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. 88460896 TRUSTED DIGITAL IDENTITY(Standard Characters, see http://uspto.report/TM/88460896/mark.png) has been amended as follows:

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

Applicant responds to the Office Action that issued on September 3, 2019 which refused registration on the ground that the mark is merely descriptive. Further, the Office Action included a notice as to the prior-pending application of the mark TRUSTED IDENTITY PLATFORM. Applicant disagrees that the mark is merely descriptive and that there is a likelihood of confusion as to the prior-pending mark for the following reasons. Applicant?s Mark is Suggestive The Office Action asserts that TRUSTED DIGITAL IDENTITY is used descriptively in connection with Applicant?s downloadable software and design, development and consulting services. As evidence to support that Applicant?s mark is descriptive, the Office Action states that the word ?trust? means ?a computer system that is secure?. This definition was obtained from a website called ComputerLanguage.com which is described as an online tech encyclopedia. The encyclopedia appears to have been authored by a husband and wife team ?because a computer dictionary could not be found?. See Exhibit A. Given that neither appears to be an authority on computer terms or experts in the field of computer technology, without more, this evidence has limited probative value, if any. Moreover, the Merriam-Webster Dictionary, a known resource defines the word ?trust? as ?to rely on the truthfulness or accuracy or to hope or expect confidently or to commit or place in one?s care or keeping.? See Exhibit B. None of the definitions stated allude to computers or computer systems. Thus, the evidence provided in the Office Action is insufficient to meet the Office?s burden of establishing that the mark is merely descriptive, which it is required to do with substantive evidence. See In re Bayer Aktiengesellshaft, 488 F.3d 960, 963-64, U.S.P.Q.2d 1828, 1831 (Fed. Cir. 2007) (the Examining Attorney must support her conclusion with appropriate evidence and has the burden of establishing that a term is merely descriptive) and TMEP ? 1209.02. Further, with so many meanings attributed to the word ?trust?, the word TRUSTED in Applicant?s mark is therefore suggestive. A vague word with alternative meanings for consumers to ponder can hardly be considered descriptive, since it does not convey an immediate idea of the characterization of the goods. Blisscraft of Hollywood v. United Plastics Co., 131 U.S.P.Q. 55, 60 (2d Cir. 1961) (POLY PITCHER held suggestive for polyethylene pitcher because it is also suggestive of Molly Pitcher, a well-known historical figure). Here, as it relates to Applicant?s mark, TRUSTED DIGITAL IDENTITY could mean a confidential name or number used on the internet or it could mean one is verified to use a certain platform or it could mean that one?s identity cannot be revealed when operating on the internet. The point is, it would take a number of mental leaps to identify what Applicant?s goods/services are in relation to the mark. Not only is the term TRUSTED vague, but it is also highly subjective. Trust is a concept that varies widely in different contexts and as perceived by different people. Some people may be reluctant to trust others due to past experience. Sources of information may be inherently untrustworthy to some but relied upon by others. Ultimately, the concept of trust is so amorphous that cannot immediately describe the nature of a service and must be considered suggestive. Moreover, the suggestiveness of the word TRUSTED is supported by the fact that the USPTO?s records evidence that there are numerous TRUSTED formative marks on the Register whereby TRUSTED was not deemed merely descriptive in connection with computer-related goods/services not unlike those of the Applicant including. In fact, for many of the references listed below, TRUSTED is the only word not disclaimed in the mark. Mark/Name Full Goods/Services Owner Information Status/Status Date TRUSTED IDENTITIES SECURE TRANSACTIONS SN: 86507493 Disclaimer: SECURE TRANSACTIONS (Int'l Class: 37) Technical support services, namely, technical consultation, advice and troubleshooting in installation of equipment for the production and issuance of financial cards, identity cards, smart cards, loyalty cards, transportation cards, secure credentials and passports; on- and off-site repair and maintenance of equipment for production and issuance of financial cards, identity cards, smart cards, loyalty cards, transportation cards, secure credentials and passports (Int'l Class: 41) Training services in the field of information security; training services in the field of production and issuance of financial cards, identity cards, smart cards, loyalty cards, transportation cards, secure credentials and passports; providing a website featuring non-downloadable videos in the fields of information security, cybersecurity, and production and issuance of financial cards, identity cards, smart cards, loyalty cards, transportation cards, secure credentials and passports (Int'l Class: 42) Hardware and software installation and support; technical support services, namely, troubleshooting in the nature of diagnosing computer hardware and software problems; providing on-line non-downloadable software for public key infrastructure (PKI) and certificate management enabling the use of digital signatures; providing on-line non- downloadable software for searching and management of digital certificates from multiple digital certificate authorities and providing information to track their location, expiration, purpose or status, digital receipts, certificate validation, encryption and permissions management services; computer software installation, integration and deployment services in the field of information security; computer security consultation; implementation of software for public key infrastructure verification and authentication; Technical support services, namely, technical consultation, advice and troubleshooting in planning, migration and implementation of software and equipment for the production and issuance of financial cards, identity cards, smart cards, loyalty cards, transportation cards, secure credentials and passports; computer hardware and software installation and technical support services, namely, troubleshooting of computer software problems (Int'l Class: 45) Consulting services in the field of Internet and information security; Internet security services, namely, authentication and validation of public key infrastructure certificates; digital certificate issuance and verification; authentication service in the nature of authentication of digital identities; authorization services in the nature of authorizing users of and applications to network resources Entrust Datacard Corporation (Delaware Corp.) 1187 Park Place Shakopee Minnesota 55379 Allowed - Intent to Use Statement of Use - Registration Review Complete September 24, 2019 TRUSTED IDENTITY PLATFORM SN: 87766917 Disclaimer: IDENTITY PLATFORM (Int'l Class: 42) Providing a website featuring computer security services information relating to the issuance of identity credentials, storage of identity information, identity protection, verification and transmission using biometric authentication and/or multi-factor authentication and blockchain technology; Platform as a service (PAAS) featuring computer software platforms for enabling user provisioning and deprovisioning and managing access to identity credentials, identity information, identity documentation and verification of same and sensitive and/or confidential information, and transmission of identity information and sensitive and/or confidential information; providing a website featuring technology that enables users to have the ability to have an authenticated identity and identity credentials and documentation, and sensitive and/or confidential information and providing access thereto and/or transmission thereof using biometric authentication and/or multi-factor authentication and blockchain technology Black Gold Coin, Inc. (Wyoming Corp.) Suite 100 7495 Azure Drive Las Vegas Nevada 89408 Allowed - Intent to Use Notice of Allowance Issued April 9, 2019 PATIENT'S DIGITAL TRUSTED SPACE SN: 87274575 Disclaimer: PATIENT?S DIGITAL (Int'l Class: 42) providing a temporary use of a web-based software application for electronically ordering medical and pharmaceutical prescriptions over a global computer network; providing temporary use of on-line downloadable or non-downloadable software and applications for allowing patients to view and store medical images along with structured reports that accompany each image Nextgen Management, LLC (Delaware Limited Liability Company) Suite 203 5355 Town Center Road Boca Raton Florida 33486 Allowed - Intent to Use 4th Extension of Time Granted July 25, 2019 AGILENT TRUSTED ANSWERS SN: 87839517 (Int'l Class: 42) Cloud computing featuring software for use in controlling and managing information and for management, analysis, interpretation, visualization, and providing diagnostic support, with import functions from data acquisition systems, and export functions towards other apparatus and software; software as a service (saas) services featuring software for management, analysis, interpretation, visualization, and sharing of business intelligence and providing diagnostic support, with import functions from data acquisition systems, and export functions towards other apparatus and software; computer network and software design for the management, analysis, interpretation, visualization, and sharing of clinical information; development, updating and maintenance of software and database systems; installation and maintenance of computer software; research, development, design and upgrading of computer software; rental of computer software; providing quality assurance services in the field of analytical laboratories; testing, analysis, and evaluation of analytical laboratories to assure compliance with industry standards; remote monitoring of the functioning and use of electrical laboratory instruments and associated computer systems for analytical laboratories; computer project management services in the fields of scientific research, quality control, regulatory compliance, testing and laboratory productivity services; custom design and development of software for use by analytical laboratories; providing data analytics information about the operation and application of analytical instruments in chemical, computer and scientific analytical laboratories; computer programming for others; diagnostic services in the fields of biological and chemical analysis equipment, computer software, and medical equipment, and providing information and consultation in conjunction therewith; installation of computer software Agilent Technologies, Inc. (Delaware Corp.) 5301 Stevens Creek Blvd. Santa Clara California 95051 Allowed - Intent to Use Statement of Use - Non-Final Refusal Mailed August 29, 2019 DARK CYBER TRUSTED CROSS-DOMAIN and Design RN: 4453918 SN: 85891359 Disclaimer: CYBER and CROSS-DOMAIN (Int'l Class: 42) computer security consultancy; computer security service, namely, restricting access to and by computer networks to and of undesired web sites, media and individuals and facilities; design and development of electronic data security systems; inserting software protection programs and security programs onto magnetic media; maintenance of computer software relating to computer security and prevention of computer risks; updating of computer software relating to computer security and prevention of computer risks; computer and technological professional services, namely, cross domain security for federal and commercial market; computer services, namely, integration of private and public cloud computing environments; providing virtual computer systems and virtual computer environments through cloud computing; developing customized software in the field of database management and data security for others; software as a service (saas) services featuring software for database management, sending and encrypting data and data security Mark Gargulinski (United States Citizen) 21405 Goshen Park Ct. Gaithersburg Maryland 20882 Registered December 24, 2013 SHAPESHIFTING TRUSTED NETWORKS SN: 88394545 (Int'l Class: 42) Development of software for secure network operations Grid7 LLC, Dba Taekion (Colorado Limited Liability Company) 1434 Spruce Street, Suite 100 Boulder Colorado 80302 Pending - Non-Final Action Mailed July 2, 2019 THE TRUSTED LENDING PLATFORM RN: 4393837 SN: 85712035 Disclaimer: LENDING PLATFORM (Int'l Class: 42) computer services for the mortgage lending industry, namely, designing, implementing, and hosting private label websites and mortgage application, origination, processing, and closing systems for lenders; providing technical support services, namely, maintenance, configuration, and troubleshooting of private label websites and mortgage application, origination, processing, and closing systems for lenders D+H Usa Corporation (Oregon Corp.) 605 Crescent Executive Court, Suite 600 Attn: Legal Dept. Lake Mary Florida 32746 Registered August 27, 2013 TRUSTED ADVERTISING SN: 88287165 (Int'l Class: 42) Electronic monitoring identifying information for security and privacy purposes in the nature of monitoring and replacing personally identifying information with randomized identity tracking for commercial entities Anonos Inc. (Delaware Corp.) Po Box 803338 #96049 Chicago Illinois 606803338 Pending - Non-Final Action Mailed April 25, 2019 TRUSTED ENTERPRISE RN: 4365261 SN: 85391052 Disclaimer: ENTERPRISE (Int'l Class: 42) information technology consulting in the field of cyber security solutions Digital Management, LLC (Delaware Limited Liability Company) 6550 Rock Spring Dr. 7th Floor Bethesda Maryland 20817 Registered July 9, 2013 TRUSTED GATEWAY SYSTEM RN: 5055033 SN: 86249172 Disclaimer: GATEWAY SYSTEM (Int'l Class: 09) computer network security software; computer software that enables safe, secure and simultaneous data movement within and between computer networks Forcepoint LLC (Delaware Limited Liability Company) 10900-A Stonelake Blvd., Quarry Oaks 1, Ste. 350 Austin Texas 78759 Registered October 4, 2016 TRUSTED INTERNET RN: 5817669 SN: 88006105 Disclaimer: INTERNET (Int'l Class: 42) Managed cyber security service, namely, providing a secure electronic online system featuring technology that offers monitored personal protected virtual private secure networks for companies, and manages security for cloud seeding and computer co-location services, namely, providing facilities for the location of computer servers with the equipment of others Trusted Internet LLC (New Hampshire Limited Liability Company) 20 Cameron Lane Wilton New Hampshire 03086 Registered July 30, 2019 The corresponding TESS records for the above marks are attached as Exhibit C. Finally, Applicant urges the Examining Attorney to follow the long-established policy of the Patent and Trademark Office to resolve any doubt as to whether a mark is merely descriptive in favor of the applicant. See In re Motion- Norwich Product, Inc., 209 U.S.P.Q. 791 (T.T.A.B. 1981) (COLOR CARE held not merely descriptive of color safe laundry bleach); In re Shutts, 217 U.S.P.Q. 363 (T.T.A.B. 1983) (SNO-RAKE is not merely descriptive of a snow removal hand tool). There is no Confusion with TRUSTED IDENTITY PLATFORM A. The Marks are Distinguishable In evaluating confusion, the marks are not to be dissected but rather to be compared in their entireties. See In re National Data Corp., 224 U.S.P.Q. 749, 750 (Fed. Cir. 1985); Opryland USA Inc. v. Great American Music Show, Inc., 23 U.S.P.Q.2d 1471, 1473 (Fed. Cir. 1992). With that in mind, Applicant notes that the marks differ significantly as depicted and further explained below: Cited Mark Applicant?s Mark TRUSTED IDENTITY PLATFORM TRUSTED DIGITAL IDENTITY While the marks share two words, those words are ordered differently. Further, the respective marks incorporate a third word, albeit descriptive, is different in each mark. As such, the marks a visually and phonetically dissimilar. Further, a consumer viewing Applicant?s mark and the prior-pending mark in public will immediately notice these differences. Moreover, the connotations of the respective marks differ. Applicant?s mark is TRUSTED DIGITAL IDENTITY while the prior-pending mark is TRUSTED IDENTITY PLATFORM. The word ?identity? in Applicant?s mark speaks to an individual or a characteristic of a person such that the whole mark seems to connote that the goods/services are geared towards an individual. By contrast, the word ?platform? in the prior-pending mark seems to connote system and has no connotation that relates to a person of individual. Marks that have different connotations, such as here, are often held not confusingly similar, even when applied to the same types of goods. See, e.g., Safeway Stores Inc. v. The Bell Canto Fancy Foods Ltd., 5 U.S.P.Q.2d 1980, 1982 (T.T.A.B. 1987) (finding no likelihood of confusion between BEL ARIA for food products and BEL-AIR for frozen food products); see also Viacom International Inc. v. Komm, 46 U.S.P.Q.2d 1233 (T.T.A.B. 1998)(finding MY-T-MOUSE for software not confusingly similar with MIGHTY MOUSE cartoon character for a variety of products). Therefore, Applicant?s Mark and the prior-pending application have different connotations such that consumers are unlikely to conclude that the goods/services originate from the same source. Moreover, the overlapping term ?TRUSTED? is highly diluted in the field, as evidenced by the coexisting TRUSTED-formative marks shown in the chart above. See In re Broadway Chicken, Inc., 38 USPQ2d 1559, 1565-66 (TTAB 1996) (?Evidence of widespread third party use, in a particular field, of marks containing a certain shared term is competent to suggest that purchasers have been conditioned to look to the other elements of the marks as a means of distinguishing the source of goods or services in the field.?). The recurrence of a word in third-party registrations indicates that ?there is an inherent weakness in a mark comprised in whole or in part of the word in question and that, therefore, the question of likelihood of confusion is colored by that weakness to the extent that only slight differences in the marks may be sufficient to distinguish one from the other.? In re Melville Corp., 18 U.S.P.Q. 2d 1386, 1388 (T.T.A.B. 1991). Therefore, marks containing words commonly occurring in third-party registrations are entitled to only a narrow scope of protection. TMEP ? 1207.01(d)(iii). B. Applicant?s Consumers are Sophisticated Professionals Applicant specializes in biometric authentication. See Exhibit D. Applicant provides its goods and services to professionals in many different fields including the financial sector, healthcare and government. Applicant?s professional customers and clients will undoubtedly know the source of its goods/services as it typically involves extensive interactions and dealings in order for the goods/services to be satisfactorily rendered. See In re Soletanche Freyssinet, App. No. 79194724 (T.T.A.B., July 16, 2019) (not precedential) (sophisticated purchasers ?either know their specific product needs, or obtain them through consultation with Applicant, and in either instance they would be expected to exercise significant care in their selection.?). Similarly, the consumers of the owner of the prior-pending application must be sophisticated and savvy in order purchase. Where a parties? goods or services are used by professionals, it is less likely that confusion would occur. See Hewlett-Packard Company v. Human Performance Measurement, Inc., 23 U.S.P.Q.2d 1390, 1396 (T.T.A.B. 1992). The C.A.F.C. has cautioned the P.T.O. not to overlook the great importance of consumer sophistication in deciding whether confusion is likely. In Electronic Design & Sales Inc. v. Electronic Data Systems Corp., 21 U.S.P.Q.2d 1388 (Fed. Cir. 1992), the C.A.F.C. there held that confusion was unlikely between E.D.S. for computer services and EDS for power supplies and battery chargers because the buyers were sophisticated commercial purchasers, as here. The C.A.F.C. strongly stressed that the sophistication of discriminating customers is an extremely important likelihood of confusion factor, even in cases where the marks are identical. Indeed, the C.A.F.C. reversed the Board?s finding of likely confusion because the Board ?apparently failed to consider, and certainly failed to address, the sophistication of buyers.? 21 U.S.P.Q.2d at 1392. In sum, to find a likelihood of confusion in this instance would require impermissible speculation given the differences between the marks and the sophistication of the relevant professional consumers. With the above, Applicant respectfully requests that the Examining Attorney withdraw the refusals and approve the instant application for publication. Information Requirement Applicant answers the following questions as follows: 1. Are applicant?s goods used for secure digital identification? Applicant?s goods are biometric authentication. 2. Are applicant?s software development tools used for secure digital identification? Applicant?s software development tools are used for biometric authentication. 3. Are applicant?s software design, development and consultation services in the field of or related to secure digital identification? Applicant?s software design, development and consultation services are in the field of biometric authentication. 4. Do applicant?s competitors use ?trusted? and/or ?digital identity? to advertise similar goods and/or similar goods/ and/or services? Applicant is not aware of how its competitors use ?digital identity?. To Applicant?s knowledge and as set forth herein, the word ?trusted? is vague and suggestive and not a term of art in the industry. For further information, please see Applicant?s website at http://www.veridiumid.com.

EVIDENCE
Evidence in the nature of Response in PDF format and exhibits. has been attached.
Original PDF file:
evi_47198018-20191023180152391246_._02336347.PDF
Converted PDF file(s) ( 11 pages)
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evi_47198018-20191023180152391246_._02336304.PDF
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CLASSIFICATION AND LISTING OF GOODS/SERVICES

Applicant proposes to amend the following class of goods/services in the application:
Current: Class 009 for Downloadable computer software and downloadable mobile applications for storing biometric data, converting biometric data into passwords and login codes, for authentication and identification of persons using biometric information and recognition, for authentication or identification purposes by means of storage of biometric features, for security and access control to websites; downloadable computer software and downloadable mobile applications for storing biometric data, converting biometric data into passwords and login codes, for authentication and identification of persons using biometric information and recognition, for authentication or identification purposes by means of storage of biometric features, for security and access control to websites; downloadable computer software development tools; downloadable mobile application software development kits, namely, computer software development tools
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: Downloadable computer software and downloadable mobile applications for storing biometric data, converting biometric data into passwords and login codes, for authentication and identification of persons using biometric information and recognition, for authentication or identification purposes by means of storage of biometric features, for security and access control to websites; downloadable computer software and downloadable mobile applications for storing biometric data, converting biometric data into passwords and login codes, for authentication and identification of persons using biometric information and recognition, for authentication or identification purposes by means of storage of biometric features, for security and access control to websites; downloadable computer software development tools; downloadable mobile application software development kits, namely, computer software development toolsClass 009 for Downloadable computer software and downloadable mobile applications for storing biometric data, converting biometric data into passwords and login codes, for authentication and identification of persons using biometric information and recognition, for authentication or identification purposes by means of storage of biometric features, for security and access control to websites; downloadable computer software development tools; downloadable mobile application software development kits, namely, computer software development tools
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's current attorney information: Deirdre A. Clarke. Deirdre A. Clarke of LEASON ELLIS LLP, is located at

      ONE BARKER AVENUE, 5TH FLOOR
      WHITE PLAINS, New York 10601
      US
The docket/reference number is 10141/.

The phone number is 914-821-3084.

The fax number is 914 288-0023.

The email address is tmdocket@leasonellis.com

The applicants proposed attorney information: Deirdre A. Clarke. Other appointed attorneys are Attorneys of Leason Ellis LLP. Deirdre A. Clarke of LEASON ELLIS 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

      ONE BARKER AVENUE, 5TH FLOOR
      WHITE PLAINS, New York 10601
      United States
The docket/reference number is 10141/313293.

The phone number is 914-821-3084.

The fax number is 914 288-0023.

The email address is tmdocket@leasonellis.com

Deirdre A. Clarke 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: DEIRDRE A. CLARKE. DEIRDRE A. CLARKE of LEASON ELLIS LLP, is located at

      ONE BARKER AVENUE, 5TH FLOOR
      WHITE PLAINS, New York 10601
      US
The docket/reference number is 10141/.

The phone number is 914-821-3084.

The fax number is 914 288-0023.

The email address is tmdocket@leasonellis.com

The applicants proposed correspondence information: Deirdre A. Clarke. Deirdre A. Clarke of LEASON ELLIS LLP, is located at

      ONE BARKER AVENUE, 5TH FLOOR
      WHITE PLAINS, New York 10601
      United States
The docket/reference number is 10141/313293.

The phone number is 914-821-3084.

The fax number is 914 288-0023.

The email address is tmdocket@leasonellis.com

SIGNATURE(S)
Response Signature
Signature: /Deirdre Clarke/     Date: 10/23/2019
Signatory's Name: Deirdre A. Clarke
Signatory's Position: Attorney - New York Bar member

Signatory's Phone Number: 914-821-3084

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:    DEIRDRE A. CLARKE
   LEASON ELLIS LLP
   
   ONE BARKER AVENUE, 5TH FLOOR
   WHITE PLAINS, New York 10601
Mailing Address:    Deirdre A. Clarke
   LEASON ELLIS LLP
   ONE BARKER AVENUE, 5TH FLOOR
   WHITE PLAINS, New York 10601
        
Serial Number: 88460896
Internet Transmission Date: Wed Oct 23 18:11:10 EDT 2019
TEAS Stamp: USPTO/ROA-XX.XX.XX.XX-201910231811104716
13-88460896-610b0eae3785dbda85a176b2ea35
03876522bafb68f36c4bf65e5d7e32e15dd-N/A-
N/A-20191023180152391246