Ronald Coleman – Archer & Greiner, PC

Belmora LLC v. Bayer Consumer Care AG

Reply Brief for Petitioners on Petition for a Writ of Certiorari to the Fourth Circuit

Issue: Whether Sections 14(3) and 43(a) of the Lanham Act allow a foreign business that has neither used nor registered its trademark in the United States to sue the owner of a U.S. registered trademark for conduct relating to…more
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Lee v. Tam

Brief for Respondent Simon Shiao Tam ("The Slants")

Issue: Whether the disparagement provision of the Lanham Act, 15 U.S.C. 1052(a), which provides that no trademark shall be refused registration on account of its nature unless, inter alia, it “[c]onsists of . . . matter which…more
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Belmora v. Bayer Consumer Care

Petition for a Writ of Certiorari

In Lexmark International Inc. v. Static Control Components, Inc., 134 S. Ct. 1377, 1388-90 (2014), this Court held that the Lanham Act does not extend a cause of action to every plaintiff with Article III standing, but instead…more
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Section 2(a) of the Lanham Act: Trademark’s Law of Unintended Consequences

Paper included as CLE materials at The 26th All Ohio Annual Institute on Intellectual Property (AOAIOIP) in Cleveland and Cincinnati Ohio over two successive days. This paper arose out of research done in connection with our…more
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Yeshiva Gedola Na'os Yaakov, Inc. Et al v. Township of Ocean, NJ et al

Proposed Brief of Agudath Israel of America as Amicus Curiae in Support of Plaintiffs' Motion for a Preliminary Injuncition

Yeshiva Gedola Na’os Yaakov of Lakewood, New Jersey acquired spacious property in Ocean Township, New Jersey and applied to the Township’s Zoning Board for the necessary zoning variances. Elements within the community,…more
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Lee v. Tam

On Petition for a Writ of Certiorari - Brief for Respondent Simon Shiao Tam

Simon Shiao Tam's response to the government's request that the U.S. Supreme Court review the decision in In re Tam, 808 F.3d 1321 (Fed. Cir. 2015), as corrected (Feb 11, 2016). In that case, the United States Court of Appeals…more
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Belmora LLC v Bayer Consumer Care AG, et al.

Belmora v. Bayer - Appellee Belmora's Petition for Rehearing En Banc in the FLANAX Trademark Case

From John Welch's TTABlog: "Belmora LLC yesterday filed a petition for reconsideration en banc [pdf here] of the FLANAX decision issued by the U.S. Court of Appeals for the Fourth Circuit in Belmora LLC v Bayer Consumer Care…more
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LVL XIII Brands, Inc. v. Louis Vuitton Malletier SA et al.

Brief In Opposition to LVL XIII's Motion to Strike Damning Material in LVL XIII's Summary Judgment Submissions

From the Preliminary Statement: "Attempting illegitimately to supplement their summary judgment briefing, defendants Louis Vuitton Malletier SA and Louis Vuitton North America, Inc. (collectively, “Louis Vuitton” or…more
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LVL XIII Brands, Inc. v. Louis Vuitton Malletier SA et al.

Reply Brief In Support of LVL XIII's Summary Judgment Motion for Trademark Infringement

From the Preliminary Statement: "Hewing to the axiom that the best defense is a good offense, in opposing the motion for summary judgment by plaintiff LVL XII Brands, Inc. (“LVL XIII”) defendants Louis Vuitton Malletier SA…more
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In re Simon Shiao Tam

Petition for a Writ of Mandamus

From Reuters: "The Slants, the Asian-American rock band whose challenge to the denial of a trademark on its controversial name prompted a U.S. appeals court to declare a ban on offensive trademarks unconstitutional, asked the…more
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Badia Spices, Inc. v. Gel Spice Company, Inc.

Gel Spice Company's Answer, Affirmative Defenses and Counterclaims to Cancel "COMPLETE SEASONING" Trademark Registrations

Badia Spices, Inc. sued Gel Spice Company on the ground that Gel's private-branded product, "Sazon Complete Mix Seasoning," infringed Badia's registered marks for COMPLETE SEASONING and SAZON COMPLETA. Badia answered and…more
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LVL XIII Brands, Inc. v. LVMH Moet Hennessy Louis Vuitton SA, et al.

LVL XIII's Summary Judgment Brief Against Louis Vuitton for Trademark Infringement

From the Preliminary Statement: Antonio Brown started his company, LVL XIII Brands, Inc. (pronounced “Level 13” in December 2012 on what was, unquestionably, a “shoe string” budget. What he lacked in capital, however, he made…more
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Codename Enterprises (d/b/a Buzzr) v. Fremantlemedia North America, Inc.

Complaint for Infringement of Buzzr.com's Registered BUZZR Trademark

This is a claim for willful trademark infringement by the North American division of one the largest television production companies in the world, Fremantlemedia North America, of plaintiff’s multiple registered trademarks for…more
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LVL XIII Brands, Inc. v. LVMH Moet Hennessy Louis Vuitton SA, et al.

LVL XIII's Brief in Opposition to Louis Vuitton's Motion to Exclude the Expert Testimony of Prof. Charles Colman

Brief in opposition defendant Louis Vuitton's motion to disqualify LVL XIII's expert, fashion law expert Prof. Charles Colman. From the preliminary statement: "Professor Charles E. Colman does not have an MBA. He never…more
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LVL XIII Brands, Inc. v. LVMH Moet Hennessy Louis Vuitton SA, et al.

LVL XIII's Brief in Support of Motion to Exclude Louis Vuitton's Survey Expert

In this case for trademark / trade dress infringement against Louis Vuitton by LVL XIII, the company of footwear designer Antonio Brown, the defendant submitted survey evidence purporting to demonstrate a lack of secondary…more
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