Response to Office Action

PTO- 1957

Approved for use through 11/30/2023. OMB 0651-0050

U.S. Patent and Trademark Office; U.S. DEPARTMENT OF COMMERCE Under the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it contains a valid OMB control number

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PTO- 1957

Approved for use through 11/30/2023. OMB 0651-0050

U.S. Patent and Trademark Office; U.S. DEPARTMENT OF COMMERCE Under the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it contains a valid OMB control number

Response to Office Action

To the Commissioner for Trademarks:

Application serial no. 90133140 TIGER KING(Standard Characters, see http://uspto.report/TM/90133140/mark.png) has been amended as follows:

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

In response to the Section 2(d) refusal stating that the U.S. Registration No. 5096256 for the mark HU WANG would create confusion due to the translation being King of Tigers, applicant argues that consumers in the United States would not be confused with the mark under Application Serial Number 90133140 TIGER KING. Consumers in the United States associate the mark TIGER KING to be associated with real life characters from the Netflix show Tiger King: Murder Mayhem and Madness, specifically as the term coined by Joseph Maldanado-Passage who then transferred ownership of the name to Greater Wynnewood Exotic Animal Park, LLC and now Tiger King LLC. It is highly unlikely that in this class of goods and services the Tiger King mark would be confused with the Hu Wang mark. As to the prior filed applications, applicants for this mark are the rightful owners of the mark. Other prior filed applications not owned by Greater Wynnewood Exotic Animal Park, LLC and Tiger King, LLC have no lawful right to registration of this mark. In response to the Section 2(a) refusal regarding false association evidence has been provided. In response to the 2(c) refusal referencing the identification of an individual as the nature of the mark, we contend that the mark Tiger King does not specifically reference a single individual. We contend that we rightfully own the rights to the mark as it applies to multiple trademark classes.

EVIDENCE

Original PDF file:
evi_2600880456076500d9728 b6930c04e58-2021052720274 0857155_._2016_09_19_Joe_ IP_rights_agreement_Jeff_ Lowe.pdf
Converted PDF file(s) ( 5 pages) Evidence-1Evidence-2Evidence-3Evidence-4Evidence-5
Correspondence Information (current):
      Katherine Sullivan
      PRIMARY EMAIL FOR CORRESPONDENCE: Katesullivanattorney@gmail.com
      SECONDARY EMAIL ADDRESS(ES) (COURTESY COPIES): kate@blackdoglawpllc.com
Correspondence Information (proposed):
      Katherine Sullivan
      PRIMARY EMAIL FOR CORRESPONDENCE: Katesullivanattorney@gmail.com
      SECONDARY EMAIL ADDRESS(ES) (COURTESY COPIES): kate@blackdoglawpllc.com

Requirement for Email and Electronic Filing: I understand that a valid email address must be maintained by the owner/holder and the owner's/holder's attorney, if appointed, and that all official trademark correspondence must be submitted via the Trademark Electronic Application System (TEAS).

FEE(S)
Fee(s) in the amount of $150 is being submitted.

SIGNATURE(S)
Response Signature
Signature: /KE Sullivan/     Date: 05/27/2021
Signatory's Name: Katherine Sullivan
Signatory's Position: Attorney of Record, OK Bar Member

Signatory's Phone Number: 9182312546 Signature method: Signed directly within the form

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:    Katherine Sullivan
   BLACK DOG LAW, PLLC
   
   33687 RIDGE RD
   AFTON, Oklahoma 74331
Mailing Address:    Katherine Sullivan
   BLACK DOG LAW, PLLC
   33687 RIDGE RD
   AFTON, Oklahoma 74331
        
PAYMENT: 90133140
PAYMENT DATE: 05/27/2021
        
Serial Number: 90133140
Internet Transmission Date: Thu May 27 20:58:32 ET 2021
TEAS Stamp: USPTO/ROA-XXXX:XXXX:XXXX:XXXX:XXXX:XXXX:
XXXX:XXXX-20210527205832115411-90133140-
780ae8788b386e61ba06da736d3d2b51469675c3
d7598a92151d0b4b8eb6e3c7-CC-58280372-202
10527202740857155