Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.gov

ESTTA Tracking number: ESTTA1132383

Filing date: 05/10/2021

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

Proceeding 91245859

Party DefendantJessica Tehlirian and Jehan Carter

CorrespondenceAddress

JEHAN CARTER3107 18TH STREET NEWASHINGTON, DC 20018UNITED STATESPrimary Email: counsel@askcarterlaw.comSecondary Email(s): info@thelawyerbae.com800-201-0266

Submission Opposition/Response to Motion

Filer's Name Jehan Carter

Filer's email counsel@askcarterlaw.com, info@thelawyerbae.com

Signature /Jehan Carter/

Date 05/10/2021

Attachments LB.ApplicantOpposition.MotionToExtend.docx Combined.pdf(1218069 bytes )

IN THE UNITED STATES PATENT AND TRADEMARK OFFICEBEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

SHAYTONNA V. BULLOCK, §§ Mark: LAWYER BAE

Opposer, § - Serial No. 87861997§ - Published: September 18, 2018

vs. §§ Opposition No. 91245859

JESSICA TEHLIRIAN §JEHAN CARTER §

§Applicants. §

APPLICANTS OPPOSITION TO OPPOSER’S MOTION TO EXTEND DISCOVERYDEADLINE

Jehan Carter and Jessica Tehlirian (“Applicants”) response and opposition to Shaytonna

Bullock (“Opposer”) Motion To Extend Discovery Deadline is as follows:

1. Opposer, Shaytonna V. Bullock, on April 19th, 2021 requested an extension to the discovery

deadline pursuant to Trademark Rule 509.01.

2. As further evidenced in the foregoing Memorandum in Support and Applicants

various previous pleadings, Applicants maintain that their products using the mark were first put

in commerce along with their professional organization services that share the same exact mark

as of January 2018 and that the March 2018 first use anywhere and first use of commerce date

was merely stated in the registration for this opposed category as a precaution since Applicants

had a change of manufacturers in that time frame. Also the March 1st, 2018 order did not

properly sync with Applicants original Printful store (that is now deleted) and so it had to be

manually entered and fulfilled. Lastly, Opposer herself has sales data from different

manufacturers and websites with alleged use of the mark so she is also aware of how

dropshipping and various sites can connect with more than one store online.

3. In addition, the fact that the Opposer has already received the necessary documents that

are in her motion from us directly (and therefore our overall general objection to her motion is

that her request is duplicative), she had the end of December-February 18th 2021 to provide this

request when our proceedings resumed and then an additional 60 days to send this request to

Printful after she asked us to extend the discovery period so this request does not fit “reasonable

notice”.

4. Applicants have already been granted ownership of the “Lawyer Bae” mark in several other

categories (with a December 2017 first use anywhere and January 2018 first in commerce date) that

launched simultaneously with Applicants products that share the same exact mark and therefore her

March 1, 2018 request is moot.

MEMORANDUM IN SUPPORT OF APPLICANTS OPPOSITION TOOPPOSER’S MOTION FOR SANCTIONS

I. FIRST GROUND FOR OPPOSITION—OPPOSER HAS ALREADY

RECEIVED REQUESTED DOCUMENTATION

Applicants have already provided to the Opposer and the Board actual use of the mark in

commerce prior to their first use in commerce date of March 1, 2018 stated in their

registration. First, Applicants have submitted the January 2018 domain purchase and Shopify

website specimen using the mark on their merchandise in Exhibit 1 of their previous response to

Opposer’s First Motion to Amend, submitted acceptable “actual use” evidence of the mark along

with submission of the March 2018 previous and current Printful store being live (also Exhibit 1

from our previous response) with Applicants products placed in commerce with the mark where

Customers could immediately purchase the product on their Thelawyerbae.com website (“Mere

advertising or promotion of a trademark on a web page is not “use in commerce,” a website page

that displays the trademark, the product and a means to buy the product is considered to be “use

in commerce.” See In re Sones, 590 F.3d 1282, 93 U.S.P.Q.2d 1118 (Fed. Cir. 2009). There must

be a means of ordering the goods directly from the web page, such as a telephone number for

placing orders or a pull-down menu for online ordering.” In re Quantum Foods, Inc., 94

U.S.P.Q.2d 1375, 1380 (T.T.A.B. 2010), submitted sales data since January of 2018 through 2021

showing continual bona fide use of the mark in sales all over the United States (the rules define

“bona fide” use as the first use followed by activities providing a continuous effort or intent to use

the mark) and last but not least, Applicants submitted examples of their 2017-2018 marketing and

advertising of the mark including retail display of the mark on the various types of products on the

online catalogue on their website. ( See Lands’ End, Inc. v. Manbeck, 24 U.S.P.Q. 2d 1314 (E.D.

Va. 1992) determining that a catalog was not mere advertising and met the relevant criteria for

displays associated with the goods because, (1) the specimen included a picture of the goods, (2)

the trademark KETCH appeared prominently on the display in a manner which closely associated

the mark with the goods, and (3) customers were able to make purchases by completing a sales

form or by calling in a purchase by phone). Additionally, the Board has considered advertising

and marketing materials in the actual use of the mark especially when there is a contest between

parties about priority as in this case (In the United States, “use analogous to trademark use,”

including advertising campaigns to announce the launch of a new product, or taking orders for a

product that will soon be on the market, can sometimes be “tacked” onto actual use for the

purposes of establishing priority. Hence, the key in trademark matters such as these is whether the

trademark owner can show this kind of prior use created an association in the minds of the

purchasing public between the mark and the goods. T.A.B. Systems v. PacTel Teletrac, 77 F.3d

1372 (Fed. Cir. 1996) In this matter, Applicants have established beyond the preponderance of the

evidence the fact that their advertising of the mark leading up to the sale of the products using the

mark should also be considered as “actual use” since the Applicants prevalent and worldwide use

has garnered them the number one Google search hit using the mark and the number one

Instagram, Facebook and Twitter pages also using the mark and therefore has established

Applicants as the source of the mark in the minds of the public). Lastly, the Trademark Board also

defines actual use in commerce on goods when a mark is affixed to the goods and such goods are

sold or transported in commerce. Applicants have provided the Board and the Opposer in their

response to Opposer’s discovery requests actual day by sales not just from January-February 2018

pre-orders that were processed by April 2018 from Applicants second Printful store but also all

months including present date sales from both Prinful and Shopify (that match) and that power

Applicants online store which also includes the first purchaser’s name, address and list of products

ordered (which is technically the only thing required of Applicants in an issue of first use).

Therefore, Opposer’s request is duplicative.

II. SECOND GROUND FOR OPPOSITION – PRINTFUL OPPOSES OPPOSERSREQUEST

1. We concur with the reasons (lack of reasonable notice, lack of prior notice to the other

parties in TTAB action, improperly purports to require the production of documents 100 miles

from where Opposer conducts business, and that conflicts with attorney client privilege and

client confidentiality) as stated in the attached opposition from Printful, from which Opposer

seeks duplicative documentation from (Exhibit A).

III. THIRD GROUND FOR OPPOSITION - APPLICANTS HAVE ALREADY BEENGRANTED THE LAWYER BAE MARK WITH THE FIRST USE OF COMMERCEDATE OF JANUARY 2018 IN OTHER CATEGORIES THAT SHARES THESAME EXACT MARK WITH APPLICANTS MERCHANDISE

1. Applicants in December 2020 were granted registration ownership over the

“Lawyer Bae” mark in several other categories that were launched in January 2018 along

with Applicants merchandise products that share the same exact mark (Exhibit B).

Applicants legal professional organization website (which was provided as a specimen for

the registration in the other categories) was launched with the organization’s merchandise

at the same time in January 2018 as explained above and therefore the March and April

2018 dates stated in this disputed registration for this category was a mere precaution since

Applicants changed manufacturers and store interfaces. Thus, the Opposer’s request for a

March 1 order sale is moot at this point.

III. CONCLUSION

In conclusion, Opposer has received both our January through February 2018 pre-order

sales from our first store that actually precede the March 2018 order she is requesting

documentation from. In addition, at the time of her last supplemental requests (July 2020 and

January-February 2021) we also provided her all the documentation we had from the March 1,

2018 order since the store no longer exists. Furthermore, Opposer has received all of our sales by

category from our current Printful account (see Motion for Sanctions exhibits) and current Shopify

account that included our Printful sales and sales from our other manufacturers. In short, Ms.

Bullock already has everything and therefore her motion to extend discovery is not only not

necessary, it goes beyond reasonableness since Opposer has ample time to make her request.

Finally, Applicants as stated above have already been granted the Trademark registration of

“Lawyer Bae” in several other categories that were launched in January 2018 along with

Applicants merchandise products that share the same exact mark so Opposer’s claims and or

questions surrounding Applicants first use is now moot and therefore we ask that her Motion is

denied with prejudice.

Respectfully submitted,

Dated: May 9, 2021 /s/Jehan A. CarterJehan A. Carter, Esq./s/Jessica TehlirianJessica Tehlirain, Esq.

CERTIFICATE OF SERVICE

I hereby certify that a true and complete copy of the foregoing APPLICANTSOPPOSITION TO OPPOSER’S MOTION TO EXTEND DISCOVERY DEADLINE has been

served on Shaytonna Bullock by forwarding said copy on this 9th day of May 2021, via email to:

Shaytonna Bullock6514 Marlboro Pike#182District Heights, MD 20747bullock.shaytonna@gmail.com .

Dated: May 9, 2021 /s/ Jehan A. Carter, Esq./s/ Jessica Tehlirian, Esq.

Applicants3107 18th Street NE

Washington, DC 20018

EXHIBIT A

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449/033175-0012 16343706

NON-PARTY PRINTFUL, INC.'S RESPONSES AND OBJECTIONS TO

PLAINTIFF/OPPOSER SHAYTONNA V. BULLOCK’S SUBPOENA

RUTAN & TUCKER, LLP Michael D. Adams (CA Bar No. 185835) madams@rutan.com Meredith L. Williams (CA Bar No. 292888) mwilliams@rutan.com 18575 Jamboree Road, 9th Floor Irvine, California 92612 Telephone: 714-641-5100 Facsimile: 714-546-9035 Attorneys for Non-Party Printful, Inc.

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF NORTH CAROLINA

Shaytonna V. Bullock,

Plaintiff/Opposer,

vs. Jehan Carter and Jessica Tehlirian,

Defendants/Applicants.

Case No.: TTAB Opposition No. 91245859 NON-PARTY PRINTFUL, INC.’S RESPONSES AND OBJECTIONS TO PLAINTIFF/OPPOSER SHAYTONNA V. BULLOCK’S SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION The Subpoena demands compliance as follows: Date: April 9, 2021 Location: Shaytonna V. Bullock

PO Box #47182 District Heights, MD 20747

The Subpoena was served as follows: Date: April 6, 2021 To: Printful, Inc. Location: 11025 Westlake Drive Charlotte, NC 28273

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449/033175-0012 16343706

-1- NON-PARTY PRINTFUL, INC.'S RESPONSES AND OBJECTIONS TO

PLAINTIFF/OPPOSER SHAYTONNA V. BULLOCK’S SUBPOENA

Pursuant to Rule 45 of the Federal Rules of Civil Procedure, non-party Printful, Inc.

(“Printful”), by and through its undersigned counsel, hereby responds and objects to the Subpoena

to Produce Documents, Information, Or Objects Or To Permit Inspection Of Premises In A Civil

Action (the “Subpoena”) attached hereto as Exhibit A and served by Plaintiff/Opposer Shaytonna

V. Bullock (“Opposer”) in connection with Opposition No. 91245859 before the Trademark Trial

and Appeal Board (the “TTAB Action”), in which Opposer is adverse to Defendants/Applicants

Jehan Carter and Jessica Tehlirian (“Applicants”). Printful hereby objects as follows:

GENERAL OBJECTIONS

1. Printful objects to the Subpoena on the ground that it was only served on Printful on

April 6, 2021, i.e. 3 days before the compliance date of April 9, 2021. As such, the Subpoena fails

to allow a reasonable time to comply pursuant to the Federal Rules of Civil Procedure, including

Rule 30(b)(1) and Rule 45(d)(3)(A)(i). See, e.g., United States v. Philip Morris Inc., 312 F. Supp.

2d 27, 36–37 (D.D.C. 2004) (“Fed.R.Civ.P. 30(b)(1) requires that ‘reasonable notice’ be provided

to any witness served with a subpoena. . . . Needless to say, notice of three business days, especially

to busy litigators . . . does not constitute ‘reasonable notice.’”).

2. Printful further objects to the Subpoena on the ground that Opposer apparently failed

to give prior notice of the Subpoena to the other parties to the TTAB Action, i.e. Applicants, as

required by Rule 45. See Dan Foam Aps v. Sleep Innovations, Inc., 106 U.S.P.Q.2d 1939 (T.T.A.B.

2013) (discussing notice requirement to adverse party under Fed. R. Civ. P. 45(b)(1) [now Rule

45(a)(4)] for a subpoena duces tecum (without deposition) issued to non-party). Federal Rule of

Civil Procedure 45(a)(4) states in relevant part that, “[i]f the subpoena commands the production

of documents, electronically stored information, or tangible things or the inspection of premises

before trial, then before it is served on the person to whom it is directed, a notice and a copy of the

subpoena must be served on each party.” Opposer also apparently failed to comply with Local

Civil Rule 45.2 of the U.S. District Court for the Western District of North Carolina, which requires

that a “notice of the issuance of a document subpoena to a non-party and a copy of the subpoena,

as required by Fed. R. Civ. P. 45(a)(4), shall be served on all other parties at least three (3) calendar

days before the date on which the subpoena is served on the non-party.” Courts have sanctioned

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449/033175-0012 16343706

-2- NON-PARTY PRINTFUL, INC.'S RESPONSES AND OBJECTIONS TO

PLAINTIFF/OPPOSER SHAYTONNA V. BULLOCK’S SUBPOENA

parties who fail to comply with the notice requirement of Rule 45, including by quashing such

improperly served subpoenas. See Firefighter's Institute for Racial Equality ex rel. Anderson v.

City of St. Louis, 220 F.3d 898 (8th Cir. 2000) (improperly served nonparty subpoenas quashed)

3. Printful also objects that the Subpoena improperly purports to require the production

of documents from Printful’s business located at 11025 Westlake Drive, Charlotte, NC 28273

outside of the state and more than 100 miles from that location, i.e. to Opposer’s PO Box located

in District Heights, MD 20747 (more than 400 miles away). The Subpoena thus violates Rule

45(c)(2)(A), which allows a subpoena to command document production only “within 100 miles

of where the person resides, is employed, or regularly transacts business in person.”

4. Printful also objects to the Subpoena and the instructions contained therein to the

extent they purport to impose any requirement or discovery obligation other than or beyond those

set forth in the Federal Rules of Civil Procedure or applicable TTAB rules or orders.

5. Printful objects to the Subpoena to the extent the requests for documents call for

information that is protected by the attorney-client privilege, the work product doctrine, the

common interest privilege, or any other applicable privilege or protection.

OBJECTIONS TO DOCUMENT REQUESTS

REQUEST NO. 1:

A copy of all documents or electronically stored information relating to sales records of

products printed and shipped by Printful, Inc., for the time period of March 1, 2018 to present,

bearing any variation of the term “LAWYER BAE” for the Shopify e-commerce store/website

utilizing the domain name www.thelawyerbae.com owned by Printful users Jehan Carter and Jessica

Tehlirian.

RESPONSE TO REQUEST NO. 1:

In addition to Printful’s general objections above, which are expressly incorporated herein

by reference and demonstrate that the Subpoena is defective, Printful objects to this request on the

ground that it is unduly burdensome and oppressive to Printful and disregards the extra protections

afforded non-parties by the Federal Rules of Civil Procedure and applicable case law. See, e.g.,

Fed. R. Civ. Proc., R. 45; Belk v. Smith, No. 1:10CV724, 2014 WL 4986678, at *2 (M.D.N.C. Oct.

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449/033175-0012 16343706

-3- NON-PARTY PRINTFUL, INC.'S RESPONSES AND OBJECTIONS TO

PLAINTIFF/OPPOSER SHAYTONNA V. BULLOCK’S SUBPOENA

6, 2014) (discussing “the recognized purpose of protecting non-parties from unnecessary discovery

burdens”) (citing Haworth, Inc. v. Herman Miller, Inc., 998 F.2d 975, 978 (Fed.Cir.1993) (holding

that a district court did not err in requiring a party to seek discovery from its opponent before seeking

it from a nonparty); see also Dart Indus. Co., Inc. v. Westwood Chem. Co., Inc., 649 F.2d 646, 649

(9th Cir.1980) (permitting broader discovery restrictions as to requests directed to non-parties);

Collins & Aikman Corp. v. J.P. Stevens & Co., 51 F.R.D. 219, 221 (D.S. C.1971) (“There appear to

be quite strong considerations indicating that the discovery would be more limited to protect third

parties from harassment, inconvenience, or disclosure of confidential documents.”).

In particular, the records that Opposer seeks from Printful—sales records for “Printful users

Jehan Carter and Jessica Tehlirian,” i.e. Applicants in the TTAB Action—should be obtained from

those parties to that action. Pursuant to the records maintained by the TTAB for that proceeding,

discovery has been open in the TTAB Action for over two years, i.e. since March 26, 2019, and

there is no legitimate reason for Opposer to seek Applicant’s sales records from Printful. Further,

by seeking Applicants’ sales records from Printful (i.e. demanding that Printful turn over customer

records), this request demands that Printful potentially violate third party consumer privacy rights

and/or provide confidential and/or proprietary business documents belonging to its customers.

Printful will not comply with this improper demand served via a procedurally deficient Subpoena.

REQUEST NO. 2:

Produce documents or electronically stored information, including, but not limited to, the

date, time, customer name, a listing of the products ordered, and the city and state to which the

first order shipped for the above-defined e-commerce store/website (www.thelawyerbae.com).

RESPONSE TO REQUEST NO. 2:

In addition to Printful’s general objections above, which are expressly incorporated herein

by reference and demonstrate that the Subpoena is defective, Printful objects to this request on the

ground that it is unduly burdensome and oppressive to Printful and disregards the extra protections

afforded non-parties by the Federal Rules of Civil Procedure and applicable case law. See, e.g.,

Fed. R. Civ. Proc., R. 45; Belk v. Smith, No. 1:10CV724, 2014 WL 4986678, at *2 (M.D.N.C. Oct.

6, 2014) (internal citations provided above).

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449/033175-0012 16343706

-4- NON-PARTY PRINTFUL, INC.'S RESPONSES AND OBJECTIONS TO

PLAINTIFF/OPPOSER SHAYTONNA V. BULLOCK’S SUBPOENA

In particular, the records that Opposer seeks from Printful—order records for Applicants in

the TTAB Action—should be obtained from those parties to that action (if they may be properly

obtained at all). Pursuant to the records maintained by the TTAB for that proceeding, discovery has

been open in the TTAB Action for over two years, i.e. since March 26, 2019, and there is no

legitimate reason for Opposer to seek Applicant’s order records from Printful. Further, by seeking

Applicants’ order records from Printful (i.e. demanding that Printful turn over customer records),

this request demands that Printful potentially violate third party consumer privacy rights and/or

provide confidential and/or proprietary business documents belonging to its customers. This request

also appears to violate the privacy rights of the third party consumer who ordered products from

Applicants, in that the request demands that Printful provide that customer’s “name, a listing of the

products ordered, and the city and state to which” that customer’s order shipped. Printful will not

comply with this improper demand served via a procedurally deficient Subpoena.

REQUEST NO. 3:

Also, produce documents or electronically stored information, including, but not limited to,

mock-up images of the clothing products made available by Printful, Inc., for the time period of

March 1, 2018 to present, via the above-described e-commerce store/website (www.the

lawyerbae.com), specifically indicating when the respective clothing products were made available

for order and showcasing the placement of any custom printed t-shirt labels included on the inside

or outside of any clothing products (i.e. t-shirts and hoodies).

RESPONSE TO REQUEST NO. 3:

In addition to Printful’s general objections above, which are expressly incorporated herein

by reference and demonstrate that the Subpoena is defective, Printful objects to this request on the

ground that it is unduly burdensome and oppressive to Printful and disregards the extra protections

afforded non-parties by the Federal Rules of Civil Procedure and applicable case law. See, e.g.,

Fed. R. Civ. Proc., R. 45; Belk v. Smith, No. 1:10CV724, 2014 WL 4986678, at *2 (M.D.N.C. Oct.

6, 2014) (internal citations provided above).

In particular, the records that Opposer seeks from Printful—mock-up images of products

made by Applicants in the TTAB Action—should be obtained from those parties to that action.

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449/033175-0012 16343706

-5- NON-PARTY PRINTFUL, INC.'S RESPONSES AND OBJECTIONS TO

PLAINTIFF/OPPOSER SHAYTONNA V. BULLOCK’S SUBPOENA

Pursuant to the records maintained by the TTAB for that proceeding, discovery has been open in

the TTAB Action for over two years, i.e. since March 26, 2019, and there is no legitimate reason

for Opposer to seek Applicant’s order records from Printful. Printful will not comply with this

improper demand served via a procedurally deficient Subpoena.

Dated: April 8, 2021 RUTAN & TUCKER, LLP

By: /s/ Meredith L. Williams Meredith L. Williams Attorneys for Non-Party PRINTFUL, INC.

      

EXHIBIT A

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449/033175-0012 16343706

-6- NON-PARTY PRINTFUL, INC.'S RESPONSES AND OBJECTIONS TO

PLAINTIFF/OPPOSER SHAYTONNA V. BULLOCK’S SUBPOENA

CERTIFICATE OF SERVICE

The undersigned hereby certifies that she is one of the attorneys for Printful, Inc., a non-

party in the above-captioned Opposition proceeding, and that on the date which appears below, she

caused a copy of the foregoing NON-PARTY PRINTFUL, INC.’S RESPONSES AND

OBJECTIONS TO PLAINTIFF/OPPOSER SHAYTONNA V. BULLOCK’S SUBPOENA

TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT

INSPECTION OF PREMISES IN A CIVIL ACTION to be served on the following via email

pursuant to the Trademark Trial and Appeal Board Manual of Procedure, § 113, and 37 C.F.R. §

2.119:

Applicants Jessica Tehlirian and Jehan Carter 3107 18TH STREET NE WASHINGTON, DC 20018 counsel@askcarterlaw.com, info@thelawyerbae.com Phone: 800-201-0266 Opposer SHAYTONNA BULLOCK 6514 MARLBORO PIKE 182 DISTRICT HEIGHTS, MD 20747 bullock.shaytonna@gmail.com Phone: 301-613-9933 Dated: April 8, 2021 /Meredith L. Williams/ Costa Mesa, California Meredith L. Williams

EXHIBIT B

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Word Mark LAWYER BAEGoods andServices

IC 025. US 022 039. G & S: Hats; Sweatshirts; Sweatshirts for women and men; apparel, namely, fashionable t-shirts and sweats in the nature of sweat jackets, sweat suits, sweat shirts, and sweat pants; T-shirts; T-shirts forwomen and men; apparel, namely, fashionable t-shirts; Baseball caps and hats; Fashion hats; Graphic T-shirts;Hooded sweatshirts; Hooded sweatshirts for women and men; apparel, namely, fashionable t-shirts and sweats inthe nature of sweat jackets, sweat suits, sweat shirts, and sweat pants; Short-sleeved or long-sleeved t-shirts; Sportscaps and hats. FIRST USE: 20180301. FIRST USE IN COMMERCE: 20180301

StandardCharactersClaimedMarkDrawingCode

(4) STANDARD CHARACTER MARK

SerialNumber 87861997

Filing Date April 3, 2018CurrentBasis 1A

OriginalFilingBasis

1A

PublishedforOpposition

September 18, 2018

Owner (APPLICANT) Jessica Tehlirian INDIVIDUAL UNITED STATES 3107 18th Street NE Washington D.C. 20018

(APPLICANT) Jehan Carter INDIVIDUAL UNITED STATES 3107 18th Street NE Washington D.C. 20018Type ofMark TRADEMARK

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