ESTTA Tracking number: ESTTA1114842 02/16/2021
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Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov ESTTA Tracking number: ESTTA1114842 Filing date: 02/16/2021 IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD Proceeding 91251090 Party Defendant Carl Raymond Amos Correspondence Address CARL AMOS 8710 W HILLSBOROUGH AVE, SUITE 413 TAMPA, FL 33615 UNITED STATES Primary Email: [email protected] 813-426-9359 Submission Other Motions/Submissions Filer's Name Carl Raymond Amos Filer's email [email protected] Signature /Carl R. Amos/ Date 02/16/2021 Attachments Motion for Change of Venue -s.pdf(2554659 bytes )
Transcript of ESTTA Tracking number: ESTTA1114842 02/16/2021
Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
ESTTA Tracking number: ESTTA1114842
Filing date: 02/16/2021
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
Proceeding 91251090
Party DefendantCarl Raymond Amos
CorrespondenceAddress
CARL AMOS8710 W HILLSBOROUGH AVE, SUITE 413TAMPA, FL 33615UNITED STATESPrimary Email: [email protected]
Submission Other Motions/Submissions
Filer's Name Carl Raymond Amos
Filer's email [email protected]
Signature /Carl R. Amos/
Date 02/16/2021
Attachments Motion for Change of Venue -s.pdf(2554659 bytes )
UNITED STATES PATENT AND TRADEMARK OFFICE:
Trademark Trial and Appeal Board
P.O. Box 1451 Alexandria, VA 22313-1451 General Contact Number: 571-272-8500
General Email: [email protected]
Carl Raymond Amos (Carl R. Amos)
Applicant
vs. Opposition no. 91251090
TransAmerica,
Aegnon Netherlands et.al
Opposer
Motion for Change of Venue
The Applicant requests a change of venue to move from the TTAB to United States Federal
Court before the Eastern District of Alexandria, Virginia. Further, the Applicant Amos requests
the move due to the Adjudicated and Denied Opposition case No. 91251090.
Reasons for Transfer are:
� Lack of Proper Venue.
� Registered Architectural Works Copyrights Patents are prohibited defenses.
� Not in TTAB prevue: and beyond its statute and scope and authority.
� Opposer’s actions are reckless mysterious and suspicious.
� Amos is owner of Registered Architectural Works Copyrights for London Shard, Exhibit
A, awarded by USA Copyright Office to Amos and issued patents currently in force.
� Amos famous ‘Mark’ is shown in the Dec 6, 1999, National Science Foundation exhibit
as Carl Amos Exhibit of Glass Building, Exhibit B,
www.ncsa.illinois.edu/People/tcoffin/ACCESS/Amos/Amos09.html.
� Amos’ non-monetary silver and gold precious metal coin trademark is Class 014
whereas the Opposer’s class is 042.
� London Shard verbatim copyright infringement, theft & patent infringement structure built
without Amos’ knowledge or permission from 2009-2012 in London, Britton, UK.
� Amos has losses exceed 6 billion USD that benefits the Qatar State Bank & United
Kingdom.
� The proper venue for Registered Architectural Works Copyrights and its related
Trademark and in force Patents, is in Federal Court for the Eastern District of Virginia.
� December 22, 2020 Opposition No.91251090 Transamerica Corporation vs. Carl Amos.
Before Wellington, Shaw, and Lebow.
Before Wellington, Shaw, and Lebow, Administrative Trademark Judges. By the Board:
We find a genuine dispute of material fact remains as to the similarity of the marks
for purposes of likelihood of confusion and dilution. Additionally, we note that
Opposer does not argue how its goods or services are related to Applicant’s non-
monetary coins or point to evidence for purposes of demonstrating a relationship.
As to the failure to function claim, a genuine dispute remains as to the extent and
manner in which Applicant is currently using his mark on the goods. In its brief,
Opposer argues Applicant’s “expressed intent is to use the claimed mark not as a
trademark but to designate his ownership of the architectural design of the London
Shard.”22However, on the summary judgment record before us, we find a genuine
dispute of material fact remains with respect to Applicant’s intent in using his mark.
Moreover, we cannot conclude that, based on such use identified by Opposer,
consumers will not perceive the mark as a source-identifier for the identified goods,
including non-monetary coins. Accordingly, Opposer’s motion for summary
judgment on its claims of priority and likelihood of confusion, dilution, and failure to
function is denied.
Respectfully submitted,
Carl R. Amos
by_______________________
Date_____02/16/2021_______
The undersigned counsel certifies that on the 16th
day of February 2021, he caused one copy
each of the foregoing Motion for Change of Venue including exhibits in support to be served by
electronic mail, facsimile, and/or overnight mail on the following :
Exhibit A
Exhibit B
