Notice of Opposition Opposers Information Applicant

Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov ESTTA Tracking number: ESTTA1143580 Filing date: 06/29/2021

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD Notice of Opposition

Notice is hereby given that the following parties oppose registration of the indicated application. Opposers Information

Name Bridgestone Corporation Entity Corporation Citizenship Japan Address 1-1, KYOBASHI 3-CHOME, CHUO-KU TOKYO, 0 JAPAN

Name Bridgestone Americas Tire Operations, LLC Entity Limited Liability Company Citizenship Delaware Address 200 4TH AVENUE S NASHVILLE, TN 37201 UNITED STATES

Attorney informa- DOUGLAS A. RETTEW tion FINNEGAN HENDERSON FARABOW GARRETT & DUNNER, LLP 901 NEW YORK AVENUE, NW WASHINGTON, DC 20001 UNITED STATES Primary Email: [email protected] Secondary Email(s): [email protected], [email protected], [email protected], [email protected] 202-408-4000

Docket Number 09748.1034 Applicant Information

Application No. 90113347 Publication date 06/01/2021 Opposition Filing 06/29/2021 Opposition Peri- 07/01/2021 Date od Ends Applicant Shenzhen ThaiStone Precision Hardware Co. ,ltd. C,2/F,BLDG A1,ZHONGPENGCHENG IP,4TH IZ HESHUIKOU COMMUNITY,MATIAN ST.,GUANGMING SHENZHEN, GUANGDONG, 518107 CHINA Goods/Services Affected by Opposition

Class 012. First Use: 2020/08/04 First Use In Commerce: 2020/08/04 All goods and services in the class are opposed, namely: Dinghies; Air pumps for automobiles; Air pumps for bicycles; Air pumps for motorcycles; Air pumps for two-wheeled motorvehicles or bicycles; Bicycle pumps; Casings for pneumatic tires; Tire inflators; Tire inflators; Pumps for inflating vehicle tyres Grounds for Opposition

Priority and likelihood of confusion Trademark Act Section 2(d) Dilution by blurring Trademark Act Sections 2 and 43(c) Marks Cited by Opposer as Basis for Opposition

U.S. Registration 140804 Application Date 04/05/1920 No. Registration Date 03/29/1921 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class U035 (International Class 007, 012, 017). First use: First Use: 1900/00/00 First Use In Commerce: 1900/00/00 Rubber Tires, Pneumatic [ and Solid; Inner Tubes, Rubber-Impregnated Tire Building and Rebuilding Fabrics; Tire Accessories-Namely, ] [ Hook-On Boots, Lace-On Boots, ] [ Flaps, and Tire-Repair Air-Bags, Fabric and Rubber Repair- Patches, Tube-Patches in Sheet and Patch Form, and Reliners and Tire-Repair Gum Materials in Sheet Form-Namely, Tread-Gums, Cushion-Gums, Tube- Gums, Camel-Back-Tread Gums,and Combination-Gums ]

U.S. Registration 1178631 Application Date 02/15/1980 No. Registration Date 11/17/1981 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class 042. First use: First Use: 1928/12/24 First Use In Commerce: 1928/00/00 Retail Tire and Automotive Store Services

U.S. Registration 1387468 Application Date 08/29/1985 No. Registration Date 03/25/1986 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class 012. First use: First Use: 1971/10/31 First Use In Commerce: 1971/10/31 VEHICLE TIRES AND INNER TUBES THEREFOR

U.S. Registration 2464005 Application Date 07/07/2000 No. Registration Date 06/26/2001 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class 012. First use: First Use: 1896/01/31 First Use In Commerce: 1900/12/31 VEHICLE TIRES AND INNER TUBES THEREFOR

U.S. Registration 3173847 Application Date 12/19/2005 No. Registration Date 11/21/2006 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class 037. First use: First Use: 1929/00/00 First Use In Commerce: 1929/00/00 automotive repair and maintenance services

U.S. Registration 3173840 Application Date 12/16/2005 No. Registration Date 11/21/2006 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class 035. First use: First Use: 1929/00/00 First Use In Commerce: 1929/00/00 retail tire store services

U.S. Registration 5041172 Application Date 03/09/2016 No. Registration Date 09/13/2016 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class 035. First use: First Use: 1929/00/00 First Use In Commerce: 1929/00/00 Retail tire, automobile parts and automobile accessories store services Class 037. First use: First Use: 1929/00/00 First Use In Commerce: 1929/00/00 automotive repair and maintenance services

U.S. Registration 3688909 Application Date 03/10/2009 No. Registration Date 09/29/2009 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark Description of NONE Mark Goods/Services Class 012. First use: First Use: 1936/12/31 First Use In Commerce: 1936/12/31 Vehicle suspension components, namely, air springs

U.S. Registration 3248867 Application Date 10/27/2006 No. Registration Date 06/05/2007 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class 012. First use: First Use: 1935/10/15 First Use In Commerce: 1935/10/15 suspension systems and components for vehicles consisting of air springs and control devices; pneumatic suspension springs and shock absorber units for vehicles and structural and replacement parts therefor; air helper springs for vehicles

U.S. Registration 5448592 Application Date 10/03/2017 No. Registration Date 04/17/2018 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class 005. First use: First Use: 2017/01/00 First Use In Commerce: 2017/01/00 first aid kits Class 007. First use: First Use: 2017/01/00 First Use In Commerce: 2017/01/00 air compressors; hand-held vacuum cleaners Class 009. First use: First Use: 2017/01/00 First Use In Commerce: 2017/01/00 safety traffic cones; stands adapted for mobile phones; jumper cables Class 012. First use: First Use: 2017/01/00 First Use In Commerce: 2017/01/00 fitted covers for vehicles; fitted car seat covers; steering wheel covers; trunk bed storage organizers; tire repair kits; aftermarket automobile accessories, namely, car interior organizer bags, nets and compartments specifically adapted for fitting in vehicles Class 021. First use: First Use: 2017/01/00 First Use In Commerce: 2017/01/00 dusters; wiping cloths, namely, chamois; microfiber cloths for cleaning Class 027. First use: First Use: 2017/01/00 First Use In Commerce: 2017/01/00 floor mats for vehicles

U.S. Registration 3299861 Application Date 03/15/2006 No. Registration Date 09/25/2007 Foreign Priority NONE Date Word Mark FIRESTONE COMPLETE AUTO CARE Design Mark

Description of NONE Mark Goods/Services Class 035. First use: First Use: 2005/06/30 First Use In Commerce: 2005/10/31 Retail tire and automobile parts and accessories store Class 037. First use: First Use: 2005/06/30 First Use In Commerce: 2005/10/31 Automotive services, namely, automobilerepair and maintenance

U.S. Registration 3455550 Application Date 04/10/2006 No. Registration Date 06/24/2008 Foreign Priority NONE Date Word Mark FIRESTONE COMPLETE AUTO CARE SINCE 1926 Design Mark

Description of NONE Mark Goods/Services Class 035. First use: First Use: 2005/06/30 First Use In Commerce: 2005/10/31 Retail tire and automotive parts and accessories store Class 037. First use: First Use: 2005/06/30 First Use In Commerce: 2005/10/31 Automotive services, namely, automobilerepair and maintenance

U.S. Registration 3171276 Application Date 12/16/2005 No. Registration Date 11/14/2006 Foreign Priority NONE Date Word Mark FIRESTONE Design Mark

Description of NONE Mark Goods/Services Class 036. First use: First Use: 2005/01/31 First Use In Commerce: 2005/01/31 credit card services

U.S. Registration 2886688 Application Date 10/03/2003 No. Registration Date 09/21/2004 Foreign Priority NONE Date Word Mark BRIDGESTONE Design Mark Description of NONE Mark Goods/Services Class 012. First use: First Use: 1928/00/00 First Use In Commerce: 1956/12/31 TIRES [ ; WHEELS FOR VEHICLES; INNER TUBES, RIMS AND COVERS FOR VEHICLE WHEELS;INNER TUBES FOR VEHICLE TIRES; PARTS AND FITTINGS FOR ALL THE AFORESAID GOODS ]

U.S. Registration 2607465 Application Date 10/12/2001 No. Registration Date 08/13/2002 Foreign Priority NONE Date Word Mark BRIDGESTONE Design Mark

Description of NONE Mark Goods/Services Class 012. First use: First Use: 1983/10/05 First Use In Commerce: 1983/11/10 Tires and inner tubes therefor

U.S. Registration 952683 Application Date 05/28/1971 No. Registration Date 02/06/1973 Foreign Priority NONE Date Word Mark BRIDGESTONE V-STEEL Design Mark Description of NONE Mark Goods/Services Class U035 (International Class 007, 012, 017). First use: First Use: 1970/04/24 First Use In Commerce: 1970/12/30 [ ALL KINDS OF ] RUBBER TIRES [ AND TUBES ] FOR [ AUTOMOBILES, AUTOBICYCLES, ORAND OTHER ] VEHICLES

U.S. Registration 5968382 Application Date 08/01/2018 No. Registration Date 01/21/2020 Foreign Priority NONE Date Word Mark BRIDGESTONE MASTERCORE Design Mark

Description of NONE Mark Goods/Services Class 012. First use: First Use: 2019/07/30 First Use In Commerce: 2019/07/30 Tires

U.S. Registration 4378086 Application Date 07/27/2011 No. Registration Date 08/06/2013 Foreign Priority 02/23/2011 Date Word Mark BRIDGESTONE Design Mark

Description of The mark consists of the stylized word "BRIDGESTONE" with an upward point- Mark ing chevron inside the letter "B" in "BRIDGESTONE". Goods/Services Class 001. First use: First Use: 0 First Use In Commerce: 0 [ Rubber cement for use in retreading preformed tires; chemical preparations, namely, degreasing and cleaning solvents;self-vulcanizing binder compositions and vulcanizing accelerator compositions, all used in the repair of tires ] Class 006. First use: First Use: 0 First Use In Commerce: 0 [ Metal junctions for pipes; metal flanges; water-pipe valves of metal; metal pipes; anti-seismic construction materials of metal, namely, bearings, rubber coated metal damping plates for bridges, and reinforcement materials for pre- ventingcollapse of bridges; construction materials of metal, namely, adiabatic dampersfor multifamily housing; reinforcing materials of metal for building; metal hardware, namely, metal wire, cording, beading, springs and fiber for use in tires for aircraft, vehicles and motorcycles; reinforcing materials of metal for pipes; nuts of metal; metal industrial water storage tanks; water tanks of metal for household purposes; steel frames for buildings; transportable steel buildings; stainless-steel water tanks for householdpurposes; containers of metal for chemicals, compressed gasses and liquids; rubber covered metal chains for preventing bridge collapse; man-made metal structures for use as garden ponds ] Class 007. First use: First Use: 0 First Use In Commerce: 0 [ Construction machines, namely, cranes, and hoses being parts of construction machines; ] rubber tracks for use with crawlers on agricultural machinery; rubber tracks for use with crawlers on miningmachinery; rubber tracks for use with crawlers on construction, cargo handling machinery; rubber pads to be attached toshoe plates of metal crawlers; rubber tracks for use with crawlers on snow removers [, and parts and fittings for the aforesaid goods; ] belts for conveyors; [transmission belts not for land vehicles; belt conveyors; ] [ brakes for machines; ] hydraulic quick release couplings for high-pressure hoses used in machines; [ hydraulic connectors (pipes) being parts of machines ] [ ; tire repairing machinery; pressure chambers as parts of tire repairing machinery; power operated tire buffers as parts of tire repairing machinery; tire tread rollers and stitchers, as parts of tire repairing machinery; tire tread cutters and bonding agent applicators used in recapping tires as parts of tire repairing machinery; pneumatic shock absorbers for machines; rubbersprings for use as shock absorbers for machine suspension systems ] Class 009. First use: First Use: 0 First Use In Commerce: 0 [ Rubber covered electrical wires; electronic buzzers; solar batteries; facsimile machines; electronic display interfaces utilizing electronic paper technology; computers; transfer rollers, toner supply rollers, development rollers, all for use in laser printers, computer printers, inkjet printers, facsimile machines and elec- trostatic copying machines; alarm devices for vehicle tire pressure in the nature of electronic tire pressure monitors; automatic indicators of low pressure in vehicle tires; rubber testing machines; cameras; magnetic cores; gasoline gauges; metered gasoline pumps for service stations; electronic circuits; CD- ROMs prerecorded with computer game software for use in handheld games with liquid crystal displays; downloadable music files; downloadable image files containing artwork, games and music videos, electronic publications, namely, newsletters in the field of automotive tires and motor sports; electric batteries; electric batteries for vehicles; sunglasses ] Class 012. First use: First Use: 0 First Use In Commerce: 0 [ Automobiles and structural parts therefor; ] tires for passenger cars, trucks, buses, racing cars and automobiles; retreaded tires for [ passenger cars, ] trucks, buses [ and racing cars ]; retreaded tires; [ retreaded tires for automobiles; ] [ inner tubes for passenger cars,trucks, buses, racing cars and automobiles; ] [ wheels and rims for passenger cars, trucks, buses, racing cars and automobiles; tread rubber for retreading tires for passenger cars, trucks, buses, racing cars and automobiles; two-wheeled motor vehicles and structural parts therefor; ] tires for two-wheeled motor vehicles; inner tubes for two-wheeled motor vehicles; [ wheels and rims for two-wheeled motor vehicles; bicycles and structural parts therefor; tires for bicycles; inner tubes for bicycles; wheels and rimsfor bicycles; aircraft and structural parts therefor; ] tires [ and inner tubesfor aircraft; ] [ adhesive rubber patches for repairing tubes or tires; tread rubber for retreading tires for two-wheeled motor vehicles or bicycles; tread rubber for retreading tires for aircraft; tread used to retread tires; preformed tire tread for retreading tires; adhesive rubber patches for repairing vehicle tire tread; ] [ shock absorbers for land vehicles; ] [ air springs for land vehicles; ] [ shaft couplings and connectors for land vehicles; ] [ fenders for vessels, namely, boat side protectors; seat cushions for vehicles; ] [ air springs for railway cars; vehicle bump- ers; ] [ suspension shock absorbers for vehicles; suspension springs for vehicles; ] [ four-wheeled go-carts; tricycles for infants; ]tires for off the road vehicles; tires for scrapers; tires for motor graders, tires for shovel loaders; tires for tire rollers; tires for wheeled cranes; tiresfor cranes; tires for snowplows; tires for pavers; tires for mining machinery Class 017. First use: First Use: 0 First Use In Commerce: 0 [ Valves of rubber or vulcanized fiber;] flexible tubes of rubber and plastic;[ sealants for use in building, construction and insulation, for use in building and construction, namely, sealants forbuildings; floating anti-pollution barriers; packing containers of rubber; ] hydraulic hoses of plastic or rubber; [ plastic substances, namely, semi-processedplastics; plastic sheets for use as interlayers for laminated glass; plastic films for commercial and industrial use, not for wrapping; ethylene vinyl acetate films used in the manufacture of solar batteries; ethylene vinyl acetate films used in the manufacture of solar cells; ]urethane foam insulation for use in land vehicles; [ thermoplastic elastomers in pellet form used as materials for buffers of hard disc drives; flexible pipes and tubes of plastic; ] flexible rubber tubes; [ laminated plastic films for usein electronic displays including plasmadisplay panels and liquid crystal displays; adhesive-coated plastic sheets for solar cells; crude rubber; ] [ materialsof rubber for seismic isolation for usein building and construction; ] [ synthetic rubber; natural rubber; rubber compounds, namely, two component silicone rubber compounds used in artistic or industrial special effects applications; ] rubber for retreading [ and repairing ] tires [ and repairing tubes; ] rubber material for recapping tires [; pipe gaskets; non-metal seals for use in cameras, electronic devices and mobile phones; waterproofing membranes for foundations of buildings; insulating waterproofing membranes ] Class 018. First use: First Use: 0 First Use In Commerce: 0 [ Canvas ] [, leather and ] reusable shopping bags; bags for sports; rucksacks;[ travelling bags; handbags; wheeled shopping bags; net bags for shopping, namely, leather net shopping bags, mesh shopping bags and reusable net shopping bags; purses; ] school bags; [ bags, envelopes and pouches of leather for packaging;] umbrellas [ ; parasols; business cardand name card cases; leather key cases;unfitted vanity cases ] Class 019. First use: First Use: 0 First Use In Commerce: 0 [ Rigid pipes, not of metal; building or construction materials, namely, rubber- roofing; antiseismic construction materials, not of metal, namely, bearings, damping rubber materials for bridges, materials for preventing collapse of bridges; rubber building materials for seismic isolation, namely, bearings, damping rubber materials for bridges, materials forpreventing collapse of bridges; non-metallic building materials, namely, bearings, damping rubber materials for bridges, materials for preventing collapse of bridges; roofing membranes; roofing membranes having waterproof properties; non-metal preformed structures for use as garden ponds; non-metal bridge constructionmaterials, covered with rubber, namely,bearings ] Class 020. First use: First Use: 0 First Use In Commerce: 0 [ Non-metal valves for containers; tanks, not of metal or masonry, for fluid storage; liquid storage tanks not of metalor masonry; gas storage tanks not of metal or masonry; chests not of metal; desks; chairs; mirrors; bathroom vanities; book- cases; cushions; pillows; mattresses; wood cases; bamboo and plastic containers for packaging; non-electric fans forpersonal use; water tanks for householdpurposes, not of metal or masonry; sleeping bags for camping; hairdressers' chairs; non-metal chains covered with rubber ] Class 024. First use: First Use: 0 First Use In Commerce: 0 towels of textile [; handkerchiefs; cloth labels ] Class 025. First use: First Use: 0 First Use In Commerce: 0 [ Wind jackets; wristbands; golf shoes;golf spikes; cyclists' suits of jerseysfor racing; cyclists' pants for racing;cyclists' overalls; golf trousers; ] golf caps; golf shirts; [ golf pants; golfskirts; ] jackets; [ jogging pants; sweat pants; trousers; overcoats; raincoats; sweaters; ] sport shirts; [ camisoles;undershirts; under- pants; ] vests; open-necked shirts; polo shirts; [ collar protectors; socks; scarfs; gloves; gloves for bicycling; neckerchiefs; thermal underwear; mufflers; ear muffs; ] hats; caps[; visors; sports shoes; walking shoes;shoes; gloves for bicycle racing; gloves for cycling ] Class 028. First use: First Use: 0 First Use In Commerce: 0 Miniature toy cars; [ rubber balls; ] model toy vehicles; golf clubs; golf bags; golf balls; golf gloves; [ golf club heads; ] golf club head covers; golf irons; golf putters; golf equipment, namely,golf tees, golf ball markers [ and putting practice mats; ] sports bags shaped to contain specific sports apparatus [ ;tennis rackets; tennis balls ] Class 035. First use: First Use: 0 First Use In Commerce: 0 [ Retail store services and wholesale store services featuring automobiles, tires and parts and fittings for automobiles; retail store services and wholesale store services featuring sporting goods; retail store services and wholesale store services featuring bicycles and parts and fittings for bicycles ] Class 037. First use: First Use: 0 First Use In Commerce: 0 [ Repair and maintenance of automobilesand their parts; repair and mainten- anceof tires for automobiles; retreading oftires; repair and maintenance of two- wheeled motor vehicles and their parts; repair and maintenance of tires for two- wheeled motor vehicles; repair and maintenance of bicycles and their parts; re- pairand maintenance of tires for bicycles; repair and maintenance of tires for aircraft; tire repair and recapping services; roofing services; roof repair; roof install- ation, and maintenance ]

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Signature /Douglas A. Rettew/ Name Douglas A. Rettew Date 06/29/2021 IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

BRIDGESTONE CORPORATION, Opposition No. ______BRIDGESTONE BRANDS, LLC, and BRIDGESTONE AMERICAS TIRE OPERATIONS, LLC, Application No. 90113347 Filed: August 13, 2020 Opposers, Mark: THAISTONE (Stylized) v.

SHENZHEN THAISTONE PRECISION HARDWARE CO., LTD.

Applicant.

NOTICE OF OPPOSITION

Bridgestone Corporation; Bridgestone Brands, LLC; and Bridgestone Americas Tire

Operations, LLC (individually and collectively “Bridgestone”) believe that they will be damaged by the registration of U.S. Application No. 90113347 for the mark THAISTONE (Stylized) in

Class 12 and oppose this application.

As grounds for its opposition, Bridgestone alleges the following, upon actual knowledge with respect to itself and its own acts, and upon information and belief as to all other matters.

Bridgestone and its BRIDGESTONE and FIRESTONE Marks

1. Opposer Bridgestone Corporation is a corporation organized under the laws of

Japan with a business address at 1-1, Kyobashi 3-Chome, Chuo-Ku, Tokyo, Japan.

2. Opposer Bridgestone Brands, LLC is a Delaware limited liability company with a business address at 200 4th Avenue S, Nashville, Tennessee 37201.

3. Opposer Bridgestone Americas Tire Operations, LLC is a Delaware limited liability company with a business address at 200 4th Avenue S, Nashville, Tennessee 37201. 4. Bridgestone and its related and affiliated companies comprise the world’s largest tire and rubber company. Their products are sold in over 150 nations and territories

around the world.

5. Bridgestone owns the BRIDGESTONE and FIRESTONE names and trademarks.

6. Bridgestone has continuously used the FIRESTONE name and trademark for over

a century, dating back to when entrepreneur and innovator Harvey S. Firestone founded

Bridgestone’s predecessor-in-interest, The Firestone Tire and Rubber Company. By 1900, with

12 employees and a single production facility in Akron, Ohio, the Firestone Tire and Rubber

Company produced its first tire. FIRESTONE tires quickly gained a reputation for quality and

performance. They were chosen by Henry Ford for the first mass produced cars in America and,

shortly thereafter, drove to victory in the very first Indy 500 car race (photo of “Firestone Boys”

at the 1925 Indianapolis 500 shown below).

7. BRIDGESTONE tires also have a rich history, dating back to 1930, when the first

BRIDGESTONE tire was produced in Japan. As the company grew, it started offering tires in the United States at least as early as the 1950s and has continued to do so to this day.

8. Today, Bridgestone develops, manufactures, and markets BRIDGESTONE and

FIRESTONE-branded tires for virtually all types of land vehicles, including tires for motorcycles and passenger, light truck, commercial truck and bus, agriculture, and off-the-road vehicles.

9. Bridgestone and its related companies presently have over 40 production facilities in the Americas alone, produce and sell 50 million tires a year, operate over 2,200 directly

owned and operated retail outlets in North America, and employ nearly 45,000 people.

10. The BRIDGESTONE and FIRESTONE marks have been used across

Bridgestone’s extensive tire and product lines and have been featured prominently throughout

Bridgestone’s marketing, advertising, and other materials.

11. The BRIDGESTONE and FIRESTONE marks appear on the sidewall of virtually

all (if not all) of Bridgestone’s tires, as shown in the following examples:

12. The BRIDGESTONE and/or FIRESTONE marks have also been used in

connection with various other tire and automotive products and accessories (e.g., air springs, tire repair kits, road-safety kits, first-aid kits, air compressors, hand-held vacuum cleaners, safety traffic cones, stands adapted for mobile phones, jumper cables, vehicle covers, seat covers, steering wheel covers, trunk bed storage organizers, aftermarket accessories, dusters, wiping cloths, floor mats, and vehicle interior organizer bags, nets, and compartments), services, and related goods (e.g., video games, models, and toys).

13. Bridgestone and its related companies have also manufactured and sold

BRIDGESTONE brand bicycles and parts for over 70 years. BRIDGESTONE bicycles and parts were sold in the U.S. for many years, though are currently not directly available in the U.S.

Even so, the BRIDGESTONE brand continues to enjoy reputation and goodwill within the cycling community. Among other things, Bridgestone’s bicycle brand image and legacy has led to a robust trade in used Bridgestone bicycles that continues in the U.S. to this day. Its brand image is also kept alive through the Internet, including through a community of interest called

“BOB,” short for Bridgestone Owners Bunch. 4

14. In 2017, Bridgestone announced its development of an “airless” bicycle tireshown below and discussed at

http://www.bridgestone.com/corporate/news/2017041701.html:

This technology, which eliminates the need for tires to be inflated and helps realize more

efficient use of resources, has received considerable third-party press and attention.

15. Bridgestone owns, among others, the following valid and subsisting United States trademark registrations for its FIRESTONE mark:

Mark Reg. No./ Goods/Services Issue Date First Use in Commerce 0140804 Rubber tires, pneumatic 03/29/1921 First Use in Commerce: 1900 1178631 Retail tire and automotive store services 11/17/1981 First Use in Commerce: 1928 1387468 Vehicle tires and inner tubes therefor 03/25/1986 First Use in Commerce: 10/31/1971

FIRESTONE 2464005 Vehicle tires and inner tubes therefor 06/26/2001 First Use in Commerce: 12/31/1900

Mark Reg. No./ Goods/Services Issue Date First Use in Commerce 3173847 Automotive repair and maintenance services 11/21/2006 First Use in Commerce: 1929 3173840 Retail tire store services 11/21/2006 First Use in Commerce: 1929 FIRESTONE 5041172 Retail tire, automobile parts and automobile accessories 09/13/2016 store services First Use in Commerce: 1929

Automotive repair and maintenance services First Use in Commerce: 1929 FIRESTONE 3688909 Vehicle suspension components, namely, air springs 09/29/2009 First Use in Commerce: 12/31/1936 3248867 Suspension systems and components for vehicles 06/05/2007 consisting of air springs and control devices; pneumatic suspension springs and shock absorber units for vehicles and structural and replacement parts therefor; air helper springs for vehicles First Use in Commerce: 10/15/1935 FIRESTONE 5448592 First aid kits 04-17-2018 First Use in Commerce: 01/2017

Air compressors; hand-held vacuum cleaners First Use in Commerce: 01/2017

Safety traffic cones; stands adapted for mobile phones; jumper cables First Use in Commerce: 01/2017

Fitted covers for vehicles; fitted car seat covers; steering wheel covers; trunk bed storage organizers; tire repair kits; aftermarket automobile accessories, namely, car interior organizer bags, nets and compartments specifically adapted for fitting in vehicles First Use in Commerce: 01/2017

Dusters; wiping cloths, namely, chamois; microfiber cloths for cleaning First Use in Commerce: 01/2017

Floor mats for vehicles First Use in Commerce: 01/2017

Mark Reg. No./ Goods/Services Issue Date First Use in Commerce 3299861 FIRESTONE Retail tire and automobile parts and accessories store 09/25/2007 First Use in Commerce: 10/31/2005 COMPLETE AUTO CARE Automotive services, namely, automobile repair and maintenance First Use in Commerce: 10/31/2005 3455550 Retail tire and automobile parts and accessories store FIRESTONE 06/24/2008 First Use in Commerce: 10/31/2005 COMPLETE AUTO CARE SINCE 1926 Automotive services, namely, automobile repair and maintenance First Use in Commerce: 10/31/2005 3171276 Credit card services 11/14-2006 First Use in Commerce: 01/31/2005

16. Printouts from the U.S. Patent and Trademark Office’s TESS/TSDR databases, including assignment information, for the registrations listed in Paragraph 15 are attached as

Exhibit A.

17. Additionally, Bridgestone owns, among others, the following valid and subsisting

U.S. trademark registrations for its BRIDGESTONE mark:

Mark Reg. No./ Goods/Services Issue Date First Use in Commerce/Filing Basis

BRIDGESTONE 2886688 Tires 09/21/2004 First Use in Commerce: 12/31/1956 2607465 Tires and inner tubes therefor 08/13/2002 First Use in Commerce: 11/10/1983 BRIDGESTONE 0952683 Rubber tires for vehicles V-STEEL 02-06-1973 First Use in Commerce: 12/30/1970 BRIDGESTONE 5968382 Tires MASTERCORE 01/21/2020 First Use in Commerce: 07/30/2019

Mark Reg. No./ Goods/Services Issue Date First Use in Commerce/Filing Basis 4378086 Rubber tracks for use with crawlers on agricultural 08-06-2013 machinery; rubber tracks for use with crawlers on mining machinery; rubber tracks for use with crawlers on construction, cargo handling machinery; rubber pads to be attached to shoe plates of metal crawlers; rubber tracks for use with crawlers on snow removers; belts for conveyors; hydraulic quick release couplings for high-pressure hoses used in machines Filing Basis: 66(a)

Tires for passenger cars, trucks, buses, racing cars and automobiles; retreaded tires for trucks, buses; retreaded tires; tires for two-wheeled motor vehicles; inner tubes for two-wheeled motor vehicles; tires; tires for off the road vehicles; tires for scrapers; tires for motor graders, tires for shovel loaders; tires for tire rollers; tires for wheeled cranes; tires for cranes; tires for snowplows; tires for pavers; tires for mining machinery Filing Basis: 66(a)

Flexible tubes of rubber and plastic; hydraulic hoses of plastic or rubber; urethane foam insulation for use in land vehicles; flexible rubber tubes; rubber for retreading tires; rubber material for recapping tires Filing Basis: 66(a)

Reusable shopping bags; bags for sports; rucksacks; school bags; umbrellas Filing Basis: 66(a)

Towels of textile Filing Basis: 66(a)

Golf caps; golf shirts; jackets; sport shirts; vests; open- necked shirts; polo shirts; hats; caps Filing Basis: 66(a)

Miniature toy cars; model toy vehicles; golf clubs; golf bags; golf balls; golf gloves; golf club head covers; golf irons; golf putters; golf equipment, namely, golf tees, golf ball markers; sports bags shaped to contain specific sports apparatus Filing Basis: 66(a)

18. Printouts from the U.S. Patent and Trademark Office’s TESS/TSDR databases,

including assignment information, for the registrations listed in Paragraph 17 above are attached

as Exhibit B.

Sale and Promotion of BRIDGESTONE and FIRESTONE-Branded Products and Services

19. Over the years, Bridgestone has sold billions of dollars of tires and other products

branded with the BRIDGESTONE and/or FIRESTONE marks in the U.S.

20. Bridgestone’s BRIDGESTONE and FIRESTONE-branded tires have been sold

through approximately 2,200 company-owned stores and 8,000 authorized and independent

dealers and retailers nationwide—ranging from major retailers such as Walmart, Costco, and

Sears to independent tire dealers.

21. Bridgestone’s BRIDGESTONE and FIRESTONE-branded tires have been

featured as original equipment on some of the world’s top-selling cars and trucks, including

those made by BMW, Toyota, Nissan, General Motors, Chrysler, Daimler (Mercedes-Benz),

Volkswagen, Mazda, Subaru, and others.

22. Bridgestone spends tens of millions of dollars annually advertising, marketing,

and promoting the BRIDGESTONE and FIRESTONE marks and products through virtually

every type of digital, broadcast, and print media, including print advertisements (e.g., magazines and newspapers), television and radio commercials, Internet advertising, social media, billboards, brochures, catalogs, point-of-sale displays, sponsorships, trade shows, and promotional items.

23. In addition, the BRIDGESTONE and FIRESTONE marks are promoted and displayed in a variety of ways through Bridgestone’s company-owned stores and authorized and independent dealers and retailers who have BRIDGESTONE and FIRESTONE signage displayed in and outside their stores.

24. For decades, the BRIDGESTONE and FIRESTONE marks have been promoted through nationally-distributed general-interest magazines such as Fortune, People, Time, Sports

Illustrated, Rolling Stone, Golf Digest, Men’s Fitness, Men’s Health, Jet, and Popular

Mechanics, as well as major national newspapers such as the Wall Street Journal and USA

Today. Additionally, Bridgestone’s corporate-owned stores and independent tire retailers regularly run advertisements in local newspapers throughout the country promoting the

BRIDGESTONE and FIRESTONE marks and tires.

25. The BRIDGESTONE and FIRESTONE marks have been regularly featured in national and local television, cable, and radio advertisements. Bridgestone’s television commercials have appeared on major network channels, including NBC, ABC, CBS, and FOX channels. They have also aired on cable-television networks such as ESPN, MTV, HGTV, TNN,

TNT, VH1, FX, Comedy Central, Discovery Channel, The History Channel, and Speed TV. For example, in 2012 Bridgestone launched its successful “Time to Perform” television advertising campaign, comprised of a series of commercials featuring high-profile professional athletes

(such as NFL players Troy Aikman, Deion Sanders, Matthew Stafford, and Adam Vinatieri;

NBA players Tim Duncan and Steve Nash; NHL Player Drew Doughty; women’s soccer player

Alex Morgan; pro bowler Kelly Kulick; and pro golfers Fred Couples, Matt Kuchar, and Hudson

Swafford) and the BRIDGESTONE mark (representative screenshots below).

26. Among its many other advertisements, in 2012 Bridgestone also launched a nationwide television ad campaign (screen shots shown below) featuring the voice of well- known country music star Trace Adkins and the FIRESTONE mark. This campaign has reached hundreds of millions of viewers nationwide.

27. Starting in 2008, commercials featuring the BRIDGESTONE mark aired during

the Super Bowl and reached over 100 million viewers each year. The 2008 Super Bowl was the

second most watched television program in U.S. history when it aired. The 2011 Super Bowl

broadcast reached over 110 million viewers, breaking the then-existing record for the most-

watched program in U.S. television history. Subsequent Super Bowls have since broken this 11 record, with the 2015 Super Bowl broadcast reaching over 114 million viewers.

28. The BRIDGESTONE and FIRESTONE marks have further been promoted through Bridgestone’s sponsorship of a number of high-profile sports leagues, associations, and events. For example, BRIDGESTONE tires are currently the Official Tire of the National

Football League (NFL), the National Hockey League (NHL), National Hockey League Players

Association (NHLPA), and the Professional Golfers Association (PGA) Tour. Bridgestone was the title sponsor of the Super Bowl XLII, XLIII, and XLIV “Bridgestone Super Bowl Halftime

Show” and currently sponsors the NHL Winter Classic (depicted below) and the World Golf

Championships–Bridgestone Invitational played at the Firestone Country Club in Akron, Ohio.

FIRESTONE is (and/or has been) the Official Tire of Major League Baseball and the Official

Tire of the Indy Racing League, IndyCar, and the Indianapolis 500.

29. Moreover, Bridgestone has signed on to be 1 of 12 primary Olympics partners/sponsors (along with Coca-Cola, McDonalds, Visa, Samsung, and others) through 2024.

Bridgestone is the Official Tire of the Olympic Games. It is also a Founding Partner of the

Olympic Channel (logo shown below), supporting this groundbreaking digital platform in its mission to celebrate the Olympic Movement and the world’s greatest athletes every day of the year. In the U.S., Bridgestone is a proud partner of the United States Olympic Committee and

U.S. Paralympics through 2024.

30. The BRIDGESTONE and FIRESTONE marks have been promoted through various widely followed automotive racing events, including Formula 1 racing, for many years.

During that time, Formula 1 race cars were equipped with BRIDGESTONE tires featuring the

BRIDGESTONE mark in prominent white lettering on the tire sidewall, as shown below. In addition to Formula 1, the BRIDGESTONE mark has been promoted through sponsorship of the

Champ Car World Series since 1996 and Formula D Drift Series racing. The FIRESTONE mark has been prominently featured in connection with the Indy 500 race. From 1920 through 1966,

Firestone won every Indy 500 race—a record unmatched by any other tire manufacturer. The

BRIDGESTONE and/or FIRESTONE marks/names have appeared prominently on signage and other materials throughout these events.

31. In 2010, Nashville’s sports and entertainment venue (depicted below) was

renamed BRIDGESTONE ARENA. The BRIDGESTONE ARENA venue is home to the

Predators―Nashville’s NHL hockey team. The venue has received several awards, 14 including the ACM (Academy of Country Music) Venue of the Year, the IEBD

(International Entertainment Buyers Association) Venue of the Year, Facilities Magazine

Prime Site, and Pollstar Venue of the Year. It has also hosted high-profile events, such as the third round of the 2012 NCAA Men’s Basketball Tournament, 2011 Stanley Cup

Western Conference Quarterfinals and Semifinals, and 45th and 51st Annual Country Music

Awards. In 2017, Bridgestone’s naming rights in the BRIDGESTONE ARENA were extended to 2025.

32. The BRIDGESTONE and FIRESTONE marks have also been promoted online through various company websites, popular social-networking websites (including Facebook,

Twitter, Instagram, and YouTube), and advertising placed on third-party websites.

33. In addition to its own substantial advertising and promotional activities,

Bridgestone, the BRIDGESTONE and FIRESTONE marks, Bridgestone’s products, and

Bridgestone’s sponsored events receive a significant amount of unsolicited media coverage, including on nationally broadcast television programs and in widely circulated publications.

34. As a result of the distinctive nature and inherent strength of the BRIDGESTONE and FIRESTONE marks; widespread use, advertising, publicity, and promotion; and billions of

dollars of sales, the BRIDGESTONE and FIRESTONE marks have been well-known and

famous since long before Applicant’s filing date.

35. In Bridgestone/Firestone North American Tire, LLC and BFS Brands, LLC v.

Silverstone Berhad, 2003 TTAB LEXIS 142, 28-29 (TTAB 2003), the Trademark Trial and

Appeal Board of the United States Patent and Trademark Office held, after a full trial, that the

FIRESTONE mark is famous.

36. In Bridgestone Brands, LLC et al. v. Dastgah, Case No. 16-cv-00906, the U.S.

District Court for the Northern District of California held, on a motion for a temporary restraining order, that the FIRESTONE mark is famous.

37. In Bridgestone Brands, LLC et al. v. Katy Freeway Tire & Auto., Inc. et al., Case

No. 4:15-cv-02274, the U.S. District Court for the Southern District of Texas held, on a motion for summary judgment, that the FIRESTONE mark is famous.

38. In Bridgestone Brands, LLC et al. v. Apollo Auto Sales & Services, Inc. et al.,

Case No. 15-cv-00857, the U.S. District Court for the Middle District of Tennessee held, on a motion for summary judgment, that the FIRESTONE mark is famous.

Applicant and Its Mark

39. Applicant “Shenzhen ThaiStone Precision Hardware Co. ,ltd.” is a limited

liability company organized under the laws of China, with an address at C,2/F,Bldg

A1,Zhongpengcheng IP,4th IZ, Heshuikou Community, Matian St.,Guangming, Shenzhen,

Guangdong CHINA 518107.

40. On August 13, 2020, Applicant filed a use-based application for the mark

THAISTONE (Stylized) (alleging a first-use and first-use-in-commerce date of August 4, 2020),

which was assigned Serial No. 90113347, for “Dinghies; Air pumps for automobiles; Air pumps

for bicycles; Air pumps for motorcycles; Air pumps for two-wheeled motor vehicles or bicycles; 16

Bicycle pumps; Casings for pneumatic tires; Tire inflators; Tire inflators; Pumps for inflating

vehicle tyres” in Class 12.

Count One Likelihood of Confusion, 15 U.S.C. § 1052(d)

41. Bridgestone repeats and re-alleges each and every allegation set forth in each of

the preceding paragraphs.

42. Bridgestone’s use and registration of its BRIDGESTONE and FIRESTONE

marks and names long predate the August 13, 2020 filing date of Application No. 90113347 and

the August 4, 2020 first-use date alleged by Applicant.

43. Applicant’s THAISTONE (Stylized) mark so resembles Bridgestone’s prior used and registered BRIDGESTONE and FIRESTONE marks, and the goods covered by

Bridgestone’s used/registered BRIDGESTONE and FIRESTONE marks and Applicant’s

THAISTONE (Stylized) mark are overlapping and similar, such that a potential consumer would be likely to be confused, mistaken, or deceived as to the source of the parties’ respective goods under Section 2(d) of the Lanham Act, as amended, 15 U.S.C. § 1052(d).

Count Two Dilution, 15 U.S.C. § 1125(c)

44. Bridgestone repeats and re-alleges each and every allegation set forth in each of

the preceding paragraphs.

45. Through extensive use and promotion, Bridgestone’s distinctive BRIDGESTONE and FIRESTONE marks and names have become famous, as defined under Section 43(c)(1) of the Lanham Act, as amended, 15 U.S.C. § 1125(c)(1).

46. The BRIDGESTONE and FIRESTONE marks and names became famous well

before Applicant’s August 13, 2020 filing date and the August 4, 2020 first-use date alleged by

Applicant. 17

47. Applicant’s THAISTONE (Stylized) mark is likely to dilute the distinctive quality of the BRIDGESTONE and FIRESTONE marks and names under Section 43(c) of the Lanham

Act, as amended, 15 U.S.C. § 1125(c).

WHEREFORE, Bridgestone believes that it is being and will continue to be damaged by the registration of the THAISTONE (Stylized) mark shown in Application No. 90113347 and respectfully requests that this opposition be sustained and that Application No. 90113347 be refused.

A filing fee has been submitted electronically. If the filing fee is found to be insufficient for any reason, please charge such deficiency to Deposit Account No. 06-0916.

Respectfully submitted,

Dated: June 29, 2021 / Douglas A. Rettew / Douglas A. Rettew Patrick J. Rodgers FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue, N.W. Washington, D.C. 20001-4413 Telephone: (202) 408-4000

Morgan E. Smith FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 3300 Hillview Avenue Palo Alto, California 94304-1203 Telephone: (650) 849-6600

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

Attorneys for Opposers Bridgestone Corporation, Bridgestone Brands, LLC, and Bridgestone Americas Tires Operations, LLC

Notice of Opposition Application No. 90113347 Mark: THAISTONE (Stylized)

Exhibit A 6/29/2021 Trademark Electronic Search System (TESS)

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Word Mark FIRESTONE Goods and IC 007 012 017. US 035. G & S: Rubber Tires, Pneumatic [ and Solid; Inner Tubes, Rubber-Impregnated Tire Services Building and Rebuilding Fabrics; Tire Accessories-Namely, ] [ Hook-On Boots, Lace-On Boots, ] [ Flaps, and Tire- Repair Air-Bags, Fabric and Rubber Repair-Patches, Tube-Patches in Sheet and Patch Form, and Reliners and Tire-Repair Gum Materials in Sheet Form-Namely, Tread-Gums, Cushion-Gums, Tube-Gums, Camel-Back-Tread Gums, and Combination-Gums ]. FIRST USE: 19000000. FIRST USE IN COMMERCE: 19000000 Mark Drawing (5) WORDS, LETTERS, AND/OR NUMBERS IN STYLIZED FORM Code Serial 71130668 Number Filing Date April 5, 1920 Current 1A Basis Original 1A Filing Basis Registration 0140804 Number Registration March 29, 1921 Date Owner (REGISTRANT) Firestone Tire & Rubber Company, The CORPORATION OHIO MAIN STREET AND COLE AVENUE Akron OHIO 44301

(LAST LISTED OWNER) BRIDGESTONE BRANDS, LLC LIMITED LIABILITY COMPANY DELAWARE 200 4th Avenue South Nashville TENNESSEE 37201

Assignment ASSIGNMENT RECORDED Recorded Attorney of Dayna M Frenkel Record https://tmsearch.uspto.gov/bin/showfield?f=doc&state=4801:zweggw.3.43 1/2 6/29/2021 Trademark Electronic Search System (TESS) Type of TRADEMARK Mark Register PRINCIPAL Affidavit SECTION 8(10-YR) 20200612. Text Renewal 6TH RENEWAL 20200612 Live/Dead LIVE Indicator

https://tmsearch.uspto.gov/bin/showfield?f=doc&state=4801:zweggw.3.43 2/2 Generated on: This page was generated by TSDR on 2021-06-29 16:34:22 EDT Mark: FIRESTONE

US Serial Number: 71130668 Application Filing Apr. 05, 1920 Date: US Registration 140804 Registration Date: Mar. 29, 1921 Number: Register: Principal Mark Type: Trademark TM5 Common Status LIVE/REGISTRATION/Issued and Active Descriptor: The trademark application has been registered with the Office.

Status: The registration has been renewed. Status Date: Jun. 12, 2020

Mark Information

Mark Literal FIRESTONE Elements: Standard Character No Claim: Mark Drawing 5 - AN ILLUSTRATION DRAWING WITH WORD(S) /LETTER(S)/ NUMBER(S) INSTYLIZED FORM Type: 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: Rubber Tires, Pneumatic [ and Solid; Inner Tubes, Rubber-Impregnated Tire Building and Rebuilding Fabrics; Tire Accessories- Namely, ] [ Hook-On Boots, Lace-On Boots, ] [ Flaps, and Tire-Repair Air-Bags, Fabric and Rubber Repair-Patches, Tube-Patches in Sheet and Patch Form, and Reliners and Tire-Repair Gum Materials in Sheet Form-Namely, Tread-Gums, Cushion-Gums, Tube- Gums, Camel-Back-Tread Gums, and Combination-Gums ] International 007, 012, 017 U.S Class(es): 035 - Primary Class Class(es): Class Status: ACTIVE Basis: 1(a) First Use: 1900 Use in Commerce: 1900 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: BRIDGESTONE BRANDS, LLC Owner Address: 200 4th Avenue South Nashville, TENNESSEE UNITED STATES 37201 Legal Entity Type: LIMITED LIABILITY COMPANY State or Country DELAWARE Where Organized: Attorney/Correspondence Information

Attorney of Record Attorney Name: Dayna M Frenkel Attorney Primary [email protected] Attorney Email Yes Email Address: Authorized: Correspondent Correspondent Dayna M Frenkel Name/Address: Bridgestone Americas, Inc. 200 4th Avenue South Nashville, TENNESSEE UNITED STATES 37201 Correspondent e- [email protected] [email protected] Correspondent e- Yes mail: mail Authorized: Domestic Representative - Not Found Prosecution History

Proceeding Date Description Number Feb. 02, 2021 APPLICANT/CORRESPONDENCE CHANGES (NON-RESPONSIVE) ENTERED 88888 Feb. 02, 2021 TEAS CHANGE OF CORRESPONDENCE RECEIVED Feb. 02, 2021 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED Feb. 02, 2021 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED Feb. 02, 2021 TEAS CHANGE OF OWNER ADDRESS RECEIVED Jun. 12, 2020 NOTICE OF ACCEPTANCE OF SEC. 8 & 9 - E-MAILED Jun. 12, 2020 REGISTERED AND RENEWED (SIXTH RENEWAL - 10 YRS) 70833 Jun. 12, 2020 REGISTERED - SEC. 8 (10-YR) ACCEPTED/SEC. 9 GRANTED 70833 Jun. 12, 2020 CASE ASSIGNED TO POST REGISTRATION PARALEGAL 70833 Mar. 30, 2020 TEAS SECTION 8 & 9 RECEIVED Mar. 29, 2020 COURTESY REMINDER - SEC. 8 (10-YR)/SEC. 9 E-MAILED Jan. 16, 2020 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED Jan. 16, 2020 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED Nov. 20, 2019 NOTICE OF SUIT Jan. 20, 2016 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED Jan. 20, 2016 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Dec. 17, 2013 NOTICE OF SUIT Mar. 22, 2011 REGISTERED AND RENEWED (FIFTH RENEWAL - 10 YRS) 75461 Mar. 22, 2011 REGISTERED - SEC. 8 (10-YR) ACCEPTED/SEC. 9 GRANTED Mar. 17, 2011 CASE ASSIGNED TO POST REGISTRATION PARALEGAL 75461 Mar. 15, 2011 TEAS SECTION 8 & 9 RECEIVED Mar. 17, 2010 AUTOMATIC UPDATE OF ASSIGNMENT OF OWNERSHIP Jan. 12, 2009 CASE FILE IN TICRS Jul. 13, 2001 REGISTERED AND RENEWED (FOURTH RENEWAL - 10 YRS) Jul. 13, 2001 REGISTERED - SEC. 8 (10-YR) ACCEPTED/SEC. 9 GRANTED Mar. 27, 2001 REGISTERED - COMBINED SECTION 8 (10-YR) & SEC. 9 FILED Mar. 29, 1981 REGISTERED AND RENEWED (THIRD RENEWAL - 20 YRS) TM Staff and Location Information TM Staff Information - None File Location Current Location: GENERIC WEB UPDATE Date in Location: Jun. 12, 2020 Assignment Abstract Of Title Information

Summary Total Assignments: 7 Registrant: Firestone Tire & Rubber Company, The

Assignment 1 of 7

Conveyance: CHANGE OF NAME 19890801 Reel/Frame: 0668/0219 Pages: 0 Date Recorded: Aug. 31, 1989 Supporting No Supporting Documents Available Documents: Assignor Name: FIRESTONE TIRE & RUBBER COMPANY Execution Date: Jul. 31, 1989 Legal Entity Type: CORPORATION State or Country OHIO Where Organized: Assignee Name: BRIDGESTONE/FIRESTONE, INC. Legal Entity Type: CORPORATION State or Country OHIO Where Organized: Address: No Assignee Address Found Correspondent Correspondent D.A. THOMAS Name: Correspondent C/O THE FIRESTONE TIRE & RUBBER COMPANY Address: 1200 FIRESTONE PARKWAY AKRON, OH 44317 Domestic Representative - Not Found Assignment 2 of 7

Conveyance: ASSIGNS THE ENTIRE INTEREST Reel/Frame: 1772/0758 Pages: 15 Date Recorded: Aug. 04, 1998 Supporting assignment-tm-1772-0758.pdf Documents: Assignor Name: BRIDGESTONE/FIRESTONE, INC. Execution Date: Jun. 01, 1998 Legal Entity Type: CORPORATION State or Country OHIO Where Organized: Assignee Name: BRIDGESTONE/FIRESTONE RESEARCH, INC. Legal Entity Type: CORPORATION State or Country DELAWARE Where Organized: Address: 1659 SOUTH MAIN STREET AKRON, OHIO 44301 Correspondent Correspondent BRIDGESTONE/FIRESTONE, INC. Name: Correspondent D. A. THOMAS Address: 1200 FIRESTONE PARKWAY AKRON, OHIO 44317-0001 Domestic Representative - Not Found Assignment 3 of 7

Conveyance: ACKNOWLEDGEMENT OF CONVERSION Reel/Frame: 2401/0692 Pages: 17 Date Recorded: Dec. 11, 2001 Supporting assignment-tm-2401-0692.pdf Documents: Assignor Name: BRIDGESTONE/FIRESTONE RESEARCH, INC. Execution Date: Nov. 28, 2001 Legal Entity Type: CORPORATION State or Country No Place Where Organized Found Where Organized: Assignee Name: BRIDGESTONE/FIRESTONE RESEARCH, LLC Legal Entity Type: LIMITED LIABILITY COMPANY - STATE State or Country No Place Where Organized Found Where Organized: Address: 1659 SOUTH MAIN STREET AKRON, OHIO 44301 Correspondent Correspondent BRIDGESTONE/FIRESTONE AMERICAS Name: Correspondent HOLDING, INC. Address: JOHN H. HORNICKEL 1200 FIRESTONE PARKWAY AKRON, OH 44317-0001 Domestic Representative - Not Found Assignment 4 of 7

Conveyance: ASSIGNS THE ENTIRE INTEREST Reel/Frame: 2405/0314 Pages: 14 Date Recorded: Dec. 13, 2001 Supporting assignment-tm-2405-0314.pdf Documents: Assignor Name: BRIDGESTONE/FIRESTONE RESEARCH, LLC Execution Date: Nov. 30, 2001 Legal Entity Type: LIMITED LIABILITY COMPANY - STATE State or Country No Place Where Organized Found Where Organized: Assignee Name: BRIDGESTONE/FIRESTONE NORTH AMERICAN TIRE, LLC Legal Entity Type: LIMITED LIABILITY COMPANY - STATE State or Country No Place Where Organized Found Where Organized: Address: 50 CENTURY BOULEVARD NASHVILLE, TENNESSEE 37214 Correspondent Correspondent BRIDGESTONE/FIRESTONE AMERICAS Name: Correspondent HOLDING, INC. - JOHN H. HORNICKEL Address: 1200 FIRESTONE PARKWAY AKRON, OH 44317-0001 Domestic Representative - Not Found Assignment 5 of 7

Conveyance: MERGER Reel/Frame: 2407/0040 Pages: 10 Date Recorded: Dec. 17, 2001 Supporting assignment-tm-2407-0040.pdf Documents: Assignor Name: BRIDGESTONE/FIRESTONE NORTH Execution Date: Nov. 30, 2001 AMERICAN TIRE, LLC Legal Entity Type: LIMITED LIABILITY COMPANY State or Country No Place Where Organized Found Where Organized: Assignee Name: BFS BRANDS, LLC Legal Entity Type: LIMITED LIABILITY COMPANY State or Country No Place Where Organized Found Where Organized: Address: 50 CENTURY BOULEVARD NASHVILLE, TENNESSEE 37214 Correspondent Correspondent BRIDGESTONE/FIRESTONE AMERICAS Name: Correspondent HOLDING, INC. Address: JOHN H. HORNICKEL 1200 FIRESTONE PARKWAY AKRON, OH 44317-0001 Domestic Representative - Not Found Assignment 6 of 7

Conveyance: RE-RECORD TO CORRECT THE NATURE OF CONVEYANCE TO READ "ASSIGNMENT", PREVIOUSLY RECORDED ON REEL 002407 FRAME 0040. Reel/Frame: 2558/0047 Pages: 12 Date Recorded: Jul. 17, 2002 Supporting assignment-tm-2558-0047.pdf Documents: Assignor Name: BRIDGESTONE/FIRESTONE NORTH Execution Date: Nov. 30, 2001 AMERICAN TIRE, LLC Legal Entity Type: LIMITED LIABILITY COMPANY State or Country DELAWARE Where Organized: Assignee Name: BFS BRANDS, LLC Legal Entity Type: LIMITED LIABILITY COMPANY State or Country DELAWARE Where Organized: Address: 50 CENTURY BOULEVARD NASHVILLE, TENNESSEE 37214 Correspondent Correspondent BRIDGESTONE/FIRESTONE AMERICA HOLDING Name: Correspondent INC. - MEREDITH E. PALMER Address: 1200 FIRESTONE PARKWAY AKRON, OHIO 44317-0001 Domestic Representative - Not Found Assignment 7 of 7

Conveyance: CHANGE OF NAME Reel/Frame: 4164/0492 Pages: 5 Date Recorded: Mar. 10, 2010 Supporting assignment-tm-4164-0492.pdf Documents: Assignor Name: BFS BRANDS, LLC Execution Date: Dec. 18, 2008 Legal Entity Type: LIMITED LIABILITY COMPANY State or Country DELAWARE Where Organized: Assignee Name: BRIDGESTONE BRANDS, LLC Legal Entity Type: LIMITED LIABILITY COMPANY State or Country DELAWARE Where Organized: Address: 535 MARRIOTT DRIVE NASHVILLE, TENNESSEE 37214 Correspondent Correspondent THOMAS R. KINGSBURY Name: Correspondent 1200 FIRESTONE PARKWAY Address: AKRON, OH 44317 Domestic Representative - Not Found 6/29/2021 Trademark Electronic Search System (TESS)

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Word Mark FIRESTONE Goods and IC 042. US 101. G & S: Retail Tire and Automotive Store Services. FIRST USE: 19281224. FIRST USE IN Services COMMERCE: 19280000 Mark Drawing (5) WORDS, LETTERS, AND/OR NUMBERS IN STYLIZED FORM Code Serial Number 73250427 Filing Date February 15, 1980 Current Basis 1A Original Filing 1A Basis Published for August 25, 1981 Opposition Registration 1178631 Number Registration Date November 17, 1981 Owner (REGISTRANT) Firestone Tire & Rubber Company, The CORPORATION OHIO 1200 Firestone Pkwy. Akron OHIO 44317

(LAST LISTED OWNER) BRIDGESTONE BRANDS, LLC LIMITED LIABILITY COMPANY DELAWARE 200 4th Avenue South Nashville TENNESSEE 37201

Assignment ASSIGNMENT RECORDED Recorded Attorney of Record Dayna M Frenkel Prior Registrations 0140804;0948402;AND OTHERS Type of Mark SERVICE MARK Register PRINCIPAL-2(F) Affidavit Text SECT 15. SECT 8 (6-YR). SECTION 8(10-YR) 20111119. Renewal 2ND RENEWAL 20111119 Live/Dead LIVE Indicator

https://tmsearch.uspto.gov/bin/showfield?f=doc&state=4801:zweggw.4.1 1/1 Generated on: This page was generated by TSDR on 2021-06-29 16:35:57 EDT Mark: FIRESTONE

US Serial Number: 73250427 Application Filing Feb. 15, 1980 Date: US Registration 1178631 Registration Date: Nov. 17, 1981 Number: Register: Principal Mark Type: Service Mark TM5 Common Status LIVE/REGISTRATION/Issued and Active Descriptor: The trademark application has been registered with the Office.

Status: The registration has been renewed. Status Date: Nov. 19, 2011 Publication Date: Aug. 25, 1981

Mark Information

Mark Literal FIRESTONE Elements: Standard Character No Claim: Mark Drawing 5 - AN ILLUSTRATION DRAWING WITH WORD(S) /LETTER(S)/ NUMBER(S) INSTYLIZED FORM Type: Acquired In whole Distinctiveness Claim: Related Properties Information

Claimed Ownership 01408040, 09484020 and others of US Registrations: Goods and Services

For: Retail Tire and Automotive Store Services International 042 - Primary Class U.S Class(es): 101 Class(es): Class Status: ACTIVE Basis: 1(a) First Use: Dec. 24, 1928 Use in Commerce: 1928 Basis Information (Case Level)

Attorney of Record Attorney Name: Dayna M Frenkel Attorney Primary [email protected] Attorney Email Yes Email Address: Authorized: Correspondent Correspondent Dayna M Frenkel Name/Address: Bridgestone Americas, Inc. 200 4th Avenue South Nashville, TENNESSEE UNITED STATES 37201 Correspondent e- [email protected] [email protected] giesl Correspondent e- Yes mail: [email protected] mail Authorized: Domestic Representative - Not Found Prosecution History

Proceeding Date Description Number May 07, 2021 TEAS SECTION 8 & 9 RECEIVED Feb. 02, 2021 APPLICANT/CORRESPONDENCE CHANGES (NON-RESPONSIVE) ENTERED 88888 Feb. 02, 2021 TEAS CHANGE OF CORRESPONDENCE RECEIVED Feb. 02, 2021 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED Feb. 02, 2021 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED Feb. 02, 2021 TEAS CHANGE OF OWNER ADDRESS RECEIVED Nov. 17, 2020 COURTESY REMINDER - SEC. 8 (10-YR)/SEC. 9 E-MAILED Jan. 16, 2020 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED Jan. 16, 2020 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED Nov. 20, 2019 NOTICE OF SUIT Jan. 20, 2016 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED Jan. 20, 2016 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Nov. 20, 2015 NOTICE OF SUIT Dec. 17, 2013 NOTICE OF SUIT Nov. 19, 2011 REGISTERED AND RENEWED (SECOND RENEWAL - 10 YRS) 73376 Nov. 19, 2011 REGISTERED - SEC. 8 (10-YR) ACCEPTED/SEC. 9 GRANTED 73376 Nov. 17, 2011 TEAS SECTION 8 & 9 RECEIVED Mar. 17, 2010 AUTOMATIC UPDATE OF ASSIGNMENT OF OWNERSHIP Mar. 20, 2008 CASE FILE IN TICRS Jan. 17, 2002 REGISTERED AND RENEWED (FIRST RENEWAL - 10 YRS) Jan. 17, 2002 REGISTERED - SEC. 8 (10-YR) ACCEPTED/SEC. 9 GRANTED Nov. 01, 2001 REGISTERED - COMBINED SECTION 8 (10-YR) & SEC. 9 FILED Mar. 21, 1988 REGISTERED - SEC. 8 (6-YR) ACCEPTED & SEC. 15 ACK. Sep. 08, 1987 REGISTERED - SEC. 8 (6-YR) & SEC. 15 FILED Nov. 17, 1981 REGISTERED-PRINCIPAL REGISTER Aug. 25, 1981 PUBLISHED FOR OPPOSITION TM Staff and Location Information

TM Staff Information - None File Location Current Location: GENERIC WEB UPDATE Date in Location: Nov. 19, 2011 Assignment Abstract Of Title Information

Summary Total Assignments: 7 Registrant: Firestone Tire & Rubber Company, The

Assignment 1 of 7

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Word Mark FIRESTONE Goods and IC 012. US 035. G & S: VEHICLE TIRES AND INNER TUBES THEREFOR. FIRST USE: 19711031. FIRST USE IN Services COMMERCE: 19711031 Mark Drawing (5) WORDS, LETTERS, AND/OR NUMBERS IN STYLIZED FORM Code Serial Number 73555946 Filing Date August 29, 1985 Current Basis 1A Original Filing 1A Basis Published for December 31, 1985