Response to Office Action

Under the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless it displays a valid OMB control number. PTO Form 1957 (Rev 10/2011)

OMB No. 0651-0050 (Exp 09/20/2020)

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Under the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless it displays a valid OMB control number. PTO Form 1957 (Rev 10/2011)

OMB No. 0651-0050 (Exp 09/20/2020)

Response to Office Action

To the Commissioner for Trademarks:

Application serial no. 88251626 CONQUER(Standard Characters, see http://uspto.report/TM/88251626/mark.png) has been amended as follows:

ARGUMENT(S)
In response to the substantive refusal(s), please note the following:

Applicant's arguments in response to the Office Action issued on March 14, 2019 are attached hereto.

EVIDENCE
Evidence in the nature of Applicant's arguments in response to the Office Action and Exhibits A - B has been attached.
Original PDF file:
evi_66195542-20190828103921995437_._CONQUER_ROA.pdf
Converted PDF file(s) ( 2 pages)
Evidence-1
Evidence-2
Original PDF file:
evi_66195542-20190828103921995437_._Exhibit_A.pdf
Converted PDF file(s) ( 3 pages)
Evidence-1
Evidence-2
Evidence-3
Original PDF file:
evi_66195542-20190828103921995437_._Exhibit_B.pdf
Converted PDF file(s) ( 3 pages)
Evidence-1
Evidence-2
Evidence-3

CLASSIFICATION AND LISTING OF GOODS/SERVICES

Applicant proposes to amend the following class of goods/services in the application:
Current: Class 035 for Retail store services featuring a variety of goods, namely, sporting goods, sport team and league merchandise, gaming merchandise, souvenirs, mugs, glassware, gift items, clothing, clothing accessories, books and magazines, food and beverages
Original Filing Basis:
Filing Basis: Section 1(b), Intent to Use: For a trademark or service mark application: As of the application filing date, the applicant had a bona fide intention, and was entitled, to use the mark in commerce on or in connection with the identified goods/services in the application. For a collective trademark, collective service mark, or collective membership mark application: As of the application filing date, the applicant had a bona fide intention, and was entitled, to exercise legitimate control over the use of the mark in commerce by members on or in connection with the identified goods/services/collective membership organization. For a certification mark application: As of the application filing date, the applicant had a bona fide intention, and was entitled, to exercise legitimate control over the use of the mark in commerce by authorized users in connection with the identified goods/services, and the applicant will not engage in the production or marketing of the goods/services to which the mark is applied, except to advertise or promote recognition of the certification program or of the goods/services that meet the certification standards of the applicant.

Proposed:
Tracked Text Description: Retail store services featuring a variety of goods, namely, sporting goods, sport team and league merchandise, gaming merchandise, souvenirs, mugs, glassware, gift items, clothing, clothing accessories, books and magazines, food and beverages; Retail store services featuring a variety of goods, namely, gaming merchandise, souvenirs, mugs, glassware, gift items, books and magazines, food and beveragesClass 035 for Retail store services featuring a variety of goods, namely, gaming merchandise, souvenirs, mugs, glassware, gift items, books and magazines, food and beverages
Filing Basis: Section 1(b), Intent to Use: For a trademark or service mark application: As of the application filing date, the applicant had a bona fide intention, and was entitled, to use the mark in commerce on or in connection with the identified goods/services in the application. For a collective trademark, collective service mark, or collective membership mark application: As of the application filing date, the applicant had a bona fide intention, and was entitled, to exercise legitimate control over the use of the mark in commerce by members on or in connection with the identified goods/services/collective membership organization. For a certification mark application: As of the application filing date, the applicant had a bona fide intention, and was entitled, to exercise legitimate control over the use of the mark in commerce by authorized users in connection with the identified goods/services, and the applicant will not engage in the production or marketing of the goods/services to which the mark is applied, except to advertise or promote recognition of the certification program or of the goods/services that meet the certification standards of the applicant.

The applicant hereby appoints Jeffrey P. Dunning. Other appointed attorneys are Mark R. Galis, Herbert H. Finn, Richard D. Harris, Gary R. Jarosik, Keith R. Jarosik, James J. Lukas, Jr., Eric J. Maiers, Jeffrey G. Mote, Cameron M. Nelson, Howard E. Silverman, Barry Horwitz, Matthew J. Levinstein, Marc Trachtenberg, Benjamin R. Gilford, Jonathan E. Giroux, Dennis P. Malloy, Jacqueline V. Brousseau, Callie Sand, Michael R. Friedman, Sara Skulman, Chase Means. Jeffrey P. Dunning of Greenberg Traurig, LLP, is a member of the XX bar, admitted to the bar in XXXX, bar membership no. XXX, and the attorney(s) is located at

      Suite 3100
      77 W. Wacker Drive
      Chicago, Illinois 60601
      United States
to submit this Response to Office Action Form on behalf of the applicant.
The docket/reference number is 113932.01730.

The phone number is 312.456.8400.

The fax number is 312.456.8435.

The email address is chiipmail@gtlaw.com

Jeffrey P. Dunning submitted the following statement: The attorney of record is an active member in good standing of the bar of the highest court of a U.S. state, the District of Columbia, or any U.S. Commonwealth or territory.
The applicant's current correspondence information: JANE TYLER MANERS. JANE TYLER MANERS of CAESARS ENTERTAINMENT, is located at

      5865 RIDGEWAY CENTER DRIVE, SUITE 300
      MEMPHIS, Tennessee 38120
      US

The phone number is 901-820-4550.

The email address is trademark@caesars.com; jtyler@caesars.com; epotter@caesars.com

The applicants proposed correspondence information: Jeffrey P. Dunning. Jeffrey P. Dunning of Greenberg Traurig, LLP, is located at

      Suite 3100
      77 W. Wacker Drive
      Chicago, Illinois 60601
      United States
The docket/reference number is 113932.01730.

The phone number is 312.456.8400.

The fax number is 312.456.8435.

The email address is chiipmail@gtlaw.com

SIGNATURE(S)
Response Signature
Signature: /Jeffrey P. Dunning/     Date: 08/28/2019
Signatory's Name: Jeffrey P. Dunning
Signatory's Position: Attorney of record, Illinois bar member

Signatory's Phone Number: 312.456.8400

The signatory has confirmed that he/she is a U.S.-licensed attorney who is an active member in good standing of the bar of the highest court of a U.S. state (including the District of Columbia and any U.S. Commonwealth or territory); and he/she is currently the owner's/holder's attorney or an associate thereof; and to the best of his/her knowledge, if prior to his/her appointment another U.S.-licensed attorney not currently associated with his/her company/firm previously represented the owner/holder in this matter: the owner/holder has revoked their power of attorney by a signed revocation or substitute power of attorney with the USPTO; the USPTO has granted that attorney's withdrawal request; the owner/holder has filed a power of attorney appointing him/her in this matter; or the owner's/holder's appointed U.S.-licensed attorney has filed a power of attorney appointing him/her as an associate attorney in this matter.

Mailing Address:    JANE TYLER MANERS
   CAESARS ENTERTAINMENT
   
   5865 RIDGEWAY CENTER DRIVE, SUITE 300
   MEMPHIS, Tennessee 38120
Mailing Address:    Jeffrey P. Dunning
   Greenberg Traurig, LLP
   Suite 3100
   77 W. Wacker Drive
   Chicago, Illinois 60601
        
Serial Number: 88251626
Internet Transmission Date: Wed Aug 28 13:04:17 EDT 2019
TEAS Stamp: USPTO/ROA-XX.XXX.XX.X-201908281304178448
16-88251626-610114958db5fd47741136720d38
8eab761579ad78e27509fd59e256799c1406dae-
N/A-N/A-20190828130203633186