Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov ESTTA Tracking number: ESTTA1104197 Filing date: 12/24/2020

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD Proceeding 91245750 Party Defendant The National Association of Professional Leagues, Inc. Baseball Leagues, Inc. Correspondence MARY FRAN LOVE Address MUNCY, GEISSLER, OLDS & LOWE, P.C. 4000 LEGATO ROAD SUITE 310 FAIRFAX, VA 22033 UNITED STATES Primary Email: [email protected] Secondary Email(s): [email protected], [email protected], [email protected] 202-247-7929

Submission Testimony For Defendant Filer's Name H. David Starr Filer's email [email protected] Signature /H. David Starr/ Date 12/24/2020 Attachments FOUNTAIN Trial Declaration with Exhibits.pdf(4239674 bytes ) IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

------ Baseball Club, Inc., ) Opposition No. 91245750 [Parent] ) Opposition No. 91245751 Opposer, ) ) DECLARATION OF v. ) ROBERT FOUNTAIN ) The National Association of ) Leagues, Inc., ) ) Applicant. ) ) ------

I, Robert Fountain, declare that:

1. I was formerly employed by The National Association of Professional Baseball

Leagues, Inc. (“Applicant”) from August 2010 through September 2020. My final position with

Applicant was serving as its Deputy General Counsel. I make this Declaration based on my

personal knowledge of the facts and circumstances stated below.

2. Applicant is non-profit trade association of professional baseball leagues and

teams. It trades under the name . Applicant’s website is attached as

Exhibit A from the following url: http://www.milb.com/milb/history/general_history.jsp.

3. Over the years, Applicant’s member baseball leagues have included both Major

League Baseball-affiliated teams and independent-unaffiliated teams, especially at the lower classification levels.

4. Of specific relevance, the Portland Mavericks was an independent-unaffiliated baseball team that played in Applicant’s member league, the from 1973 through 1977. The Northwest League continues to exist and be a member to this date. 5. Although an independent-unaffiliated team, I have always understood the

Portland Mavericks to be a member club of Applicant, both directly and indirectly through the

Northwest League.

6. As such, given the direct and indirect affiliation of the Portland Mavericks with

Applicant, I strongly dispute any contention that any of my statements in filings in the USPTO were anything but true. Further, all of my statements made on information and belief were believed to be true.

7. Furthermore, I did not have any knowledge of the Opposer at the time I filed any of the Portland Mavericks applications. To the best of my recollection, the first time I learned of

Opposer’s existence was at the time its oppositions were filed.

8. I have reviewed the Declaration of Bill Stewart, dated October 28, 2020, submitted by the Opposer in this matter.

9. Mr. Stewart’s Declaration refers to the June 2017 letter I sent to him upon learning of their unlicensed use of PORTLAND MAVERICKS. We had filed the subject applications and two additional Class 25 applications in April 2017. As such, the PORTLAND

MAVERICKS marks were the subject of applications for federal registration.

10. The letter also refers to the inclusion of the PORTLAND MAVERICKS trademark in Applicant’s Hometown Collection, which Applicant refers to on its website as:

The Minor League Baseball Hometown Collection celebrates the rich, colorful

heritage of Minor League Baseball and the special place that the Minor Leagues

occupy in our national culture. Embracing franchises both iconic and obscure, Hometown Collection products span the globe from Havana to Hawaii, from

Vancouver to Charleston, as well as dozens of points in between, from the days

of flannel uniforms to the present time.

https://milbstore.com/collections/hometown-collection?page=2&sort_by=title-ascending (visited

December 14, 2020). True and correct printouts showing PORTLAND MAVERICKS apparel currently sold at Applicant’s online store are submitted herewith as Exhibit B.

11. To the best of my knowledge, Mr. Stewart has not previously communicated any concerns with the signed letter agreement to Applicant and, to my knowledge, has not initiated any litigation to void the letter agreement.

12. Although it would have been more clear in my letter to state that that the Portland

Mavericks trademarks are the subject of applications for trademark registrations, I dispute the contention that my letter contains “material misrepresentations” as our assertion of trademark rights was based upon the historical relationship of the marks with Applicant as well as

Applicant’s ongoing licensing program.

13. I have reviewed the Declaration of Dustin Alameda, dated October 29, 2020, submitted by the Opposer in this proceeding.

14. Although Applicant is engaged in other USPTO proceedings with Mr. Alameda’s company, these proceedings have no bearing on the present proceedings with Opposer.

15. Mr. Alameda contends that I “threatened” him in a phone call. I certainly never threatened him personally. I merely communicated to Mr. Alameda that Applicant has certain rights and potential remedies and sought to work towards an amicable resolution with his

company 503 Sports.

The signatory being warned that willful false statements and the like are punishable by fine or imprisonment, or both, under 18 U.S.C. 1001, declares that all statements made of his own knowledge are true and all statements made on information and belief are believed to be true.

Executed on December 18, 2020 at Valrico, Florida.

______Robert Fountain

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Official Info General History Jobs MiLB History Home This Day in MiLB History Top 100 Teams Timeline Award winners Presidents General History The History & Function of Minor League Baseball Alumni The National Association of Professional Baseball Leagues, now Green Team known as Minor League Baseball, was formed Sept. 5, 1901, from Licensing a meeting of Minor League executives at the Leland Hotel in Chicago. The President of the Eastern League, Patrick T. Powers, Sponsorship was elected as the first President of the NAPBL. Fourteen leagues Charity partners and 96 clubs were members during the first season in 1902. The first NA office was established in Auburn, New York, under Umpires President Powers and successfully by Secretary-Treasurer MiLB Office John H. Farrell. By the time Powers left office in 1909, there were 35 leagues and 246 clubs. Publications In 1910, Michael Sexton became President. In his first few years, Help Center wars between the Major Leagues and the outlaw Federal League hurt Minor League Baseball. The Federal League raided top Minor League Baseball teams, as well as National and teams, for players and territory. Sexton led a fight at the 1914 Baseball Winter Meetings to ward off a bid from radicals for Minor played for the , League Baseball to desert the Major Leagues and back the a Dodgers farm team, before he integrated the Federal League. For 22 years, Sexton presided over Minor Major Leagues. (AP) League Baseball, leaving at the height of the Depression in 1932. But during his time, peace was restored and the Minor Leagues began to flourish. At the Winter Meetings of 1932, Judge William G. Bramham was elected President and served for 15 years. Bramham, who moved the NAPBL office to Durham, North Carolina, inherited 14 leagues and 102 clubs, but turned over 52 leagues and 388 clubs to George M. Trautman in 1947. During the height of World War II in 1943, the National Association had only 66 clubs and drew less than six million fans, an all-time low. But the end of the war would see fans again crowding into the ballparks in record numbers. Trautman moved the office to Columbus, Ohio, as he began a 16-year reign as President. The year 1949 saw 59 leagues and 448 clubs, both all-time highs, attract 39,640,443 fans, a record that stood for 54 years. However, the advent of television and, in Trautman's last two years, Major League expansion, would begin to cut into attendance. Following Trautman's death in March 1963, Frank Shaughnessy served as interim president until Trautman's assistant, Phillip Piton, was elected in December 1963. There were 20 leagues and 132 clubs in 1964 and attendance was only 10 million. By the time Piton left office in 1971, membership was back to 155 clubs. With the election of Henry J. Peters as President in December 1971, the NA was headed for another move. In September 1973, the office found its fourth home on Fourth Street South in St. Petersburg, Florida. Peters left in 1975 to become General of the . Robert R. "Bobby" Bragan SALE became President in January 1976, and by 1978 there were 158 clubs. On March 28, 1978, the office moved five blocks to $159.99 Bayshore Drive into the old clubhouse beside , which was renovated and turned into an office building. HP OceJet Pro 9015 Wireless Color Inkjet In January 1979, John H. Johnson took office. While the number All-In-One Printer of clubs stayed near 160-170, attendance skyrocketed. In 1987, Save $70/Reg $229.99 more than 20 million fans attended games, a figure not matched since 1953. Franchise values also went up dramatically during Johnson's time. Johnson died January 12, 1988, and Sal B. Artiaga was elected in April as the ninth President. His first year in office saw Minor League Baseball climb to over 21,659,000 in Order online. Pick The Splendid Splinter first honed his attendance with 188 clubs. up curbside. unique batting skills as a Minor Leaguer with the Available in most Mike Moore, who had been Chief Administrative Officer of the NA, in 1936. (Pacific Coast stores* was elected President during the 1991 Baseball Winter Meetings. League) One of his first moves after taking over in January 1992 was to convene a constitutional convention that would rewrite the National Association Agreement, the by-laws that spell out the relationship between the NA and its member leagues. It was an agreement that had not materially changed in nearly a century of existence. One of the more important changes was converting the National Association to more of a "corporate" structure than a "political" one. The governing authority of the NA is vested in the President, working closely on policy and direction with the 17-member Board of Trustees (consisting of one club owner from each of the various leagues) and the Council of www.milb.com/milb/history/general_history.jsp 1/3 4/2/2020 General History | MiLB.com History | The Official Site of Minor League Baseball League Presidents (consisting of the Presidents of the various leagues.) The President is elected at an annual meeting of the Minor League Baseball membership for a four-year term. The NA had phenomenal growth under the leadership of Moore, who retired in December 2007, after 16 years as President. In 1991, prior to becoming President, he established an agency agreement partnership between the Professional Baseball Promotion Corporation, a NAPBL subsidiary, and Properties to authorize licensed merchandise. From a humble beginning in the early 1990s, merchandise sales in 2017 topped $70 million. At the Baseball Winter Meetings, the Promo Corp. conducts the annual Baseball Trade Show, where merchandisers and manufacturers display the goods that will fill stadium novelty stands and souvenir shops in the year ahead, and conducts business seminars for member teams. The Promo Corp. also runs Professional Baseball Employment Opportunities (PBEO), which assists candidates seeking jobs in pro baseball and the Minor League Baseball Promotional Seminar. There were several major accomplishments during the 1998 Joe DiMaggio, who debuted as shortstop with the season, including the realignment of Triple-A baseball from three 1932 San Francisco Seals, had a career average leagues into two, and establishing the Triple-A , of .398 in the Minor Leagues. (Pacific Coast which was played in Las Vegas (1998-2000). Since 2006, the League) Triple-A champion has been determined by the winner of a game between the and champions, hosted by a Triple-A club. Another subsidiary, Professional Baseball Umpire Corp. (PBUC), was formed in 1998 to operate and maintain the umpire program for the 16 domestic leagues, under terms of the historic 10-year Professional Baseball Agreement that was negotiated with Major League Baseball. Minor League Baseball has been a continuing success story at the box office. The 2008 regular season attendance total of 43,263,740 established a new all-time record. Total regular season attendance has increased in 28 of the last 36 seasons and has surpassed 33-million fans for 24 straight years, a level not attained since the late 1940s when membership consisted of more than 50 leagues and more than 400 teams. In 2017, the 15 leagues with a total of 176 teams that charged admission attracted 41,832,364 fans. After serving 15 years as Chief Operating Officer, Pat O'Conner took over as Minor League Baseball's 11th President in January 2008. O'Conner was re-elected to a second term in December 2011 and a third term in December 2015. Highlights of O'Conner's first term in office include the extension of the Professional Baseball Agreement with Major League Baseball through the 2020 season; a five-year collective bargaining agreement with the Association of Minor League Umpires (AMLU) through 2016; realignment of four leagues; the organization-wide bundling of Internet rights; a first-ever diversity initiative; an industry-wide health care program; a "Green Team" initiative to make Minor League Baseball teams and stadiums more eco-friendly and cost effective; and the location of new office space comprised of four buildings, totaling 18,000 square feet, on 16th Street North in St. Petersburg, Florida. In the first year of his third term (2016), O'Conner oversaw the use of 15-second pitch clocks in the which led to a six-minute improvement in the time of FSL games. O'Conner also led the realignment of the Advanced Class-A California and Carolina Leagues following the 2016 season. In his second term, Willie Mays first played Minor League ball in O'Conner and Minor League Baseball launched Minor League Trenton, N.J., and then Minneapolis before Baseball Enterprises and Project Brand in 2013. The primary getting called up by the Giants in 1951. objective of Project Brand is to create national sponsorship (International League) revenues by monetizing the collective branding power of 160 Minor League Baseball franchises. Prior to the 2015 season, PBUC was re-named MiLB Umpire Development and The Umpire School was rebranded as the Minor League Baseball Umpire Training Academy. Also in 2015, Minor League Baseball began the use of 20 second pitch clocks to speed up the pace of play at the Triple-A and -A levels. The result was a 13-minute improvement in the time of game at those levels.

* * * National Association Presidents 1901-present Patrick T. Powers, 1901-1909 Michael H. Sexton, 1909-1933 William G. Bramham, 1933-1946 George M. Trautman, 1946-1963 Phillip Piton, 1964-1972 Henry J. Peters, 1972-1976 Robert R. Bragan, 1976-1979 John H. Johnson, 1979-1988 Sal B. Artiaga, 1988-1991 Mike Moore, 1992-2007 Pat O'Conner, 2008-

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'47 The Minor League Baseball Hometown Collection celebrates the rich, colorful Antigua heritage of Minor League Baseball and the special place that the Minor Ebbets Field Leagues occupy in our national culture. Embracing franchises both iconic and Flannels obscure, Hometown Collection products span the globe from Havana to New Era Hawaii, from Vancouver to Charleston, as well as dozens of points in between, OT Sports from the days of flannel uniforms to the present time. Retro Brand Learn more about these historic teams here. Cap Type

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'47 The Minor League Baseball Hometown Collection celebrates the rich, colorful Antigua heritage of Minor League Baseball and the special place that the Minor Ebbets Field Leagues occupy in our national culture. Embracing franchises both iconic and Flannels obscure, Hometown Collection products span the globe from Havana to New Era Hawaii, from Vancouver to Charleston, as well as dozens of points in between, OT Sports from the days of flannel uniforms to the present time. Retro Brand Learn more about these historic teams here. Cap Type

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This is to certify that a copy of the foregoing Declaration of Robert Fountain was served by email on December 24, 2020 upon attorney of record for Opposer:

Frank J. Bonini, Jr. Attorney for Opposer, Portland Mavericks Baseball Club, Inc. Bonini IP Law LLC 150 N Radnor Chester Rd. Suite F200 Radnor, PA 19087 [email protected]

Date: December 24, 2020

Name: H. David Starr

Signed: _/H. David Starr/_