ESTTA Tracking number: ESTTA956107 02/22/2019

Trademark Trial and Appeal Board Electronic Filing System.

ESTTA Tracking number:

Filing date:

Proceeding

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

91230554

Party

Defendant

Aiping Fan

Correspondence

Address

TOMMY SONGFONG WANG

WANG IP LAW GROUP PC

18645 E GALE AVE, SUITE 205

CITY OF INDUSTRY, CA 91748

UNITED STATES

twang@, lfan@

626-269-6753

Submission

Defendant's Notice of Reliance

Filer's Name

Tommy SF Wang

Filer's email

twang@, lfan@

Signature

/s/Tommy SF Wang

Date

02/22/2019

Attachments

First Notice of Reliance_02222019.pdf(1741428 bytes )

ESTTA956107

02/22/2019

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

In the Matter of Trademark Application No.: 86/888,740

For the Mark: Sock It Up

Published on: June 14, 2016

SOCK IT TO ME, INC., an Oregon Corp., )

)

Opposer,

)

)

)

)

v.

)

)

)

AIPING FAN, an individual,

)

)

)

Applicant.

)

)

____________________________________)

Opposition No. 91230554

APPLICANT¡¯S FIRST NOTICE OF RELIANCE

Applicant Aiping Fan hereby makes of record and notifies Opposer Sock It To Me, Inc.

of its reliance of the following dictionary definitions, reference materials and other publications:

Exhibit 5:

Entry for ¡°Sock¡±, Merriam-Webster Dictionary, accessed online at

on February 4, 2019.

Exhibit 6:

Entry for ¡°Suck it up¡±, , accessed online at

,

on February 4, 2019.

Exhibit 7:

Entry for ¡°Suck it up¡±, The Free Dictionary by Farlex, accessed online at

, on February 4, 2019.

Exhibit 8:

Entry for ¡°Suck it up¡±, , accessed online at

, on February 4,

2019.

Exhibit 9:

Entry for ¡°Suck it up¡±, Urban Dictionary, accessed online at

, on

February 4, 2019.

Exhibit 10:

Entry for ¡°Sock it to¡±, , accessed online at

, on February 4, 2019.

Exhibit 11:

Entry for ¡°Sock it to¡±, The Free Dictionary by Farlex, accessed online at

, on February 4, 2019.

Exhibit 12:

Entry for ¡°Sock it to someone¡±, Macmillan Dictionary, accessed online at

, on February 4, 2019.

Exhibit 13:

Entry for ¡°Sock it to¡±, , accessed online at

, on February 4,

2019.

Exhibit 14:

Entry for ¡°Sock it to me,¡± Urban Dictionary, accessed online at



me, on February 4, 2019.

Exhibit 15:

Missy Elliot & Da Brat, Sock It 2 Me Lyrics, accessed online at



accessed online on July 13, 2017.

Exhibit 16:

Mitch Ryder and The Detroit Wheels ¡°Sock It To Me, Baby!¡± Lyrics,

accessed online at



ck_it_to_me_baby.html on July 13, 2017.

These documents are relevant to show there is no likelihood of confusion, including the

dissimilarity of the parties¡¯ respective marks in terms of appearance, sound, meaning and

commercial impression.

Dated: February 22, 2019

WANG IP LAW GROUP, P.C.

By:/s/Leontyne Fan

Tommy SF Wang

Leontyne Fan

Attorneys for Applicant

Aiping Fan

CERTIFICATION OF SERVICE

This is to certify that on February 22, 2019, a copy of the foregoing Applicant¡¯s First

Notice of Reliance was sent via email to following addresses:

Sheila Fox Morrison

Davis Wright Tremaine LLP

1300 S.W. Fifth Avenue, Suite 2400

Portland, OR 97201

Email: sheilafoxmorrison@, pdxtmenforcement@,

stevenklein@, pdxtrademarks@

/s/Leontyne Fan

Leontyne Fan

EXHIBIT 5

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