrayed by George Sawaya) - Member of the United Underworld Jack O'Shea (portrayed by Jack Kelly) - This Gotham City Times writer pens the most widely read gossip column in the country. His office is the third phone booth in Glob's drugstore. His favorite lunch is corn beef on white, heavy on the mayo, and two glasses of buttermilk from the drugstore's deli. Despite his national fame, O'Shea found it necessary to enlist with Catwoman in what she called "the https://batman.fandom.com/wiki/Catwoman_(Dozierverse) 3/13 12/19/2020 Catwoman | Batman Wiki | Fandom

FandomShopADVERTISEMENT Fandom IG GalaxyQuest greatet caper in crimedum's history"—the carefully orchestrated theft of two antique Strativarius violins. The Gotham City Times will be without O'Shea's talents for several years as he does time in Gotham State Penitentiary. John, Thomas and Charles (portrayed by Buck Kartalian, Charles Horvath, and George Barrows) - The creme de la creme of Gotham City's cat-burglars, these three men successfully made it through Catwoman's selection process, becoming players in "the greatest caper in crimedum's history". After a small caper, John is left behind, revealing information which leads the Dynamic Duo to Catwoman's lair and a trap. All three are currently serving time. Cowboys (portrayed by Christopher Riordan) - Catwoman's henchmen Ma Parker - She was released from imprisonment by her and became a member of Ma's new prison gang after the gangster took over Gotham State Penetentiary. Pretty Boy Parker (portrayed by Robert Belheller) - Former prisoner of the penitentiary who became a member of Ma's new gang. Machine Gun Parker (portrayed by Peter Brooks) - Former prisoner of the penitentiary who became a member of Ma's new gang. Mad Dog Parker (portrayed by Michael Vanderver) - Former prisoner of the penitentiary who became a member of Ma's new gang. Parker (portrayed by Tisha Sterling) - Former prisoner of the penitentiary who became a member of Ma's new gang. Eenie (portrayed by Sharyn Winters) - Female helper and member of the band "Catwoman and the Kittens." She was constantly questioning Catwoman's decisions and complaining about the next caper. Meanie, Miney and Moe (portrayed by T.J. Castronova, Chuck Henderson, and Ric Roman) - Catwoman's henchmen and members of "Catwoman and the Kittens." Benton Bellgoody (portrayed by Joe Flynn) - Benton works at Duncan Dance Studios. He apparently allowed Catwoman and her gang to hide out in the basement, and let Catwoman pretend to be a dance teacher. When Batman and Robin visited, he pretended not to remember their names, but Batman saw right through him. Kitty, Cattie, and Catarina (portrayed by Valerie Kairys, Pat Bender, and Jeanie Moore) - During her partnership with Sandman, Catwoman had a pair of female criminal companions. It appears as if these two women functioned more as servants than criminal helpers. This is suggested through the leashes Catwoman made them wear. She refers to them as her "kittens". - Worked together on a scheme to get rid of Batman once and for all, but eventually he double crossed her. Nap (portrayed by Tony Ballen) - Sandman's and Catwoman's henchman. Snooze (portrayed by Richard Peel) - Sandman's and Catwoman's henchman. Pussycat (portrayed by Lesley Gore) - She always wanted to be a rock and roll singer, but wasn't doing too well when Catwoman picked her up at the Milkshake-a-go-go on Sunset Strip. Catwoman convinced her that at 20 years old, she was over the hill. Spade, Marlow, and Templar (portrayed by Jock Gaynor, Tony Epper, and George Sawaya) - Catwoman's simple henchmen who assisted Catwoman in brainwashing Robin. Pat Pending (portrayed by J. Pat O'Malley) - Catwoman's henchmen. Rudy, the Valet (portrayed by Steve Franken) - Catwoman's henchmen. Little Al (portrayed by Allen Jenkins) - Catwoman's henchmen. Freddy the Fence - The owner of French Freddy's Fencing Academy. Catwoman and Minerva Henchman. Also a well-known fence. He sometimes uses his fencing mask to strain spaghetti. https://batman.fandom.com/wiki/Catwoman_(Dozierverse) 4/13 12/19/2020 Catwoman | Batman Wiki | Fandom

FandomShopADVERTISEMENT Fandom IG GalaxyQuest Cornell, Penn, and Brown (portrayed by Paul Mantee, Sheldon Allman, and Paul Picerni) - Catwoman's simple henchmen. Cornell is a master mimic, even able to impersonate Batman's voice perfectly. Manx and Angora (portrayed by James Griffith and Dirk Evans) - Catwoman's henchmen and amateur fasion critics. Giggler and Laugher (portrayed by Sandy Kevin and Bobby Hall) - Catwoman's henchmen, both were looking forward very much to working with Joker. Lucky Pierre (portrayed by Pierre Salinger) - Catwoman's attorney who presented her and Joker's case. He wore a lucky wishbone in his hat, carried a lucky rabbit's foot round a chain on his waistcoat. and claimed he never lost a case. But after it was revealed that he and Catwoman rigged the jury, he lost his first case, thus he destroyed his lucky wishbone, threw away his lucky rabbit's foot and stormed out. Marvin the Moose and Dave the Dummy (portrayed by Gil Perkins and Sammy Shack) -They worked with Catwoman in the past. Lucky Pierre disguised them and put them on the jury in Batman's case against her. Jurors (portrayed by Al Bain, Donald Chaffin, Neil Collins, Sig Frohlich, Joseph Glick, and Johnny Kern) - Joker and Catwoman's henchmen Dr. Cassandra Spellcraft - A diabolical alchemist who has invented camouflage pills which turn people invisible. She freed Gotham's most dangerous criminals in Gotham including Catwoman to form her new invisible gang. She was told by Dr. Cassandra to rob all the fish market areas. Cabala - Dr. Cassandra's fiendish husband who assists in her plot. - Former adversary of Batman released from prison to form Dr. Cassandra's new invisible gang. He was told to rob all the museums. Egghead - Former adversary of Batman released from prison to form Dr. Cassandra's new invisible gang. He was told to rob the poultry farms. Known Hideouts The Pink Sandbox - A new restaurant and dance club on the west side of Gotham. From this hip club came the Catusi, the latest dance craze.

Subterranean Suite 6 of the Catacombs Condominium - It is adjoining Duncan's Dance Studio.

The Catlair West - It is across the river in New Guernsey. Basement of the Eta Beta Latka - A sorority house. Gato & Chat Fur Warehouse - 2809 West 20th Street 32 Pussyfoot Road, in the heart of Gotham City's garment center The Hotel Sleazy, across the street from Police Headquarters The Grimalkin Novelty Company Appearances Batman

Season 1 The Purr-Fect Crime/Better Luck Next Time

Season 2 /The Cat and the Fiddle Ma Parker (Cameo) The Cat's Meow/The Bat's Kow Tow The Sandman Cometh/The Catwoman Goeth (A Stitch in Time) That Darn Catwoman/Scat! Darn Catwoman Catwoman Goes to College/Batman Displays His Knowledge

Season 3 Catwoman's Dressed to Kill The Funny Feline Felonies/The Joke's on Catwoman The Entrancing Dr. Cassandra (Cameo, portrayed by body double) Films Batman: The Movie https://batman.fandom.com/wiki/Catwoman_(Dozierverse) 5/13 12/19/2020 Catwoman | Batman Wiki | Fandom

FandomShopADVERTISEMENT Fandom IG GalaxyQuest Batman: Return of the Caped Crusaders Batman vs. Two-Face Behind the scenes Catwoman was first portrayed in the 1960s series by Julie Newmar in the first two seasons. Lee Meriwether and Eartha Kitt replaced when she was unavailable for the movie and season three. Marilyn Watson was Newmar's stunt double. Her birth name Selina Kyle is never mentioned in the series. Nor are her motives or origins. Trivia Unlike Newmar and Kitt, Meriwether didn't wear the golden cat medallion. As a cat oriented person, Catwoman loves pussy willows and coincidentally is allergic to Dogwood. Gallery Still photos

Catwoman in Season 1 (Unmasked)

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ADD A PHOTO TO THIS GALLERY Screencaps

Catwoman with her whip

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Catwoman after being freed by Ma Parker

Catwoman with her associate Pussycat

Catwoman as Miss Klutz

Catwoman in Season 2

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'Miss Kitka' disguise

Catwoman with Joker, Penguin and Riddler in Batman: Return of the Caped Crusaders

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Retrieved from "https://batman.fandom.com/wiki/Catwoman_(Dozierverse)? oldid=227213"

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EXHIBIT R-4 screenshot-www.foundationforpn.org-2020.12.19-15_52_20 https://www.foundationforpn.org/what-is-peripheral-neuropathy/evaluation-and-tests/computerized-axial-tomography-scan/ 19.12.2020 EXHIBIT R-5 screenshot-www.investopedia.com-2020.12.19-15_50_16 https://www.investopedia.com/terms/c/catastrophebond.asp#:~:text=CA T%20bonds%20are%20a%20type,protected%20by%20the%20bond%E2%80%94occurs. 19.12.2020

EXHIBIT R-6 screenshot-www.artemis.bm-2020.12.19-15_46_11 https://www.artemis.bm/library/what-is-a-catastrophe-bond/ 19.12.2020

EXHIBIT R-7 screenshot-worldcat.com-2020.12.19-15_55_32 https://worldcat.com/ 19.12.2020

EXHIBIT R-8 screenshot-en.wikipedia.org-2020.12.19-15_37_38 https://en.wikipedia.org/wiki/Catboat#:~:text=A%20catboat%20is%20a%20sailboat,hull%20length%20at%20the%20waterline. 19.12.2020 EXHIBIT R-9 screenshot-www.aspcapetinsurance.com-2020.12.19-15_34_40 https://en.wikipedia.org/wiki/Catboat#:~:text=A%20catboat%20is%20a%20sailboat,hull%20length%20at%20the%20waterline. 19.12.2020

EXHIBIT R-10 screenshot-www.alleycat.org-2020.12.19-16_10_24 https://www.alleycat.org/ 19.12.2020