United States Patent and Trademark Office (USPTO)
Office Action (Official Letter) About Applicant’s Trademark Application
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U.S. Application Serial No. 88573683
Mark: FSP
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Correspondence Address: 1000 LOUISIANA STREET, SUITE 1700
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Applicant: Trinity Bay Equipment Holdings, LLC
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Reference/Docket No. 166301-01010
Correspondence Email Address: |
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The USPTO must receive applicant’s response to this letter within six months of the issue date below or the application will be abandoned. Respond using the Trademark Electronic Application System (TEAS). A link to the appropriate TEAS response form appears at the end of this Office action.
PARTIAL SECTION 2(d) REFUSAL – LIKELIHOOD OF CONFUSION WITH REGARD
TO SPECIFIED GOODS
THIS PARTIAL REFUSAL APPLIES ONLY TO THE GOODS SPECIFIED THEREIN
Applicant has applied to register FSP in standard characters for:
Trademark Act Section 2(d) bars registration of an applied-for mark that is so similar to a registered mark that it is likely consumers would be confused, mistaken, or deceived as to the commercial source of the goods and/or services of the parties. See 15 U.S.C. §1052(d). Likelihood of confusion is determined on a case-by-case basis by applying the factors set forth in In re E. I. du Pont de Nemours & Co., 476 F.2d 1357, 1361, 177 USPQ 563, 567 (C.C.P.A. 1973) (called the “du Pont factors”). In re i.am.symbolic, llc, 866 F.3d 1315, 1322, 123 USPQ2d 1744, 1747 (Fed. Cir. 2017). Only those factors that are “relevant and of record” need be considered. M2 Software, Inc. v. M2 Commc’ns, Inc., 450 F.3d 1378, 1382, 78 USPQ2d 1944, 1947 (Fed. Cir. 2006) (citing Shen Mfg. Co. v. Ritz Hotel Ltd., 393 F.3d 1238, 1241, 73 USPQ2d 1350, 1353 (Fed. Cir. 2004)); see In re Inn at St. John’s, LLC, 126 USPQ2d 1742, 1744 (TTAB 2018).
Although not all du Pont factors may be relevant, there are generally two key considerations in any likelihood of confusion analysis: (1) the similarities between the compared marks and (2) the relatedness of the compared goods and/or services. See In re i.am.symbolic, llc, 866 F.3d at 1322, 123 USPQ2d at 1747 (quoting Herbko Int’l, Inc. v. Kappa Books, Inc., 308 F.3d 1156, 1164-65, 64 USPQ2d 1375, 1380 (Fed. Cir. 2002)); Federated Foods, Inc. v. Fort Howard Paper Co.,544 F.2d 1098, 1103, 192 USPQ 24, 29 (C.C.P.A. 1976) (“The fundamental inquiry mandated by [Section] 2(d) goes to the cumulative effect of differences in the essential characteristics of the goods [or services] and differences in the marks.”); TMEP §1207.01.
Similarity of the Marks
The applicant has applied for the mark FSP. The cited marks are FSP, owned by FSP Holdings Pty. Ltd., and FSP-ONE, owned by FSP-One.
Marks are compared in their entireties for similarities in appearance, sound, connotation, and commercial impression. Stone Lion Capital Partners, LP v. Lion Capital LLP, 746 F.3d 1317, 1321, 110 USPQ2d 1157, 1160 (Fed. Cir. 2014) (quoting Palm Bay Imps., Inc. v. Veuve Clicquot Ponsardin Maison Fondee En 1772, 396 F.3d 1369, 1371, 73 USPQ2d 1689, 1691 (Fed. Cir. 2005)); TMEP §1207.01(b)-(b)(v). “Similarity in any one of these elements may be sufficient to find the marks confusingly similar.” In re Inn at St. John’s, LLC, 126 USPQ2d 1742, 1746 (TTAB 2018) (citing In re Davia, 110 USPQ2d 1810, 1812 (TTAB 2014)); TMEP §1207.01(b).
When comparing marks, “[t]he proper test is not a side-by-side comparison of the marks, but instead whether the marks are sufficiently similar in terms of their commercial impression such that [consumers] who encounter the marks would be likely to assume a connection between the parties.” Cai v. Diamond Hong, Inc., __ F.3d __, 127 USPQ2d 1797, 1801 (Fed. Cir. 2018) (quoting Coach Servs., Inc. v. Triumph Learning LLC, 668 F.3d 1356, 1368, 101 USPQ2d 1713, 1721 (Fed. Cir. 2012)); TMEP §1207.01(b). The proper focus is on the recollection of the average purchaser, who retains a general rather than specific impression of trademarks. In re Inn at St. John’s, LLC, 126 USPQ2d 1742, 1746 (TTAB 2018) (citing In re St. Helena Hosp., 774 F.3d 747, 750-51, 113 USPQ2d 1082, 1085 (Fed. Cir. 2014); Geigy Chem. Corp. v. Atlas Chem. Indus., Inc., 438 F.2d 1005, 1007, 169 USPQ 39, 40 (CCPA 1971)); TMEP §1207.01(b).
Here, the applicant’s mark, FSP, is confusingly similar to the registrants’ marks, FSP and FSP-ONE. Specifically, the marks share the wording “FSP”.
Finally, the stylization and design elements present in the registered marks also do not sufficiently differentiate the marks. When evaluating a composite mark consisting of words and a design, the word portion is normally accorded greater weight because it is likely to make a greater impression upon purchasers, be remembered by them, and be used by them to refer to or request the goods and/or services. In re Aquitaine Wine USA, LLC, 126 USPQ2d 1181, 1184 (TTAB 2018) (citing In re Viterra Inc., 671 F.3d 1358, 1362, 101 USPQ2d 1905, 1908 (Fed. Cir. 2012)); TMEP §1207.01(c)(ii). Thus, although marks must be compared in their entireties, the word portion is often considered the dominant feature and is accorded greater weight in determining whether marks are confusingly similar, even where the word portion has been disclaimed. In re Viterra Inc., 671 F.3d at 1366-67, 101 USPQ2d at 1911 (citing Giant Food, Inc. v. Nation’s Foodservice, Inc., 710 F.2d 1565, 1570-71, 218 USPQ2d 390, 395 (Fed. Cir. 1983)).
Thus, because the marks share the wording “FSP”, and therefore look and sound similar, the marks are considered similar for likelihood of confusion purposes.
Relatedness of the Goods
The applicant’s goods at issue are “Flexible pipe and pipeline products, all of metal, namely, pipe, fittings, pipe clips, collars, connectors, couplings and joints; steel pipes and tubes; branching tubes of metal for pipelines, compressed air pipe fittings of metal; metal cable wire; non-electric cables of metal” and “flexible steel pipe; flexible pipe and pipeline products for use in the oil and gas industry for oil and gas exploration and production, transmission and drilling, namely, pipes comprised primarily or wholly of metal and metal fittings therefor; flexible pipes comprised primarily or wholly of metal for conveying natural gas, oil, water, carbon dioxide, mined ore, jet fuel, sewage, and fiber optic cables; pipe clips, collars, connectors, couplings and joints comprised primarily or wholly of metal; but not including hose, flexible pipe or pipeline products or other products used for oil or petroleum retail dispensing or fueling purposes” in Class 6.
In re U.S. Registration No. 4906756
The applicants goods at issue are “Flexible pipe and pipeline products, all of metal, namely, pipe, fittings, pipe clips, collars, connectors, couplings and joints; steel pipes and tubes; branching tubes of metal for pipelines, compressed air pipe fittings of metal” and “flexible steel pipe; flexible pipe and pipeline products for use in the oil and gas industry for oil and gas exploration and production, transmission and drilling, namely, pipes comprised primarily or wholly of metal and metal fittings therefor; flexible pipes comprised primarily or wholly of metal for conveying natural gas, oil, water, carbon dioxide, mined ore, jet fuel, sewage, and fiber optic cables; pipe clips, collars, connectors, couplings and joints comprised primarily or wholly of metal; but not including hose, flexible pipe or pipeline products or other products used for oil or petroleum retail dispensing or fueling purposes” in Class 6.
The registrant’s relevant goods are “pipes of metal” in Class 6.
In this case, the registration uses broad wording to describe “pipes of metal”, which presumably encompasses all goods of the type described, including applicant’s more narrow “Flexible pipe and pipeline products, all of metal, namely, pipe”, “steel pipes and tubes; branching tubes of metal for pipelines”, “flexible steel pipe; flexible pipe and pipeline products for use in the oil and gas industry for oil and gas exploration and production, transmission and drilling, namely, pipes comprised primarily or wholly of metal”, and “flexible pipes comprised primarily or wholly of metal for conveying natural gas, oil, water, carbon dioxide, mined ore, jet fuel, sewage, and fiber optic cables”. See, e.g., In re Solid State Design Inc., 125 USPQ2d 1409, 1412-15 (TTAB 2018); Sw. Mgmt., Inc. v. Ocinomled, Ltd., 115 USPQ2d 1007, 1025 (TTAB 2015). Thus, applicant’s and registrant’s goods are highly related. See, e.g., In re i.am.symbolic, llc, 127 USPQ2d 1627, 1629 (TTAB 2018) (citing Tuxedo Monopoly, Inc. v.Gen. Mills Fun Grp., Inc., 648 F.2d 1335, 1336, 209 USPQ 986, 988 (C.C.P.A. 1981); Inter IKEA Sys. B.V. v. Akea, LLC, 110 USPQ2d 1734, 1745 (TTAB 2014); Baseball Am. Inc. v. Powerplay Sports Ltd., 71 USPQ2d 1844, 1847 n.9 (TTAB 2004)).
• Grainger provides metal pipes as well as pipe fittings, collars, connectors , couplings, joints, and compressed air pipe fittings, all comprised of metal:
o http://www.grainger.com/product/4NXW6?gclid=EAIaIQobChMIxtnI_oPb5QIVD4zICh31bgN2EAQYAiABEgLIGPD_BwE&cm_mmc=PPC:+Google+PLA&ef_id=EAIaIQobChMIxtnI_oPb5QIVD4zICh31bgN2EAQYAiABEgLIGPD_BwE:G:s&s_kwcid=AL!2966!3!390126534856!!!g!540448928863!; http://www.grainger.com/product/30LX28?gclid=EAIaIQobChMInqa2pYPb5QIVEYzICh3Lig5TEAQYAiABEgK_0_D_BwE&cm_mmc=PPC:+Google+PLA&ef_id=EAIaIQobChMInqa2pYPb5QIVEYzICh3Lig5TEAQYAiABEgK_0_D_BwE:G:s&s_kwcid=AL!2966!3!390126534856!!!g!540448928863!; http://www.grainger.com/product/4NXR2?gclid=EAIaIQobChMInYeLwIPb5QIVjLbICh3UHAFdEAQYASABEgJ_xPD_BwE&cm_mmc=PPC:+Google+PLA&ef_id=EAIaIQobChMInYeLwIPb5QIVjLbICh3UHAFdEAQYASABEgJ_xPD_BwE:G:s&s_kwcid=AL!2966!3!390126534856!!!g!540448928863!; http://www.grainger.com/category/pneumatics/distribution-equipment
• American Piping Products provides metal pipes as well as metal fittings for metal pipes:
o http://www.amerpipe.com/steel-pipe-products/carbon-pipe/;
• Petro Piping provides metal pipes as well as metal fittings for metal pipes:
o http://petropipingsupply.com/carbon-steel-pipes/; http://petropipingsupply.com/carbon-steel-fittings/
Thus, applicant’s and registrant’s goods are considered related for likelihood of confusion purposes. See, e.g., In re Davey Prods. Pty Ltd., 92 USPQ2d 1198, 1202-04 (TTAB 2009); In re Toshiba Med. Sys. Corp., 91 USPQ2d 1266, 1268-69, 1271-72 (TTAB 2009).
In re U.S. Registration No. 3042019
Applicant’s relevant goods are “metal cable wire; non-electric cables of metal” in Class 6.
The registrant’s relevant goods are “Metal wires and wires of common metal alloys, except fuses” in Class 6.
In this case, the registration uses broad wording to describe metal wires, which presumably encompasses all goods of the type described, including applicant’s more narrow metal cable wire. See, e.g., In re Solid State Design Inc., 125 USPQ2d 1409, 1412-15 (TTAB 2018); Sw. Mgmt., Inc. v. Ocinomled, Ltd., 115 USPQ2d 1007, 1025 (TTAB 2015). Thus, applicant’s and registrant’s goods are highly related. See, e.g., In re i.am.symbolic, llc, 127 USPQ2d 1627, 1629 (TTAB 2018) (citing Tuxedo Monopoly, Inc. v.Gen. Mills Fun Grp., Inc., 648 F.2d 1335, 1336, 209 USPQ 986, 988 (C.C.P.A. 1981); Inter IKEA Sys. B.V. v. Akea, LLC, 110 USPQ2d 1734, 1745 (TTAB 2014); Baseball Am. Inc. v. Powerplay Sports Ltd., 71 USPQ2d 1844, 1847 n.9 (TTAB 2004)).
Further, the attached Internet evidence from U.S. Cargo Control, Lexco, and MSC, establishes that the same entity commonly manufactures, produces, or provides the relevant goods and markets the goods under the same mark, and the relevant goods are sold or provided through the same trade channels and used by the same classes of consumers in the same fields of use. For example:
The trademark examining attorney has attached evidence from the USPTO’s X-Search database consisting of a number of third-party marks registered for use in connection with the same or similar goods as those of both applicant and registrant in this case. This evidence shows that the goods listed therein, namely metal wires and metal cables, are of a kind that may emanate from a single source under a single mark. See In re I-Coat Co., 126 USPQ2d 1730, 1737 (TTAB 2018) (citing In re Infinity Broad. Corp., 60 USPQ2d 1214, 1217-18 (TTAB 2001); In re Albert Trostel & Sons Co.,29 USPQ2d 1783, 1785-86 (TTAB 1993); In re Mucky Duck Mustard Co., 6 USPQ2d 1467, 1470 n.6 (TTAB 1988)); TMEP §1207.01(d)(iii). See Registration Nos. 5879174, 5869777, and 5819610.
Thus, applicant’s and registrant’s goods are considered related for likelihood of confusion purposes. See, e.g., In re Davey Prods. Pty Ltd., 92 USPQ2d 1198, 1202-04 (TTAB 2009); In re Toshiba Med. Sys. Corp., 91 USPQ2d 1266, 1268-69, 1271-72 (TTAB 2009).
Accordingly, because the marks are significantly similar and the goods are highly related, purchasers are likely to be confused as to the source of the goods. Thus, registration is partially refused pursuant to Section 2(d) of the Trademark Act.
Although applicant’s mark has been refused registration, applicant may respond to the refusal(s) by submitting evidence and arguments in support of registration. Applicant should note the following advisory.
ADVISORY: PARTIAL REFUSAL RESPONSE OPTIONS
(1) Deleting the goods and/or services to which the refusal pertains;
(2) Filing a request to divide out the goods and/or services that have not been refused registration, so that the mark may proceed toward publication for opposition for those goods or services to which the refusal does not pertain. See 37 C.F.R. §2.87. See generally TMEP §§1110 et seq. (regarding the requirements for filing a request to divide). If applicant files a request to divide, then to avoid abandonment, applicant must also file a timely response to all outstanding issues in this Office action, including the refusal. 37 C.F.R. §2.87(e).; or
(3) Amending the basis for the goods and/or services identified in the refusal, if appropriate. TMEP §806.03(h). (The basis cannot be changed for applications filed under Trademark Act Section 66(a). TMEP §1904.01(a).)
Applicant must address the following requirements.
CLASSIFICATION AND IDENTIFICATION OF GOODS AND SERVICES
The identification of goods/services in Classes 6, 17, 37, 39, and 42 is indefinite and/or overbroad and must be clarified or reclassified to ensure proper analysis.
In Class 6, the wording “reinforcing materials, namely, flexible plates of metal for building purposes, excluding hose, flexible pipe or hose or flexible pipe used for oil or petroleum retail dispensing or fueling purposes or pipeline products or other products used for oil or petroleum retail dispensing or fueling purposes” in the identification of goods is indefinite and must be clarified to further specify the nature of the goods, as set forth below. See 37 C.F.R. §2.32(a)(6); TMEP §1402.01.
In Class 17, the wording “Flexible steel pipe and pipeline products for use in the oil and gas industry for oil and gas exploration and production, transmission and drilling, namely, flexible pipes for conveying natural gas comprised primarily or wholly of plastics” and “connectors, couplings and joints, pipe fittings, namely, rosettes, non-metal tubing and tubing couplings for joining and terminating pipes” in the identification of goods is indefinite and must be clarified to further specify the nature of the goods, as set forth below. See 37 C.F.R. §2.32(a)(6); TMEP §1402.01
In Class 37, the wording “installation, operation and maintenance of steel pipes and steel deployment systems” in the identification of services is indefinite and must be clarified to further specify the nature of the services, as set forth below. See 37 C.F.R. §2.32(a)(6); TMEP §1402.01
Applicant must clarify the goods by (1) describing the nature, purpose, or use of the system; and (2) listing the system’s parts or components, using common generic terms and referencing the primary parts or components of the system first. See 37 C.F.R. §2.32(a)(6); TMEP §§1401.05(d), 1402.01, 1402.03(a). Additionally, this wording should be classified in the same international class as the primary parts or components of the system. See TMEP §1401.05(d).
In Class 39, the wording “equipment” in the identification of services is indefinite and misclassified, as it is classified in a services class rather than a goods class, and must be clarified to further specify the equipment provided, as set forth below. See 37 C.F.R. §2.32(a)(6); TMEP §1402.01
In Class 42, the wording “Design of pipes for others; pipeline services, namely, pipeline integrity testing” in the identification of services is indefinite and must be clarified to further specify the nature of the services, as set forth below. See 37 C.F.R. §2.32(a)(6); TMEP §1402.01
Applicant may adopt the following suggestions, if accurate:
006: Flexible pipe and pipeline products, all of metal, namely, pipe, fittings, pipe clips, collars, connectors, couplings and joints; steel pipes and tubes; branching tubes of metal for pipelines, compressed air pipe fittings of metal; metal cable wire; non-electric cables of metal; reinforcing materials, namely, flexible plates of steel for building purposes, excluding hose, flexible pipe or hose or flexible pipe used for oil or petroleum retail dispensing or fueling purposes or pipeline products or other products used for oil or petroleum retail dispensing or fueling purposes; flexible steel pipe; flexible pipe and pipeline products for use in the oil and gas industry for oil and gas exploration and production, transmission and drilling, namely, pipes comprised primarily or wholly of metal and metal fittings therefor; flexible pipes comprised primarily or wholly of metal for conveying natural gas, oil, water, carbon dioxide, mined ore, jet fuel, sewage, and fiber optic cables; pipe clips, collars, connectors, couplings and joints comprised primarily or wholly of metal; but not including hose, flexible pipe or pipeline products or other products used for oil or petroleum retail dispensing or fueling purposes; flexible steel pipe deployment systems comprised of {specify components, e.g., steel pipes, pipe fittings of metal, pipe tubes of metal, metal pipe clips, etc.} and equipment therefor, namely, {specify equipment, e.g., pipe fittings of metal, metal pipe clips, etc.}
007: Mechanical lifting system for deploying pipes, designed to raise or lower pipe coils and install pipe, consisting primarily of mechanical and hydraulic lifts, mounted on a trailer and trailer bed, with trailer bed actuators as a unit
012: Trailers for laying flexible steel pipe; flexible steel pipe deployment systems comprised primarily of trailers for hauling and laying pipe, coiled pipe, coiled tubing, flexible pipe, flexible steel pipe and flexible composite pipe; equipment trailers, coil trailers, coil tubing trailers, pipe trailers, flexible pipe trailers, flexible steel pipe trailers, and flexible composite pipe trailers
017: Flexible steel pipe and Pipeline products for use in the oil and gas industry for oil and gas exploration and production, transmission and drilling, namely, flexible
pipes for conveying natural gas comprised primarily or wholly of plastics; reinforced flexible thermoplastic pipe; flexible pipes comprised primarily or wholly of plastics for conveying natural gas,
oil, water, carbon dioxide, mined ore, jet fuel, sewage, and fiber optic cables, but not including hose, flexible pipe or pipeline products or other products used for oil or
petroleum retail dispensing or fueling purposes; branching tubes not of metal for pipelines, rubber tubes and pipes, non-metal pipe collars, non-metal pipe connectors,
pipe couplings and joints, pipe fittings, namely, rosettes, non-metal flexible tubing and tubing couplings for joining and terminating pipes, pipe gaskets,
flexible compressed air pipe fittings, not of metal, flexible plastic pipes for conveying natural gas, insulated pipe supports, insulation jackets for industrial pipes, insulating sleeves for
pipeline; interior linings made of non-metal fabric and sealant for the repair of electrical, telecommunication and natural gas utility conduits and pipes, rings of rubber for use as pipe connection
seals; but not including hose, flexible pipe or pipeline products or other products used for oil or petroleum retail dispensing or fueling purposes; all the aforesaid goods not of metal or of
composites or plastic and metals; flexible pipe, not of metal
020: Non-metal pipe collars
037: Pipe deployment services, namely, pipe laying for others; operating pipe deployment systems, namely, pipe laying services using pipe laying equipment to install pipe for others; pipeline maintenance and construction, namely, installation, operation and maintenance of steel pipes and steel deployment systems
039: Flexible steel pipe deployment systems and equipment
042: {Specify type of design, e.g., engineering, industrial} design services, namely, design of pipes for others; pipeline services, namely, testing the functionality and integrity of apparatus and instruments in the nature of {specify nature of pipelines, e.g., oil, gas} pipelines
For assistance with identifying and classifying goods and services in trademark applications, please see the USPTO’s online searchable U.S. Acceptable Identification of Goods and Services Manual. See TMEP §1402.04.
Applicant must address the following additional requirement.
MULTIPLE-CLASS APPLICATION REQUIREMENTS
The application identifies goods and services that are potentially classified in at least eight classes; however, applicant submitted a fee sufficient for only seven classes. In a multiple-class application, a fee for each class is required. 37 C.F.R. §2.86(a)(2), (b)(2); TMEP §§810.01, 1403.01.
Therefore, applicant must either (1) restrict the application to the number of classes covered by the fees already paid, or (2) submit the fees for each additional class and satisfy all the requirements below for each international class based on Trademark Act Section 1(b):
(1) List the goods and/or services by their international class number in consecutive numerical order, starting with the lowest numbered class.
(2) Submit a filing fee for each international class not covered by the fee(s) already paid (view the USPTO’s current fee schedule). The application identifies goods and/or services that are potentially classified in at least eight classes; however, applicant submitted a fee(s) sufficient for only seven classes. As explained, applicant must either submit the filing fees for the classes not covered by the submitted fees or restrict the application to the number of classes covered by the fees already paid.
See 15 U.S.C. §§1051(b), 1112, 1126(e); 37 C.F.R. §§2.32(a)(6)-(7), 2.34(a)(2)-(3), 2.86(a); TMEP §§1403.01, 1403.02(c).
See an overview of the requirements for a Section 1(b) multiple-class application and how to satisfy the requirements online using the Trademark Electronic Application System (TEAS) form.
The fee for adding classes to a TEAS Reduced Fee (RF) application is $275 per class. See 37 C.F.R. §§2.6(a)(1)(iii), 2.23(a). See more information regarding the requirements for maintaining the lower TEAS RF fee and, if these requirements are not satisfied, for adding classes at a higher fee using regular TEAS.
RESPONSE GUIDELINES
See 37 C.F.R. §2.65(a); TMEP §718.02(a).
In such case, the application will then proceed with the following goods and services only:
See TMEP §718.02(a).
TEAS PLUS OR TEAS REDUCED FEE (TEAS RF) APPLICANTS – TO MAINTAIN LOWER FEE, ADDITIONAL REQUIREMENTS MUST BE MET, INCLUDING SUBMITTING DOCUMENTS ONLINE: Applicants who filed their application online using the lower-fee TEAS Plus or TEAS RF application form must (1) file certain documents online using TEAS, including responses to Office actions (see TMEP §§819.02(b), 820.02(b) for a complete list of these documents); (2) maintain a valid e-mail correspondence address; and (3) agree to receive correspondence from the USPTO by e-mail throughout the prosecution of the application. See 37 C.F.R. §§2.22(b), 2.23(b); TMEP §§819, 820. TEAS Plus or TEAS RF applicants who do not meet these requirements must submit an additional processing fee of $125 per class of goods and/or services. 37 C.F.R. §§2.6(a)(1)(v), 2.22(c), 2.23(c); TMEP §§819.04, 820.04. However, in certain situations, TEAS Plus or TEAS RF applicants may respond to an Office action by authorizing an examiner’s amendment by telephone or e-mail without incurring this additional fee.
How to respond. Click to file a response to this nonfinal Office action
/Nathaniel Pettican/
Nathaniel Pettican
Examining Attorney
Law Office 108
(571) 272-1087
nathaniel.pettican@uspto.gov
RESPONSE GUIDANCE
