R. Josephs Licensing Inc.v.Laguna Costa LLC

Trademark Trial and Appeal Board

Dec 6, 2016

CANC (T.T.A.B. Dec. 6, 2016)

Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
ESTTA Tracking number: ESTTA787541
Filing date: 12/06/2016
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
Proceeding 92063073
Party Defendant
Laguna Costa LLC
Correspondence
Address
JAMES E KEY
HARRIS FINLEY & BOGLE PC
777 MAIN STREET, SUITE 1800
FORT WORTH, TX 76102
UNITED STATES
jkey@hfblaw.com, lriley@hfblaw.com
Submission Other Motions/Papers
Filer's Name James E. Key
Filer's e-mail jkey@hfblaw.com, lriley@hfblaw.com, bdore@hfblaw.com
Signature /James E. Key/
Date 12/06/2016
Attachments Laguna Costa LLC Notice of Expert Disclosures.pdf(294000 bytes )
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
R. JOSEPHS LICENSING INC.,
Petitioner,
V.
LAGUNA COSTA LLC,
Registrant.
R. JOSEPHS LICENSING INC.,
Opposer,
V.
LAGUNA COSTA LLC,
Applicant.
LAGUNA COSTA LLC,
Petitioner,
v.
R. JOSEPHS LICENSING INC.,
Registrant.
Cancellation Nos. 92063076 & 92063073
Registration No. 4784628 & 4784629
Registration Date: August 4, 2015
Mark: LAGUNA COSTA and DESIGN
Opposition No. 91225944
Serial No. 86606622
Published: January 12, 2016
Mark: LAGUNA COSTA and DESIGN
Cancellation No. 1541125
Registration No. 1541125
Registration Date: May 30, 1989
Mark: LAGUNA
REGISTRANT LAGUNA COSTA LLC'S NOTICE OF EXPERT DISCLOSURES.
In accordance with Rule 26(a)(2) of the Federal Rules of Civil Procedure, Section 401.03
of the Trademark Trial and Appeal Board Manual of Procedure, and the Scheduling Order,
Laguna Costa, LLC ("Laguna Costa") submits notice to the Trademark Trial & Appeal Board
that it has designated its experts to R. Josephs Licensing Inc. ("Josephs Licensing"). In
accordance with the above stated rules, Laguna Costa has provided copies of expert reports to
Josephs Licensing.
A. Identity of Experts
1. Mr. Alex Frakking
Laguna Costa designates the following expert witness to testify on its behalf:
LAGUNA COSTA LLC'S NOTICE OF EXPERT DISCLOSURES Page 1 of3
Mr. Alex Frakking
President
HIT Laboratories Inc.
999 3rd A venue, Unit 700
Seattle, Washington 98104
2. Mr. Alexander Gurevich
Laguna Costa designates the following expert witness to testify on its behalf:
Mr. Alexander Gurevich
Founder & Owner
Final Step Marketing
85 Broad St.
New York, New York 10004
B. Reservation of Rights:
Laguna Costa reserves the right to depose, call at trial in Laguna Costa's case-in-chief,
and/or cross-examine any and all expert witnesses designated by Josephs Licensing, including
rebuttal experts.
Laguna Costa also reserves the right to designate additional expert witnesses whose
testimony cannot be reasonably anticipated at this time, including, but not limited to, expert
witnesses who may provide rebuttal or impeachment testimony, and expert witnesses whose
testimony may be reasonably necessary to address issues unknown or not disclosed to Range at
this time.
To the extent any deposition testimony of any of individual designated herein constitutes
expert testimony, it is expected that the individual will provide testimony concerning the matters
addressed in those depositions. To the extent necessary, the deposition testimony of such
individuals is incorporated by reference herein.
LAGUNA COST A LLC 'S NOTICE OF EXPERT DISCLOSURES Page 2 of3
Respectfully Submitted,
\ . ---"" ,-r- .
ｾ＠ ~ ~ --
Jam~ ｾ＠
Texas State Bar No. 24012958
Email: ikey@hfblaw.com
HARRIS, FINLEY & BOGLE, P.C.
777 Main Street, Suite 1800
Fmi Wmih, Texas 76102
Telephone: 817-870-8700
Fax: 817-333-1182
ATTORNEY FOR APPPLICANT
LAGUNA COSTA, LLC
CERTIFICATE OF SERVICE
This is to ce1iify that a true and c01Tect copy of this document has been served on the
following counsel on this 6th day of December, 2016:
536613.1
Via Email - cohenlaw@coheniplaw.com; timtyson@pacbell.net
& via CMRRR No.
Timothy T. Tyson
LAW OFFICE OF LAWRENCE S. COHEN
1401 Westwood Blvd., Suite 240
Los Angeles, CA 90024-4963
LAGUNA COSTA LLC'S NOTICE OF EXPERT DISCLOSURES Page 3 of3