LegalForce v. Trademark Engine (Second Amended Complaint) Filed August 10, 2018

Case 3:17-cv-07303-MMC Document 107 Filed 08/10/18 Page 1 of 28
RAJ V. ABHYANKER, California SBN 233284

Email: raj@legalforcelaw.com
WENSHENG MA, California SBN 299961
Email: vincent@legalforcelaw.com
LEGALFORCE RAPC WORLDWIDE, P.C.

1580 W. El Camino Real, Suite 10
Mountain View, CA 94040
Telephone: (650) 965-8731
Facsimile: (650) 989-2131
Attorneys for Plaintiff,

LegalForce RAPC Worldwide, P.C.
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
LEGALFORCE RAPC WORLDWIDE, Case No.: 3:17-CV-07303-MMC

P.C.,
SECOND AMENDED COMPLAINT FOR:
Plaintiff,
1. DECLARATORY JUDGMENT, 28
v. U.S.C. § 2201;
2. FALSE OR MISLEADING ADVERTISING
TRADEMARK ENGINE LLC;
TRAVIS CRABTREE; and DOES 1-50, 15 U.S.C. § 1125(a);
INCLUSIVE, 3. UNFAIR COMPETITION, CAL. BUS. &
PROF. CODE § 17200, ET SEQ.
Defendants.
JURY TRIAL DEMANDED
1
SECOND AMENDED COMPLAINT
CASE NO.: 3:17-cv-07303-MMC
1. LegalForce RAPC Worldwide, P.C. (“Plaintiff” or “RAPC”) complains and alleges

against defendant Trademark Engine LLC (“TE”) and defendant Travis Crabtree (“Crabtree”)
(collectively “Defendants”) as follows:
NATURE OF ACTION
2. RAPC brings this action to stop TE and Crabtree from misrepresenting the nature and
characteristics of its trademark services by false or misleading advertising, and from unfairly
competing with RAPC by providing the services unlawfully and unfairly. RAPC also brings this
action to recover losses caused by TE and Crabtree’s unlawful and unfair business practices.
3. RAPC and TE compete to provide individuals and small businesses with affordable
access to legal services that allow them to protect their marks through filings with the United
States Patent and Trademark Office (“USPTO”). Both use technology and innovation to provide
these services for hundreds of dollars instead of the thousands of dollars that traditional law
firms charge.
4. But while RAPC innovated within the existing legal framework that protects consumers
from getting bad legal advice, TE and Crabtree employ unscrupulous, unlawful and unfair
practices in its business. TE and Crabtree have gained substantial cost advantage over RAPC
because TE and Crabtree employ non-attorneys to provide legal advice to customers. RAPC
contends that TE and Crabtree’s entire trademark business is built upon the foundation of the
unauthorized practice of law.
THE PARTIES
The Plaintiff
5. RAPC is a law firm wholly owned by Raj Abhyanker, a member in good standing of the
State Bar of California, and the United States Patent Bar. The firm practices patent and
trademark law before the USPTO with a principal place of business located at 1580 W. El
Camino Real, Suite 10, Mountain View, CA 94040, and a law office located at 446 E. Southern
Ave, Tempe, AZ 85282.
The Defendants
6. Trademark Engine LLC is a Delaware corporation with a principal place of business at
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12605 E. Freeway, Suite 540, Houston, TX 77014. It is not a law firm in the United States and
is not authorized to practice law in any state. TE operates website TrademarkEngine.com to
advertise, promote and provide trademark filing related services.
7. Travis Crabtree (“Crabtree”) is an attorney licensed in the state of Texas. He is a
co-founder, minority member and a managing member of Trademark Engine LLC. His principal
place of business is located at 12605 E. Freeway, Suite 540, Houston, TX 77014.
8. DOES 1-50 are entities that participated in the transactions complained of herein in
ways which are unknown to Plaintiff. The true names, capacities, nature, and extent of
participation in the alleged activities by DOES 1-50, inclusive, are unknown to Plaintiff and
therefore Plaintiff sues these defendants by such fictitious names. Plaintiff will amend the
complaint to allege their true names and capacities when ascertained.
JURISDICTION AND VENUE
Subject Matter Jurisdiction
9. This Court has subject matter jurisdiction under federal question (28 U.S.C. § 1331)
because Defendants violated the Lanham Act. This court has supplemental jurisdiction over the
California UCL claim under 28 U.S.C. § 1367 because the UCL claim arises from the same
nucleus of operative facts as the Lanham Act claim.
10. Alternatively, if this Court finds that it has no federal question jurisdiction over the
Lanham Act claim, Plaintiff requests this Court to exercise diversity jurisdiction (28 U.S.C. §
1332) over the California UCL claim because Plaintiff and Defendants are citizens of different
States and the matter in controversy exceeds the sum or value of $75,000, exclusive of interest
and costs.
Personal Jurisdiction
11. This Court has specific personal jurisdiction over Defendants because they have
minimum contacts with the State of California. They purposefully directed their advertisements
or promotions at consumers in California. These activities are intentional acts expressly aimed
at California that are likely to cause harm in California. RAPC’s claims arose out of these
activities and exercising jurisdiction over Defendants would not be unreasonable. Moreover,
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Defendants have waived their objections to personal jurisdiction. See Dkt. 41 at 2.

12. Venue is proper in the Northern District of California under 28 U.S.C. § 1391(b)
because a substantial part of the events or omissions giving rise to this action occurred in this
district. It is convenient for third-party witnesses to testify in this Court to prove the alleged
illegal activities of all defendants. Judges in this district are more familiar with California laws
than in judges in other states. In addition, California has a general policy interest in protecting
residents harmed by violations of California law by out-of-state actors such as Defendants.
Moreover, Defendants have waived their objections to improper venue by not raising the
objections in their first Rule 12 response. See Dkt. 41.
FACTUAL ALLEGATIONS
I. TE’s False And Misleading Statements
13. The Lanham Act, 15 U.S.C. § 1125(a)(1)(B), prohibits any person from using false or
misleading statements to misrepresent the nature or qualities of his services in commercial
advertising or promotion. TE violated the Lanham Act by making the following false and/or
misleading statements on its website.
A. Using the word “professional” to represent the nature of TE’s services
14. TE uses the word “professional” in at least two advertising statements to misrepresent
the nature and quality of its trademark filing services. Apparently, TE attempts to use
“professional” to represent that the service is provided by its staff who are “conforming to the
technical or ethical standards of a profession.”1 As alleged in sections III and IV below, since
TE’s trademark filing services are unlawful, using the word “professional” to represent the
nature of the services is both false and misleading.
15. Statement #1: “Let the Professionals File Your Trademark Today!” is one of TE’s
xhibit A. When a potential customer types “trademark
advertising statements on Google. See E
filing” in Google’s search bar, the advertisement would appear at the second paid position in the
search result. See Id. The Google search pages presented in this exhibit were recorded on
December 24, 2017.
1
efinition of “professional” by Merriam-Webster: https://www.merriam-webster.com/
See
D
dictionary/professional.
4
16. In addition, since August 2016, Statement #1 has been appearing in at least 270 different
advertisements purchased by TE on Google. A sample of these Google advertisements are
shown in Exhibit B. For better illustration, some of the Google advertisements are shown
below:
17. Statement #2: “Professional Preparation of your federal trademark application” is one
of TE’s promotional statements on its webpage http://www.trademarkengine.com/pricing/
trademark-registration-packages. See below and Exhibit C at 2. This webpage compares
different services provided by TE’s different level of packages. As shown on the page,
“professional preparation” of clients federal trademark application is provided by all three levels
of service package. The pages presented in this exhibit were recorded on August 8, 2018.
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18. Using the word “professional” in Statements #1 and #2 to represent the nature of TE’s
trademark filing services is literally false.
19. No unlawful service can be called a “lawful” service. As such, using the word “lawful”
to describe an unlawful service, e.g., a service arranging fake-marriages to obtain green cards in
violation of immigration laws, would be literally false. Likewise, no unlawful service can be
called a “professional” service. Thus, using the word “professional” to describe the
fake-marriage arranging service would be literally false. Therefore, it follows logically that
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using the word “professional” to describe TE’s unlawful services, which are provided in
ections III and IV, infra ( alleging
violation of federal and state laws, is also literally false. See S
TE’s services are unlawful).
20. RAPC does not allege that the word “professional” is being used to represent that TE
has better experience or service quality than others, and because TE turns out to have less
experience or poor service quality, the word “professional” is false or misleading. The use of
“professional” in that sense would be merely an opinion or nonactionable puffery, as the Court
has pointed out.2
21. Instead, RAPC alleges that using the word “professional” to describe a service is a
guarantee of at least one thing—that the service is at least a lawful service—for no unlawful
service can be called a “professional” service. In this sense, “professional” becomes a statement
of fact with a guarantee that the service is lawful. When the service is in fact not lawful, as
RAPC alleges, using the word “professional” to represent the nature of that service is literally
false.
22. Using the word “professional” in Statements #1 and #2 to represent the nature of TE’s
trademark filing services is also misleading.
23. Using the word “professional” in these statements has actually misled or confused the
consuming public, including actual TE customers, into believing that TE provides at least
lawful services.
xhibit D),
24. Out of the eighty (80) actual TE customers who were harmed by TE (see E
many of them were actually misled by TE’s use of the word “professional” into believing that
TE provides at least lawful services. These customers have agreed to serve as witnesses for
Plaintiffs. Some notable facts from these customers are listed below:
a. Customer #4 confirmed that he thought TE was providing a lawful service.
b. Customer #8 “absolutely” believed that TE provides at least a lawful service.
2
See ase No. 3:18-cv-00127-MMC, Dkt. 42 at pgs 7-8.
C
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c. Customer #9 confirmed to Plaintiff’s counsel that when she saw TE claiming on

their website that they are professionals, she “absolutely” believed they were
providing a lawful service.
d. Customer #11 “did assume [TE] were using professional and providing a lawful
service [sic] as per their website description.”
e. Customers #13, #21, #27, #34, #40, #41, #44, #45 and #46 believed that TE were
providing a lawful service when they saw TE claiming on their website that they
are “professionals”.
f. Customers #31, #32, #33, #35, #38, #39, #54, #56 and #58 confirmed to
Plaintiff’s counsel that TE’s advertising led them to believe that, among other
things, TE was at least providing a lawful service.
25. As RAPC alleges that TE’s service is not lawful, see Sections III and IV, infra, using
Statements #1 and #2 to represent the nature of TE’s service is misleading because the
statements have actually misled TE customers into believing that TE is at least providing a
lawful service.
B. Statements about the privacy/identity protection program
26. TE made the following upsell statements to paid customers of TE during the workflow
of filing their trademark applications:
a. Statement #3: “Protect your Identity - Identity Protection Program”;
b. Statement #4: “With our Trademark Privacy Protection program, the public will see
our email and phone number rather than yours”;
c. Statement #5: “Yes, I want to keep my information private ( $5/month) Highly
Recommended”.
27. These statements appear in Exhibit E and are shown below for better illustration.
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28. At least since August 2017, these statements have been shown to paid customers of TE
in the upsell page towards the end of the trademark filing workflow, e.g., at 97% completion as
shown above. TE customers are encouraged to select “Yes, I want to keep my information
private ( $5/month) Highly Recommended”. When TE customers select this service, they will
be charged $5 per month for the purported service of protecting their privacy.
29. Using Statements #3, #4 and #5 to represent the nature and quality of TE’s
privacy/identity protection program is literally false.
30. The statements are literally false because, regardless of whether a customer purchased
the $5/month privacy protection program or not, TE always lists each of its customer’s contact
information, including emails and phone numbers, on USPTO’s trademark application forms.
As information of trademark applicant’s contact information is public on USPTO’s website, TE
does not protect the privacy of its customers who purchased the privacy protection program.
31. The following customers of TE (listed in Exhibit D) actually purchased the privacy
protection program by clicking “Yes, I want to keep my information private ( $5/month) Highly
Recommended”:
a. Customer #5 paid $5 a month to protect his privacy and is still paying for that
service.
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b. Customers #7, #49, #56, #58 and #61 signed up for the privacy protection
program.
c. Customers #31, #32, #33 and #44 paid $5 a month to protect their privacy. They
are upset that their private information has been published on USPTO public
forms.
d. Customer #47 called and confirmed to Plaintiff’s counsel that he purchased the $5
a month trademark privacy service from TE and feels victimized that his private
information has been published.
32. None of the above paid customers’ privacy information were protected by TE. Their
information are publically available on USPTO’s website. Thus, TE’s upsell Statements #3, #4
and #5 are literally false.
33. Using Statements #3, #4 and #5 to represent the nature and quality of TE’s
privacy/identity protection program is also misleading.
34. The TE customers listed above who purchased the privacy protection program were
actually misled by the statements. Clicking on Statement #5 on the upsell page (Exhibit E),
which also contains Statements #3 and #4, is the only way to purchase the program. No one
would spend $5 per month on this program unless they were made to believe from the
statements that their privacy information would be protected by TE.
35. Furthermore, Customer #12 confirmed to Plaintiff's counsel that “I purchased the
privacy protection Service. I believed my information would be kept private.” As clicking
through the upsell page is the only way to purchase the program, Customer #12, along with
other customers alleged above, were actually misled by these statements.
II. Liability of Crabtree for TE’s Lanham Act Violation
36. Crabtree, as an officer of TE and a managing member of the LLC, authorized, directed
or participated in TE’s Lanham Act violation alleged above. Therefore, Crabtree is liable for the
Lanham Act violation committed by TE.
37. Facts from the interview of a TE’s ex-employee further demonstrates that Crabtree, as
the co-founder who started the business of TE, actively manages the daily operations of TE. See
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Exhibit F, e.g., “[Crabtree]’s in the process of kind of branching off and doing his own thing ...
he started a web engine, called Trademark Engines…” Id. at 4:13; “At the time he started the
company…” Id. at 4:15; “[Crabtree] kind of let other people do [the common law searches]...”
Id. at 5:7; “before I submitted anything, it had to go to [Crabtree] first.” Id. a t 7:6.
38. Thus, because advertising and promotion is key to a company’s operation, upon
information and belief, Crabtree authorized, directed or participated in the design and
advertising of the five false and misleading statements alleged above. As such, Crabtree is
personally liable for the Lanham Act violation committed by TE.
III. The Unlawful Practices of TE
A. TE’s practice violates the unauthorized practice of law
39. TE’s practice violates California and Texas state statutes which prohibit the
unauthorized practice of law. Cal Bus. & Prof. Code § 6125 provides that “[n]o person shall
practice law in California unless the person is an active member of the State Bar.” Under Texas
law, a person may not practice law unless the person is a member of the Texas state bar. Tex.
Gov’t Code § 81.102. Falsely holding oneself out as a lawyer with the intent to obtain an
economic benefit is a felony of the third degree. Tex. Pen. Code § 38.122.
40. The USPTO defines the practice of law to include the following3:
a. Consulting with or giving advice to an applicant or registrant in contemplation of
filing a trademark application or application-related document;
b. Preparing or prosecuting an application, response, post-registration maintenance
document, or other related document;
c. Advising applicants on proper responses to USPTO actions;
d. Conducting pre-filing searches for potentially conflicting trademarks;
e. Analyzing or pre-approving documents before filing; and
3
See
https://www.uspto.gov/trademark/trademark-updates-and-announcements/warning-unauthorized-
lawpractice; and
https://www.uspto.gov/learning-and-resources/support-centers/trademark-assistance-center.
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f. Advising applicants on substantive examination issues, such as the acceptability

of specimens and classification of goods and services.
41. TE, a non-legal entity and a nonlawyer, unlawfully practices law by engaging in
following conducts: performing pre-filing trademark searches; creating and reviewing
trademark applications; making legal determinations about classification and other matters;
advising clients on problems with their applications including recommending changes to
classifications and descriptions of goods and services; and filing trademark applications on
clients’ behalf.
42. The facts alleged below further demonstrates that TE has committed the unauthorized
practice of law as defined by USPTO.
1. TE modifies client’s original description and classification of trademark
43. TE analizes client’s original description and classification of trademark which client
initially submitted to TE for review, advises client on how to modify the description and
classification, and pre-prove the trademark application before filing.
44. TE’s practice is demonstrated by the following facts from a recent EVEREST CLAY
REALTORS trademark application submitted by Raj Abhyanker (“Abhyanker”) via TE’s
website:
a. In a chat session, a TE staff named Jake suggested a different class 36 and a
modified description of goods and services to Abhyanker.
b. In an email to Abhyanker on December 13, 2017, TE’s staff modified the goods
and description of EVEREST CLAY REALTORS provided by Raj Abhyanker
from:
Everest Clay is a real estate brokerage in California that will also do
property management and create a website to help them find their real
house as well as find their own real estate investments. We will also
self manage my properties[,]
to:
Real estate brokerage; Real estate service, namely, rental property
management; Providing an internet website portal offering information
in the field of real estate concerning the purchase and sale of new and
resale homes and condos; Real estate investment services; Real estate
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investment services in the nature of purchasing and selling of real

estate for others; Financial investment in the field of {real estate};
Real estate management services.
45. TE’s practice is further demonstrated by the following facts from actual customers of TE
(listed in Exhibit D).
a. After Customer #7 submitted his/her original classification and description to TE,
TE emailed him/her to suggest a modified description and class that were
different from his/her original submission. TE’s staff wrote the following in the
email:
The description of goods you provided is deficient and may create
delays or rejections by the USPTO because it is too general as it is
now. For example, a trademark application with a class description of
“Clothing” will be rejected by the USPTO for being too general. A
better description would be “Clothing, namely, pants, shirts, shorts,
and shoes.” Likewise, you cannot simply state that you plan on selling
products in certain industry; you need to describe what kinds of
products.
See Exhibit D at 3 (“Deficient Description of Goods”).
b. TE suggested Customer #19 to change the classification of his mark from class
003 to 035 and he agreed to the suggestion. But later he found out that his
trademark was in the wrong class.
c. TE amended or suggested amending the description and classification for
Customers #4, #5, #18, #26, #27, #31, #32, #33, #40, #41, #42, #44, #46, #48,
#56, #59, #60 and #61.
d. TE modified the original description submitted by Customer #37 but kept the
classification she originally selected.
e. Astonishingly, TE sent Customer #41 a detailed email on October 30, 2017 which
provides him with in-depth legal advice on the description of goods and services.
See Exhibit D at 11 (“We Have a Question About Your Description of Goods or
Services”).
f. Customer #46 wrote to the Plaintiff’s counsel that not only did TE assist him in
selecting classification and adjusting his goods and services, “[they] spent a
13
month trying to determine the classification.” See Id. a t 13.

2. TE searches and advises potential conflicting trademarks
46. The following facts demonstrate that TE performs pre-filing searches for potential
conflicting trademarks and advises clients of the conflict and possible solutions.
a. During the EVEREST CLAY REALTORS trademark application process, TE
prepared Abhyanker a search report of trademarks that may conflict with
EVEREST CLAY REALTORS .
b. Customer #37 was advised by TE that her trademark name was not in conflict
xhibit D at 9.
with a construction company. See E
c. After pre-filing search for potentially conflicting trademarks, TE advised
Customer #41 that “we have found an exact match for the mark you are
attempting to trademark.” Exhibit D at 10 (“Direct-hit Located”). TE further
advised him that “[j]ust because there is an exact match, it does not mean that you
cannot also register your name if it is in a different category.” Id. at 10.
B. TE’s practice violates Article One of California State Constitution
47. Cal. Const., art. I, § 1 provides that “[a]ll people are by nature free and independent and
have inalienable rights. Among these are enjoying and defending life and liberty, acquiring,
possessing, and protecting property, and pursuing and obtaining safety, happiness, and privacy.”
48. TE unilaterally waives client’s right to privacy when its staff, without clients’
knowledge, agreed to the following while submitting trademark applications for clients on
USPTO’s website: (1) waiving clients’ rights to cancel the filing or refund the government fee;
(2) waiving clients’ rights to privacy by allowing their names, phone numbers, emails and street
addresses to be published publicly; and (3) permitting USPTO to make clients’ information
available for public search on USPTO’s online databases and other online databases. See
Exhibit G.
49. For better illustration, the USPTO’s trademark application submission form clearly
states the following:
STEP 3: Read and check the following:
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Important Notice:
(1) Once you submit this application, we will not cancel the filing or refund
your fee. The fee is a processing fee, which we do not refund even if we
cannot issue a registration after our substantive review. This is true regardless
of how soon after submission you might attempt to request cancellation of the
filing.
Therefore, please review ALL information carefully prior to transmission.
(2) All information you submit to the USPTO at any point in the application
and/or registration process will become public record, including your name,
phone number, e-mail address, and street address. By filing this application,
you acknowledge that YOU HAVE NO RIGHT TO CONFIDENTIALITY in
the information disclosed. The public will be able to view this information in
the USPTO’s on-line databases and through internet search engines and other
on-line databases. This information will remain public even if the application
is later abandoned or any resulting registration is surrendered, cancelled, or
expired. To maintain confidentiality of banking or credit card information,
only enter payment information in the secure portion of the site after
validating your form. For any information that may be subject to copyright
protection, by submitting it to the USPTO, the filer is representing that he or
she has the authority to grant, and is granting, the USPTO permission to make
the information available in its on-line database and in copies of the
application or registration record.
(3) Be aware that private companies not associated with the USPTO often use
trademark application and registration information from the USPTO's
databases to mail or e-mail trademark-related solicitations (samples of
non-USPTO solicitations included).
If you have read and understand the above notice, please check the box before
you click on the Pay/Submit button.
50. TE Customers #2, #4, #5, #31, #32, #33, #34, #35, #39, #44, #45, #46, #47, #48, #49,
#54, #56, #57, #60 and #61 stated that they were not aware or informed by TE that their rights
xhibit D. Thus, TE’s practice violates Article One of
to privacy would be waived by TE. See E
California State Constitution.
C. TE’s practice violates 18 U.S.C. § 1001
51. Third, TE’s practice violates 18 U.S.C. § 1001 which generally prohibits knowingly and
willfully making false or fraudulent statements, or concealing information, in “any matter
within the jurisdiction” of the United States. Violation of 18 U.S.C. 1001 carries a maximum
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penalty of 5 years.4
52. A preliminary search of public data reveals that TE has been submitting or aiding and
abetting its customers in submitting fraudulent specimens to the USPTO.5 These fraudulent
specimens include fabricated proofs of use submitted to the USPTO on behalf of customers of
TE. See Exhibit H, Declaration Of Randall Hull In Support Of Plaintiff’s Second Amended
Complaint.
IV. The Unlawful Practices of Crabtree
53. A lawyer can practice law by himself personally, or practice law in a law firm. But a
lawyer cannot practice law behind a non-legal corporation or LLC. As an officer and a
managing member of TE, a non-legal LLC, Crabtree personally violates Cal Bus. & Prof. Code
§ 6125, Tex. Gov’t Code § 81.102 and Tex. Pen. Code § 38.122 by aiding and abetting TE to
practice law.
54. Facts from the interview of the TE’s ex-employee demonstrate that Crabtree covertly
practiced law behind the LLC. See, e.g., the facts below.
a. The non-lawyer assistant “select[ed] the class that was close to or exactly” related
to the goods and services offered by the customer. Exhibit F at 5:14;
b. Mr. Crabtree “normally answered any type of Office Actions” from USPTO. Id.
at 5:19.
c. Before the non-lawyer assistant submitted anything to USPTO, “it had to go to
[Mr. Crabtree] first.” Id. at 7:6.
55. Furthermore, as an officer and a managing member of TE who actively manages the
daily operations of TE, Crabtree either directly submitted or aided and abetted TE to submit
fake and fraudulent specimens to the USPTO, thereby violating 18 U.S.C. § 1001 himself
personally.
4
also Nationstar Mortg. LLC v. Mujahid Ahmad, 2014 TTAB LEXIS 350, *9 (Trademark
See
Trial & App. Bd. Sep. 30, 2014) (“Fraud in procuring a trademark registration occurs when an
applicant knowingly makes false, material representations of fact in connection with its
application with intent to deceive the USPTO.”).
5
See the following fake specimens submitted by TE for its customers: 87819123, 87787183,
and 87817340.
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56. Moreover, Crabtree, as a trademark practitioner before the USPTO, also violated the
following federal regulations:
a. Crabtree violated 37 C.F.R. § 11.104(a)(2) by failing to reasonably consult with
clients about the means by which the clients’ objectives are to be accomplished
because TE customers’ rights to privacy were waived without their knowledge.
b. Crabtree violated 37 C.F.R. § 11.503(b) by failing to make reasonable efforts to
ensure that the conduct of his non-practitioner assistants at TE (e.g., J ake) is
compatible with the professional obligations. Crabtree violated this federal
regulation because Jake and other non-practitioner assistants at TE have engaged
in the unauthorized practice of law.
c. Upon information and belief, Crabtree violated 37 C.F.R. §§ 11.107 and 11.109
by failing to check conflict of interest among his current and former clients prior
to retaining new clients for TE.
d. Upon information and belief, Crabtree violated 37 C.F.R. § 11.115(c) by failing to
deposit legal fees and expenses paid in advance by his customers into a client trust
account.
V. RAPC’s Lawful and Innovative Practice
57. RAPC also offers trademark filing services for $199 plus government filing fees through
LegalForce, Inc.’s Trademarkia.com website. Unlike TE, RAPC is a law firm.
58. Like TE, RAPC’s $199 service provides clients with legal advice and representation in
the prosecution of a trademark application. But unlike TE, RAPC’s service is
attorney-supervised. An attorney is involved in all critical steps of the application process. A
licensed attorney personally signs off on each filing.
59. RAPC has accomplished its mission by innovating within the bounds of the regulations
governing the legal profession:
APC has developed its own platform
a. Client/Matter Management Technology. R
for client and matter management that automates many processes, detects and
corrects errors through artificial intelligence, streamlines the work flow, and
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focuses attorney attention on only attorney tasks. USPTO uses similar but perhaps
even less advanced technology to manage its process.
b. Volume. With over 400 new trademark clients a month, RAPC attorneys spend all
of their time doing the same types of tasks--which not only develops their
expertise, but makes them more efficient. Five of the top ten most successful
filers ranked by the 2017 World Trademark Review industry publication are
RAPC attorneys.
APC applied best manufacturing
c. Bifurcated Supply Chain Management. R
practices to legal services by taking all non-attorney work off of attorneys’ plates
and globalizing it to improve quality while reducing costs.
d. Training. RAPC attorneys undergo a three-month intensive training process
modeled after the USPTO examiner training program to ensure they are proficient
and efficient trademark attorneys.
VI. The Unfair Competition By TE and Crabtree
60. As explained above, RAPC provides superior technology, is more innovative, and
provides more qualified, higher quality services than TE at the same price. But it is losing the
battle because it is being fought on uneven playing field: RAPC and its attorneys are bound by
the rules of conduct governing the legal profession. TE has eschewed those rules by thus far
operating outside of the existing regulatory framework. Many of those rules protect consumers:
they ensure competence and loyalty and provide remedies when those duties are violated.
61. TE purports to operate outside those duties and disclaims them in its terms of use and
other fine-print disclaimers on its site. Consumers are worse off because they don’t get the
protections they expect from the legal profession. For example, the following are statements on
TE:
a. Our customer service representatives cannot answer legal questions and
because we do not have an attorney-client relationship, any
communications with our customer service representatives are not
privileged and you should not share confidential information with them.
18
b. At no time do we review your answers for legal sufficiency, draw legal

conclusions, provide legal advice, opinions or recommendations about your
legal rights, remedies, defenses, options, selection of forms, or strategies,
or apply the law to the facts of your particular situation.
c. TE is not a "lawyer referral service" and does not provide legal advice or
participate in any legal representation. Use of TE is subject to our Terms of
Service and Privacy Policy.
d. We are not a substitute for an attorney and we cannot provide you any legal
advice.
62. Terms require the use of arbitration on an individual basis to resolve disputes, rather
than jury trials or class actions, and also limit the remedies available to in the event of a dispute.
By renouncing the attorney-client relationship and purporting to provide legal help by
professionals rather than legal advice, TE achieves two business advantages at the expense of
consumers: (1) sidestepping professional responsibilities governing the legal profession and (2)
avoiding liability.
63. In short, TE touts its experience and expertise in helping people with legal problems.
But in the fine print, TE seeks to avoid the responsibilities of law practice by characterizing its
services as self-help and maintaining that the website cannot substitute for an attorney,
regardless of the contrary assumptions of consumers that are reinforced by TE’s promotional
statements. Despite this, if taken at face value, TE’s disclaimer and terms of use allow it to
operate free from the confines of ethical rules enforceable upon attorneys while denying
consumers redress that they would otherwise have for the faulty legal advice it provides.
64. TE’s false and misleading promotional statements deceive consumers into purchasing
inferior services, but its success in exploiting advantages by not operating as a law firm --
despite surreptitiously practicing law -- have also given it a broader competitive advantage:
a. TE professionals are cheaper labor: they make about $14 an hour, when compared
with a $67,000 median starting salary for a licensed attorney at a law firm with
fewer than 25 employees (larger firms have even higher starting salaries)
19
including at RAPC.
b. TE does not expend time or money on conflict checks, does not forego clients
with conflicts, and as a result and can simultaneously assist direct competitors and
adversaries in litigation from filing trademarks for the same or confusingly similar
trademarks at any time.
c. TE does not have the limitations, expense, and administrative burden of trust
accounts, reporting, continuing legal education, bar fees, malpractice insurance,
and other regulatory burdens imposed on lawyers and law firms. As a result, they
are able to better regulate their cash flow cycles to meet short term expenses by
not having client funds for trademark filings for which work has not started
locked away in an IOLTA trust account.
d. TE does not have the limitations, expense, and administrative burden of ethics
compliance audits, regular consultation with outside ethics counsel, and vigilant
adherence to rules governing lawyers.
e. TE does not have the limitations of not splitting legal service fees for trademark
filings and prosecution with non-attorneys, giving them new ways of hiring and
incentivizing non-lawyer staff through commissions, bonuses, and incentives for
the sale of U.S. trademark filing and prosecution services by customers of TE, and
such incentives cannot be offered by lawyers and law firms including RAPC.
f. TE does not have the limitations, expense, and administrative burden of
supervising non-attorney work using licensed lawyers. As a result, its legal staff
are able to have unregulated reign on counseling customers on U.S. trademark
filing and prosecution matters without oversight by a regulated professional.
g. TE do not face the expense and burden of responding to regulatory inquiries,
requests for information, and investigations from the Bar and USPTO’s OED
(even where no action has ultimately been taken), or face exclusion and reciprocal
discipline.
h. TE are not disciplined for incentivizing its non-attorney employees such as
20
Lubbat through ownership in an entity that directly gains revenue from U.S.
trademark filing. By subverting the restriction on non-lawyer ownership of law
firms, TE are able to provide non-attorney employees with stock option and
Restricted stock units (RSUs) incentives for employees. Such incentives are
unavailable to lawyers and law firms including RAPC making it difficult for it to
compete for talented non-attorney labor.
i. Institutional investors are able to purchase equity in TE giving the company
capital required to grow and invest in capital assets at a rate faster than RAPC,
making it difficult to compete.
j. TE disclaim responsibility for the consequences of the professional legal help it
gives, while lawyers must maintain malpractice insurance and exercise caution
and diligence to avoid even the appearance of impropriety or incompetence that
could lead to a malpractice action or a bar/OED investigation.
65. It is thus important that TE is enjoined and held accountable for its false and
misleading promotions and unfair competitions as described herein.
66. As a result of Defendants’ false and misleading advertisement and unfair competition,
RAPC has suffered lost revenue, loss of market share, reduced asset value, diverted sales to TE,
and increased advertising costs.
67. RAPC has lost revenue in two ways: First, TE’s false advertising and unfair competition
have caused consumers to purchase TE’s services instead of RAPC’s services. Second, TE’s
operation outside the law firm regulatory framework has allowed it to raise capital that RAPC
cannot. As a result, RAPC lost significant competitive bidding opportunities on approximately
$1.4 million dollars of advertising spend in the year 2017 alone to TE. RAPC has reduced its
trademark legal service prices from $499 to $199 and sometimes even $69 to match the unfair
competition of TE.
68. But for TE’s conduct of false advertising and unfair competition, a good percentage of
consumers likely would have purchased RAPC’s trademark filing services, not TE’s. In total,
RAPC’s lost sales and opportunities exceeding $3,000,000 dollars based on the lifetime value
21
per customer.
69. RAPC has also lost asset value. It has seen its market share decline from nearly 2.4% of
all U.S. trademarks filed in the United States in 2015 to approximately 1.8% in 2017. As a
consequence of TE’ unfair competition, RAPC has lost market share of approximately 0.6% of
the overall trademark market since 2015 (approximately 2670 trademarks filings per year) in the
relevant market for U.S. trademark filing and prosecution, upon information and belief.
Tellingly, RAPC ceased making the INC5000 list of the fastest growing companies in America
in 2015 after four consecutive years of making the list. See
https://www.inc.com/profile/legalforce-rapc. The value of RAPC’s business has been directly
reduced and negotiations with potential acquirers have stalled.
70. Moreover, upon information and belief, RAPC’s advertising costs have increased.
RAPC’s cost per click and total advertising attract trademark clients has gone up by
approximately 10% as a direct consequence of TE’ unfair competition. In addition, as a direct
consequence of TE’ wrongful acts, upon information and belief, RAPC has reduced their
attorney led service prices from $499 to $199 and sometimes lower to match the unfair
competition from TE.
71. Defendants’ conduct of false and misleading advertising and unfair competition
proximately caused RAPC’s injury. Defendants, along with about a dozen other unauthorized
trademark online filers, advertise through Google and other online marketplaces where RAPC
also advertises. They purchase the same or similar advertising keywords which RAPC also
purchases. If Defendants do not engage in the alleged conduct, e.g., unauthorized practice of
law, in the advertisement they would have to significantly limit the scope of their service to the
point which there is not much value-added service. They can simply fill out forms and but
cannot provide any filing related legal advice to customers, such as suggesting and modifying
descriptions and classifications. Because RAPC provides full-scale trademark legal service and
so advertises in its ads, potential trademark service customers, comparing the advertisement of
both RAPC and Defendants, would have chosen RAPC instead of Defendants. Therefore,
Defendants take away potential sales from RAPC and proximately caused injury to RAPC.
22
72. In addition to the theory of proximate causation alleged above, Defendants’ conduct also
proximately caused RAPC’s injury on alternative theories of causation. “If a plaintiff can prove
that an entire industry was tortious, the doctrine of enterprise liability shifts the burden to
members of that industry to prove that they did not [] caused the injury.” Barron v.
Martin-Marietta Corp., 868 F. Supp. 1203, 1208 (N.D. Cal. Nov. 2, 1994) (citation omitted).
Moreover, “[u]nder the doctrine of market share liability, where it is impossible for the plaintiff
to prove which member of the market was responsible for the injury, each member of the
market is responsible for a percentage of the recovery matching its share of the market.” Id.
(citation omitted).
VII. Substantial Consumer Harm
73. TE and Crabtree have caused substantial harm to consumers because of their unfair
competition and unlawful practices. Listed in Exhibit D is a small sample of TE customers (full
names, serial numbers, and contact information can be submitted under seal and have already
been provided to Defendants counsel prior to the filing of this SAC) who have been misled by
Defendants’ advertising and/or harmed by Defendants’ unlawful and unfair practices. All have
agreed to be witnesses for Plaintiff.
FIRST CLAIM FOR RELIEF
DECLARATORY JUDGMENT
(Against TE and DOES 1-50)
74. RAPC repeats each and every allegations contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
75. An actual controversy has arisen and now exists between RAPC and TE regarding TE’s
false advertising and unfair business practices, which necessarily requires a foundational
determination as to whether TE has engaged in the unauthorized practice of law.
76. RAPC’s injury is fairly traceable to TE’s conduct of unauthorized practice of law.
Because TE, as a nonlawyer, unlawfully practices law, TE can perform all the legal services that
a trademark law firm such as RAPC can perform, but at a price and business expense much
lower than a law firm. Therefore, TE unfaily competes with RAPC and causes RAPC’s injury.
77. RAPC’s injury will be redressed by the Court’s declaration addressing the question of
23
whether TE is engaged in the unauthorized practice of law. If the answer to this question is
affirmative, then TE can no longer provide trademark related legal services and RAPC will be
able to redress its injuries and fairly compete with TE.
78. Wherefore, RAPC seeks a declaration from this Court that TE’s trademark filing
services, specially the practices and facts alleged in Section III.A, violate Cal Bus. & Prof. Code
§ 6125, Tex. Gov’t Code § 81.102 or Tex. Pen. Code § 38.122.
SECOND CLAIM FOR RELIEF
FALSE OR MISLEADING ADVERTISING
THE LANHAM ACT, 15 U.S.C. § 1125(a)
(Against TE, Crabtree and DOES 1-50)
80. TE violated 15 U.S.C. § 1125(a) by making false and misleading advertising Statements
#1 to #5 as alleged supra in Sections I.
81. Crabtree violated 15 U.S.C. § 1125(a) because he is personally liable as alleged supra in
Sections II.
82. Statements #1 to #5 are commercial advertisements or promotions because:
a. They were designed to promote the services of TE;
b. They propose commercial transactions, including but not limited to the purchase
xhibit B;
of TE’s $69 “basic package” trademark filing service. See E
c. They promote TE’ commercial activities;
d. They were motivated by TE’ economic interests; and
e. The statements were sufficiently disseminated to the relevant purchasing public,
namely consumers seeking trademark protection assistance.
83. The statements were made in connection with services offered by TE. The statements
relate to descriptions or representations of fact that misrepresent the nature, characteristics, and
quality of TE’s services.
84. Defendants’ false or misleading advertisements have caused and, unless enjoined, will
continue to cause immediate and irreparable harm to RAPC’s for which there is no adequate
24
remedy at law. In addition, as a result of Defendants’ false advertisements, RAPC has been
injured, including but not limited to, lost customers, direct diversion of sales from RAPC to
Defendants, decline in sales and market share, lost profits, having to pay increased advertising
costs, loss of goodwill, and additional losses and damages. Furthermore, Defendants have been
unjustly enriched at the expense of RAPC as a consequence of Defendants’ false and misleading
advertising. Accordingly, RAPC is entitled to injunctive relief and to recover up to three times
the damages sustained by RAPC, as well as Defendants’ profits, and reasonable attorney fees
under 15 U.S.C. §§ 1114, 1116, and 1117.
THIRD CLAIM FOR RELIEF
CALIFORNIA UNFAIR COMPETITION
CAL. BUS. & PROF. CODE § 17200 ET SEQ.
(Against TE, Crabtree and DOES 1-50)
86. RAPC has standing to sue because it has suffered injury in fact and lost money,
including diverted sales to Defendants, lost revenue, loss of market share, reduced asset value,
and increased advertising costs.
87. TE violated the unlawful prong of UCL because of the following reasons:
a. TE violated Cal Bus. & Prof. Code § 6125, Tex. Gov’t Code § 81.102 and Tex.
Pen. Code § 38.122 as alleged supra in Section III.A.
b. TE violated Cal. Const., art. I, § 1 as alleged supra in Section III.B.
c. TE violated 18 U.S.C. § 1001 as alleged supra in Section III.C.
88. Crabtree violated the unlawful prong of UCL because of the following reasons:
a. Crabtree violated Cal Bus. & Prof. Code § 6125, Tex. Gov’t Code § 81.102 and
Tex. Pen. Code § 38.122 as alleged supra i n Section IV.
b. Crabtree violated 18 U.S.C. § 1001 as alleged supra.
c. Crabtree violated the following federal regulations as alleged supra: 37 C.F.R. §
11.104(a)(2), 37 C.F.R. § 11.503(b), 37 C.F.R. §§ 11.107 and 11.109, and 37
C.F.R. § 11.115(c).
25
89. TE and Crabtree have violated the unfair prong of UCL because of the following
reasons:
a. The consumer injury caused by submitting fraudulent specimens to the USPTO
and violations of unauthorized practice of law and various other state and federal
statutes is substantial. Consumers become susceptible to the risk of bad legal
advice dispensed by unlicensed, un-trained, and uninformed non-lawyers. Public
interest is greatly harmed. See supra Section VII “Substantial Consumer Harm”.
b. Unauthorized practice of law and submitting fraudulent specimens to the USPTO
offer no countervailing benefits to consumers or competition.
c. Consumers themselves cannot reasonably have avoided the injury because a
reasonable consumer (1) is not familiar with the trademark filing process and does
not understand what constitutes the practice of law in the process; and (2) does
not understand that unauthorized practice of law is a crime under California and
Texas laws.
d. It is unfair to the competition for trademark filing related services generally if
Defendants are able to offer trademark filing services unlawfully by violating
state and federal laws and regulations, while the vast majority of attorneys
practicing before the USPTO abide by the laws and regulations.
90. RAPC is informed and believe that TE, as a competitor to RAPC, performed the acts
alleged herein for the purpose of injuring RAPC and competition generally. The acts alleged
herein continue to this day and present a threat to RAPC, the general public, the trade and
consumers.
91. As a result of TE and Crabtree’s wrongful acts, RAPC has suffered and will continue to
suffer loss of millions of dollars of income, profits and valuable business opportunities and if
not preliminarily or permanently enjoined, Defendants will have unfairly derived and will
continue to derive income, profits and business opportunities as a result of its wrongful acts.
26
92. RAPC seeks an order of this Court under California Business & Professions Code
§17200 et seq. that preliminarily and permanently enjoins TE and Crabtree from continuing to
engage in the unlawful and unfair acts or practices set forth herein, as well as restitution.
REQUEST FOR RELIEF
WHEREFORE, RAPC requests relief as follows:
93. Declare that TE is engaged in the unauthorized practice of law while providing
trademark related services to its clients;
94. Enter judgment against TE and Crabtree;
95. Award RAPC all available damages including restitutionary damages against TE and
Crabtree in an amount to be proven at trial;
96. Award RAPC its costs and expenses of this action against TE and Crabtree, including
RAPC’s reasonable attorney fees necessarily incurred in bringing and pressing this case, as
provided in 15 U.S.C. § 1117(a);
97. Award RAPC pre- and post-judgment interest at the applicable rates on all amounts
awarded;
98. Grant permanent injunctive relief to prevent the recurrence of the violations for which
redress is sought in this complaint;
99. Order any other such relief as the Court deems appropriate.
Respectfully submitted this Friday August 10, 2018.
LEGALFORCE RAPC WORLDWIDE P.C.
/s/ Raj V. Abhyanker______

Raj V. Abhyanker
California State Bar No. 233,284
Attorney for Plaintiff:
27
JURY TRIAL DEMANDED
Plaintiff hereby request a bench trial for the declaratory relief and jury trial for all other
causes of action alleged in this Second Amended Complaint.
Respectfully submitted this Friday August 10, 2018.
LEGALFORCE RAPC WORLDWIDE P.C.
By__/s/ Raj V. Abhyanker______

Raj V. Abhyanker
California State Bar No. 233284
Attorney for Plaintiff:
28
Case 3:17-cv-07303-MMC Document 107-1 Filed 08/10/18 Page 1 of 73
EXHIBIT A
12/24/2017 trademark filing
Case 3:17-cv-07303-MMC Document 107-1 - Google Search
Filed 08/10/18 Page 2 of 73
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Case 3:17-cv-07303-MMC Document 107-1 - Google Search
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EXHIBIT B
EXHIBIT B
01213450 6789
87
107-1
Case 3:17-cv-07303-MMC Document
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EXHIBIT C
1
2
3
4
EXHIBIT D
List of harmed customers of Trademark Engine LLC:
1. Customer J.R. in California requested a filing of a trademark application

through Trademark Engine on or about October 2017. J.R. chose Trademark
Engine because its advertising led him to believe he would be represented by an
attorney. When asked, J.R. confirmed that he thought Trademark Engine was
2. Customer C.R. in Indiana requested a filing of a trademark application through

Trademark Engine on or about January 2018. C.R. believed that Trademark
Engine’s service was lawful and that her email would be kept private. C.R. stated
that Trademark Engine did not inform her that her privacy would be waived. She
confirmed to Plaintiff’s counsel on July 31, 2018 that “Their advertising did lead
me to believe that I would be represented by at least 1 trademark attorney, and
that they would submit trademark documents for me.”
3. Customer J.S. in California requested a filing of two trademark applications

through Trademark Engine on or about February 2017. J.S. confirmed to
Plaintiff’s counsel on July 29, 2018 that “I do feel Trademark Engine inaccurately
marketed their services and professionalism.”
4. Customer M.C. in New York requested a filing of a trademark application

through Trademark Engine on or about October 2017. M.C. confirmed to
Plaintiff’s counsel on July 29, 2018 that he believed he would be represented by
a group of trademark attorneys. M.C. also wrote that Trademark Engine assisted
him in amending his description and selecting classification. M.C. said he was
not told his privacy would be waived. M.C. confirmed that he thought Trademark
Engine was providing a lawful service.
5. Customer M.D. in Maryland requested a filing of a trademark application

through Trademark Engine on or about March 2018. M.D. confirmed to Plaintiff’s
counsel on July 29, 2018 that “I believed that TradeMark Engine was a company
run by experienced USPTO attorneys”, and that Trademark Engine amended his
description and selected classification. He paid $5 a month to protect his privacy
and is still paying for that service. He is upset that they waived his privacy and
his private information has been published on USPTO public forms. Travis
Crabtree personally signed his name as a “domestic representative information”
for M.D.
6. Customer E.T. in California requested a filing of a trademark application

through Trademark Engine on or about December 2017. E.T. confirmed to
Plaintiff’s counsel on July 29, 2018 that “They first said make corrections show
detailed information on good and services provided in which was done. Then I
was told to make corrections”, “they presented themselves as legal service”, and
“I’m really feeling swindled”.
1
EXHIBIT D TO SECOND AMENDED COMPLAINT
CASE NO.: 3:17-CV-07303-MMC
7. Customer J.J. in New York requested a filing of a trademark application through

Trademark Engine on or about February 2017. J.J. confirmed to Plaintiff’s
counsel that “I was led to believe that they were a legal service. They did help
amend my trademark application. I did sign up for they're privacy service. They
did as well mislead me”. In an email to J.J., titled “Please CONFIRM Your
Application Details - Trademark Engine” on October 3, 2017, Trademark Engine
provided a “SUGGESTED Description” and “SUGGESTED Class” (class 36) that
were different and modified the original description of the classification provided
by J.J. (class 35). J.J. forwarded to Plaintiff’s counsel the screenshot sent by
Trademark Engine on Friday, February 10, 2017, with the subject line “Deficient
Description of Goods - Trademark Engine”, showing clearly that Trademark
Engine assisted J.J. with modifying the description of goods and services, and
provided legal advice when they wrote “The description of goods you provided is
deficient and may create delays or rejections by the USPTO because it is too
general as it is now. For example, a trademark application with a class
description of “Clothing” will be rejected by the USPTO for being too general. A
better description would be “Clothing, namely, pants, shirts, shorts, and shoes.”
Likewise, you cannot simply state that you plan on selling products in certain
industry; you need to describe what kinds of products.” See screenshot below:
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8. Customer F.G. in Santa Clara County, California requested a filing of a

trademark application through Trademark Engine on or about December 2016.
F.G. confirmed to Plaintiff’s counsel on July 31, 2018 that Trademark Engine’s
advertising led him to believe that he would be represented by a trademark
attorney, and that he “Absolutely” believed Trademark Engine was at least a
lawful service.
9. Customer G.C. in Rhode Island requested a filing of a trademark application

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through Trademark Engine on or about March 2018. G.C. confirmed to Plaintiff’s

counsel when she saw Trademark Engine claiming on their website that they are
professionals, she “100% yes, absolutely” believed they were providing a lawful
service. G.C. further stated that Trademark Engine’s advertising led her to
believe she would be represented by a group of trademark attorneys and that
“they guided me in choosing the best classification”.
10. Customer D.M. in Ohio requested a filing of a trademark application through

Trademark Engine on or about March 2018. D.M. confirmed to Plaintiff’s counsel
on July 31, 2018 that Trademark Engine “wanted me to put items that were not
correct in my application or were not truthful then when I was deneighed [sic] my
trademark they were done with me.”
11. Customer C.P. in Texas requested a filing of a trademark application through

Trademark Engine on or about November 2017. C.P. confirmed to Plaintiff’s
counsel on July 26, 2018 that “I did assume they were using professional and
providing a lawful service [sic] as per their website description. I would not
expect, but not be surprised, if Trademark Engine retained and re-used or sold
my personal information.”
12. Customer A.W. in Tennessee requested a filing of a trademark application

through Trademark Engine on or about December 2017. A.W. confirmed to
Plaintiff’s counsel on July 31, 2018 that Trademark Engine’s advertising led her
to believe she would be represented by a group of trademark attorneys. She
wrote that “Yes, I purchased the privacy protection Service. I believed my
information would be kept private. I was informed that Trademark Engine would
help me with any issues I might face.” and “Trademark Engine has not reached
back out to me to help me with the issues.”
13. Customer A.A. in Texas requested a filing of a trademark application through

Trademark Engine on or about September 2016. A.A. confirmed to Plaintiff’s
counsel on August 6, 2018 that Trademark Engine’s advertising led him to
believe he would be represented by a group of trademark attorneys. He also
believed his information would be kept private. A.A. confirmed when he saw
Trademark Engine claiming on their website that they are professionals, it led
him to believe they were providing a lawful service.
14. Customer C.A. in Texas requested a filing of a trademark application through

Trademark Engine on or about August 2017. C.A. confirmed to Plaintiff’s counsel
on July 26, 2018 that “This company pretty much screwed me. Kept coming up
with new charges. They also were taking money out of my account without
permission which I did get back after confronting. Basically got scammed. Never
got a trademark because of there [sic] incompetence. I never would have used
them if I knew they weren't working with lawyers or that my information would not
be kept a secret”.
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15. Customer S.B. in Texas requested a filing of a trademark application through

Trademark Engine on or about October 2017. S.B. confirmed to Plaintiff’s
counsel on July 26, 2018 that “We used trademark engine during the course of
that relationship we were led to believe they would be assisting us in the process
with legal services. The released [sic] our confidential information to other
sources without our consent and misled us to believe they were a professional
company.”
16. Customer T.O. in Maryland requested a filing of a trademark application

through Trademark Engine on or about November 2016. T.O. confirmed to
Plaintiff’s counsel on August 3, 2018 that “It was not my experience that my
dealings with Trademark Engine was [sic] lawful.”
17. Customer T.C. in San Francisco County, California requested a filing of at

least two trademark applications through Trademark Engine on or about April
2017. T.C. confirmed to Plaintiff’s counsel on July 30, 2018 that “I filed with
Trademark Engine with the understanding that this was a professional company
that was going to help me with every step and after steps of my trademark
process. Since they have offered no support after my filing I have had to higher
other lawers [sic] to fining [sic] this process and am still in the process of trying to
finish this process. I have also bee [sic] receiving strange phone calls for other
companies and have wondered where they got my number, well now I know!”
18. Customer R.B. in New York requested a filing of a trademark application

through Trademark Engine on or about January 2018. R.B. confirmed to
Plaintiff’s counsel on July 31, 2018 that “Good afternoon trade mark [sic] did
guide me in amending the description of my trademark, after sending emails they
instructed me to call them to switch it as well as say every thing [sic] looks good
and would be approved. I have email proof.”
19. Customer R.S. in California requested a filing of at least two trademark

applications through Trademark Engine on or about June 2017. R.S. confirmed
to Plaintiff’s counsel on July 31, 2018 that “I took screen shots some time ago of
most of my correspondence over chat on the Trademark Engine website after I
found out that my Trademark in the wrong class. [sic] I approve the class it was
filed under - but - that is because I was lead [sic] to believe that trademarking in 1
class would protect my logo design of it.” and “Also I just checked a few previous
emails where in our correspondence my class was changed at their suggestion. I
write, [sic] can someone please change class 003 to class 035, the suggested
class. They suggested I change it either over the phone or via email. I'd have to
really look through the chat to see if it was there. But either way my letter to them
in that situation was in response to receiving their request for me to approve
finalizing of the application - my response was to make the changes they
suggested so that the application was show the correct suggested class. I also
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have the email before that with their application details showing my original class
applied for as 003. I'm not sure how many times I paid the USPTO additionally
but I know it was at least once an additional 275 dollar application for having to
refile with them AT LEAST a second time in a different class.”
20. Customer L.W. in Texas requested a filing of a trademark application through

Trademark Engine on or about May 2017. L.W. confirmed to Plaintiff’s counsel
on July 30, 2018 that “Yes, they led me to believe they were attorneys.”
21. Customer R.A. in Santa Clara County, California requested a filing of a

trademark application through on or about September 2017. R.A. confirmed to
Plaintiff’s counsel on July 30, 2018 that “I believe I should have been advised y
[sic] one of their “Attorneys” that it would most likely be rejected.” R.A. also wrote
on August 1, 2018 that it was “not to my understanding” that Trademark Engine
would waive his privacy when they paid government fees for his trademark, and
that when he saw Trademark Engine claiming on their website that they are
professionals, he believed they were providing a lawful service.
22. Customer Z.K. in Oregon requested a filing of two trademark applications

through Trademark Engine on or about January 2017. Z.K. confirmed to
Plaintiff’s counsel on July 30, 2018 that “I ordered two trademarks. They acted
like lawyers, they gave me bad advice. My trademark did not work.”
23. Customer S.F. in Oregon r equested a filing of a trademark application through

Trademark Engine on or about January 2017. S.F. confirmed to Plaintiff’s
counsel on July 30, 2018 that “I thought they were attorneys and used their
service.”
24. Customer S.N. in Texas requested a filing of a trademark application through

Trademark Engine on or about January 2018. S.N. confirmed to Plaintiff’s
counsel on July 30, 2018 that “I believed Trademark Engine was providing legal
services and that my information would remain private. I have been bombarded
with emails and phone calls to my cell by solicitations from attorneys.”
25. Customer S.S. in California requested a filing of a trademark application

through Trademark Engine on or about September 2017. S.S. confirmed to
Plaintiff’s counsel on July 30, 2018 that “I submitted my trademark application
through Trademark Engine, as well as payment for their “professional” service.
My application was received and processed, and then seemed to be forgotten.
Many months passed (far exceeding the specified processing period) and my
application status never changed. I finally got ahold of someone at Trademark
Engine on the phone and asked for my money back so that I could use another
service. Only then did my application actually get sent to the USPTO for review. I
was lead [sic] to believe lawyers were handling my application, but I get the
feeling that I was scammed. Even when I spoke to a Trademark Engine
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“employee” I got the feeling my call had been forwarded to someone’s cell phone
and that the whole company was set up to appear to be something different than
what it actually is.”
26. Customer F.D. in Wisconsin requested a filing of a trademark application

through Trademark Engine on or about July 2017. F.D. confirmed to Plaintiff’s
counsel on August 5, 2018 that “I kind of felt like there were lawyers as part of
their team, because one part states that they “amend my description of goods
and services to match the USPTO ID manual. I thought that was weird.” F.D. also
said she has saved all her correspondence with Trademark Engine.
27. Customer R.M. in Texas requested a filing of a trademark application through

Trademark Engine on or about June 2017. R.M. confirmed to Plaintiff’s counsel
on August 2, 2018 that he felt he would be represented by a group of trademark
attorneys, that Trademark Engine assisted him in amending the description of his
trademark and selecting his classification, and he believed his information would
be kept private. R.M. also stated that when he saw Trademark Engine claiming
on their website that they are professionals, he believed they were providing a
lawful service.
28. Customer M.S. in Texas requested a filing of a trademark application through

Trademark Engine on or about May 2017. M.S. confirmed to Plaintiff’s counsel
on August 31, 2018 that “yes they acted as though they were professional and
versed on the legalities of trademarks.” M.S. also stated that she felt she was
scammed by Trademark Engine.
29. Customer H.J. in Michigan requested a filing of a trademark application through

Trademark Engine on or about April 2018. H.J. confirmed to Plaintiff’s counsel on
July 30, 2018 that “I did believe that they would keep my information private...”
30. Customer S.F. in Texas requested a filing of a trademark application through

Trademark Engine on or about November 2017. S.F. confirmed to Plaintiff’s
counsel on July 30, 2018 that “I paid Trade Mark Engines [sic] multiple times for
things that I thought were included in the process. I believe that I still have emails
where I questioned them about it. My business was classified under a topic that
has nothing to do with what the business even does.”
31. Customer J.H. in Florida requested a filing of a trademark application through

Trademark Engine on or about July 2017. J.H. wrote several emails to Plaintiff’s
counsel stating that Trademark Engine’s advertising led her to believe that she
would be represented by experienced trademark attorneys, and that Trademark
Engine amended her description and selected classification. She paid $5 a
month to protect her privacy and is still paying for that service, and is upset that
they waived her privacy and her private information has been published on
USPTO public forms. J.H. believed that Trademark Engine was at least providing
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a lawful service, and her information would be kept private. J.H. also forwarded
emails from her to/from a Jose (“Jake”) Abueg at Trademark Engine, who
requested $149 additional fees to respond to an Office Action rejection from the
USPTO. Abueg wrote to J.H. “We can submit the response to the USPTO today,
and you'll receive confirmation once that process is completed.” Trademark
Engine subsequently prepared and responded to the Office Action response on
behalf of J.H.
32. Customer M.P. in Missouri requested a filing of two trademark applications

through Trademark Engine, one of which was on or about February 2018. M.P.
confirmed to Plaintiff’s counsel that Trademark Engine’s advertising led him to
believe that he would be represented by experienced trademark attorneys, and
that Trademark Engine amended his description and selected classification. He
paid $5 a month to protect his privacy, and is upset that they waived his privacy
and his private information has been published on USPTO public forms. J.H.
believed that Trademark Engine was at least providing a lawful service.
33. Customer W.K. in Connecticut requested a filing of a trademark application

through Trademark Engine, on or about October 2017. W.K. confirmed to
Plaintiff’s counsel that Trademark Engine’s advertising led him to believe that he
would be represented by a trademark lawyer, and that Trademark Engine
amended his description and selected classification. He paid $5 a month to
protect his privacy, believed his information would be kept private, and is upset
that they waived his privacy and his private information has been published on
USPTO public forms. W.K. also believed that Trademark Engine was at least
34. Customer R.F. in Colorado requested a filing of a trademark application

through Trademark Engine, on or about August 2017. R.F. confirmed to Plaintiff’s
counsel that “To the best of my knowledge I was not informed that my privacy
would be waived when they paid government fees for my trademark filing on my
behalf.” and “I did think that when I saw Trademark Engine claiming on their
website that they were professionals and [sic] were providing lawful service.”
35. Customer J.J. in Georgia requested a filing of a trademark application through

Trademark Engine, on or about October 2017. J.J. confirmed to Plaintiff’s
counsel that Trademark Engine’s advertising led him to believe that he would be
represented by experienced trademark attorneys. He is upset that they waived
his privacy and his private information has been published on USPTO public
forms. J.J. believed that Trademark Engine was at least providing a lawful
service.
36. Customer L.A. in Utah requested a filing of a trademark application through

Trademark Engine, on or about July 2017. L.A. confirmed to Plaintiff’s counsel
that he “felt they were providing a lawful service and felt they had attorneys who
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reviewed things”.
37. Customer L.S. in South Carolina requested a filing of a trademark application

through Trademark Engine, on or about April 2017. L.S. provided Plaintiff’s
counsel with an audio recording she took of a Trademark Engine representative
named “Sky” who directly provided legal advice to her. In addition to the audio
recording, L.S. wrote that “I was advised that my trademark name was not a
conflict with a construction company…” In a separate email to L.S. on April 21,
2017, titled “Please CONFIRM Your Application Details - Trademark Engine”,
Trademark Engine provided a “SUGGESTED Description” and “SUGGESTED
Class” (class 35) that was different and modified the original description while
keeping the classification the same as the one the customer originally selected.
38. Customer K.G. in Colorado requested a filing of a trademark application

through Trademark Engine, on or about December 2016. K.G. confirmed to
Plaintiff’s counsel that Trademark Engine’s advertising led her to believe that she
would be represented by a group of experienced trademark attorneys. K.G.
believed that Trademark Engine was at least providing a lawful service.
39. Customer K.K. in Michigan requested a filing of a trademark application

through Trademark Engine, on or about December 2017. K.K. confirmed to
Plaintiff’s counsel that Trademark Engine’s advertising led her to believe that she
would be represented by experienced trademark attorneys. She is upset that
they waived her privacy and her private information has been published on
USPTO public forms. K.K. believed that Trademark Engine was at least providing
a lawful service and wrote “They led me to believe they were professional.”
40. Customer K.F. in Texas requested a filing of a trademark application through

Trademark Engine, on or about June 2017. K.F. confirmed to Plaintiff’s counsel
that Trademark Engine’s advertising led her to believe that she would be
represented by experienced trademark attorneys. K.F. also wrote “I thought they
were a law firm that only handled trademarks.” She stated Trademark Engine
assisted her in amending the description of her trademark and selecting her
classification, and she believed her information would be kept private. K.F.
further informed Plaintiff’s counsel that when she saw Trademark Engine
claiming on their website that they are professionals, she believed they were
providing a lawful service. In an email to K.F. on May 31, 2017, titled “Please
CONFIRM Your Application Details - Trademark Engine”, Trademark Engine
provided a “SUGGESTED Description” and “SUGGESTED Class” (class 3) that
had a different description while keeping the class the same.
41. Customer W.W. in Georgia requested a filing of a trademark application through

Trademark Engine, on or about November 2017. W.W. was sent a
“Comprehensive Search Report” in which a detailed search of conflicting marks
was provided. In another email on October 30, 2017, titled “Direct-hit Located -
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Trademark Engine”, Trademark Engine provided legal advice by telling W.W. that
there were directly conflicting marks. W.W. felt victimized by Trademark Engine
and forwarded to Plaintiff’s counsel emails which demonstrated that Trademark
Engine provided him with legal advice. W.W. confirmed to Plaintiff's counsel on
August 6, 2018, that he felt he would be represented by a group of trademark
attorneys, that Trademark Engine assisted him in amending the description of his
trademark and selecting his classification, and he believed his information would
be kept private. W.W. further informed Plaintiff’s counsel that when he saw
Trademark Engine claiming on their website that they are professionals, he
believed they were providing a lawful service.
In that email, Trademark Engine wrote “As part of our service, we do a basic
exact match search with the USPTO which is limited to direct matches,
phonetically similar, or appearance by way of design. After running an exact
match search on your trademark, we have found an exact match for the mark
you are attempting to trademark. Just because there is an exact match, it does
not mean that you cannot also register your name if it is in a different category.”
See screenshot below:
In a separate email sent to W.W. on October 31, 2017, titled “Please CONFIRM
Your Application Details - Trademark Engine”, Trademark Engine provided a
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“SUGGESTED Description” and “SUGGESTED Class” (class 35) that was

different and modified the original description classification (class 25) provided by
W.W.
In a third email sent on October 30, 2017, with the subject “Deficient Description
of Goods - Multiple Classes - Trademark Engine,” Trademark Engine provided
additional guidance. A relevant sample of this email is shown below:
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42. Customer G.M. in Texas requested a filing of a trademark application through

Trademark Engine, on or about October 2017. G.M. called Plaintiff’s counsel and
told them that Trademark Engine’s advertising led him to believe that he would
be represented by trademark lawyers. G.M. believes he still has the Chat History
saved of conversations in which Trademark Engine provided him legal advice in
modifying his goods and services and assisted him in selecting trademark
classification. G.M. believes that the advice he received was faulty because he
received an office action. When G.M. saw on Trademark Engine’s website that
they were professionals, he assumed that they were lawyers with respect to
trademarks. G.M. is upset his personal information was released, although he is
unsure if he purchased the $5 a month trademark privacy protection.
43. Customer Y.B. in Florida requested a filing of a trademark application through

Trademark Engine, on or about December 2017. Y.B. confirmed to Plaintiff’s
counsel stating that “I thought that I was being represented by attorneys” and
“The trademark engine totally deceived and embarrassed me. Trademark
attorneys are writing me from everywhere to defend my rights. I am so thank for
you [sic] because I didn't have the money to fight…” When asked, Y.B. confirmed
to Plaintiff’s counsel that he thought Trademark Engine was providing a lawful
service.
44. Customer J.S. in Kentucky requested a filing of a trademark application

through Trademark Engine, on or about August 2017. J.S. confirmed to Plaintiff’s
counsel stating that “Yes I was wronged by this company and They [sic] took my
ideas and hard work I had Invested thousands into and didn’t protect My [sic]
interest. I lost my entire idea and trademark I feel like they owe me a lifetime of
work.” J.S. believed he would be represented by a trademark lawyer, and
Trademark Engine assisted him with amending the description of his trademark
and modifying the goods and services associated with his trademark. J.S.
confirmed that when he saw Trademark Engine claiming on their website that
they are professionals, he believed they were providing a lawful service. J.S. paid
$5 a month to protect his privacy and is upset that they waived his privacy and
his private information has been published on USPTO public forms.
45. Customer D.P. in New York requested a filing of a trademark application

through Trademark Engine, on or about September 2017. D.P. spoke to
Plaintiff’s counsel over the phone and confirmed that he chose Trademark
Engine because their advertising led him to believe you would be represented by
a team of trademark lawyers with experience preparing and filing trademark
applications. D.P. expected that Trademark Engine attorneys would have
competently handled his trademark. Trademark Engine gave him legal advice
prior to filing by telling him the logo he submitted was insufficient, and asked you
for a new logo as a specimen of use. The advice D.P. received was faulty
because his mark still received an Office Action and he had to go back and forth
with the USPTO examiner to try fix it, but his trademark is now abandoned. D.P.
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does not believe he was ever informed by Trademark Engine that his privacy
would be waived. When D.P. saw Trademark Engine claiming on their website
that they are professionals, he thought this meant that their service was lawful
and they were attorneys because “only lawyers are professionals” and the word
“professional” indicated to D.P. their “professionals” were lawful and were
trademark attorneys.
46. Customer K.A. in Virginia requested a filing of a trademark application through

Trademark Engine, on or about January 2018. K.A. confirmed to Plaintiff’s
counsel that he was made to believe by Trademark Engine’s advertising that he
would be represented by a team of trademark lawyers. K.A. wrote to Plaintiff’s
counsel that not only did Trademark Engine assist him in selecting classification
and adjusting his goods and services, “We spent a month trying to determine the
classification.” K.A. was not informed his privacy would be waived when
government fees would be paid on his behalf. Moreover, K.A. believed when he
saw advertisements in which Trademark Engine claimed to be professionals that
meant that Trademark Engine were providing a lawful service.
47. Customer A.G. in Michigan requested a filing of a trademark application

through Trademark Engine, on or about November 2017. A.G. called and
confirmed to Plaintiff’s counsel that he purchased the $5 a month trademark
privacy service from Trademark Engine, that he was not told his privacy would be
waived, and feels victimized that his private information has been published. A.G.
confirmed via email that he believed he would be represented by a group of
trademark attorneys. When asked, A.G. confirmed that he thought Trademark
Engine was providing a lawful service.
48. Customer B.M. in California requested a filing of two trademark applications

through Trademark Engine, one of which was on or about November 2017. B.M.
called Plaintiff’s counsel and also wrote “Yes, I thought they had a legal staff and
believed a trademark lawyer would review the document prior to submission.
They definitely guided me in amending the description on both Trademarks
submissions. One person told me almost every submission they submit is
approved (i.e. they have an excellent track record of approvals). Nobody told me
my privacy would be waived.” B.M. further wrote “We wasted our money
submitting the trademark application. Yes, I consider myself injured. I will submit
several more applications in the future and never use these type [sic] of rip-off
artists.”
49. Customer P.L. in New York requested a filing of a trademark application

through Trademark Engine, on or about June 2017. P.L. called Plaintiff’s counsel
and also wrote that “I was lead [sic] to believe that I would be represented in a
way that is in upstanding [sic] with all the rules.” P.L. further told the Plaintiff’s
counsel that he thought he would be represented by a trademark lawyer, that
Trademark Engine assisted him with the selection of classification and
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modification of his goods and services, and did not inform him that his privacy
would be waived. P.L. believes that he purchased the $5 a month “Trademark
Privacy Protection” service on Trademark Engine.
50. Customer T.J.D. in Maryland requested a filing of a trademark application

through Trademark Engine, on or about May 2017. T.J.D. told the Plaintiff’s
counsel that “I sent copies of books I have written that are currently available on
Amazon. I’ve written three books using this name. When I sent this info to them
they said it was enough but I later learned my trademark was denied or stopped
and I had no more money to pay to fix the issue” and that “I was under the
assumption that once my money was paid they would handle everything and that
they were qualified to do so which apparently was not the case. Now I’ve lost the
money I paid and still have not trademarked the name.” T.J.D further wrote “I
definitely feel like the company misrepresented what they would and could do,
took the money and ran.”
51. Customer J.F. in Washington requested a filing of a trademark application

through Trademark Engine, on or about February 2017. J.F. called Plaintiff’s
counsel as well as wrote “i feel they mislead me from the beginning.” [sic] and
“they were nasty acting during this time i feel they should have caught the misake
[sic] but did just more money i still do not have my trademark...” [sic]
52. Customer A.L. in Ohio requested a filing of a trademark application through

Trademark Engine, on or about November 2017. A.L. called Plaintiff’s counsel as
well as wrote “I believed they were honest and telling the truth and operating
legally. They picked the classification for me after asking what I did. I had to write
the description, and they took care of the rest of it.” In addition, A.L. wrote “I
believed they were a legal team that specialized in trademark registration”. A.L.
also wrote “They required me to pay an additional fee for the privacy, which was
not honored. I was bombarded with solicitations after it was filed.” Furthermore,
A.L. confirmed to Plaintiff’s counsel that he “believed my information would be
kept private. It was not kept private. When I attempted to cancel, they refused to
honor it (After stating they would cancel it) and continued to bill me anyways. I
had to call my bank and put a block on my debit card account to prevent them
from taking any more money.”
53. Customer M.B. in Georgia requested a filing of a trademark application through

Trademark Engine, on or about April 2018. M.B. called Plaintiff’s counsel as well
as wrote “I spent a lot of money with them basically to get rejected. I trusted them
and I seen their ad on Facebook and yes they told me they were professionals
and they have done this for a long time. So I thought everything would go well. It
seemed legit and they asked all the right questions but then so much nonsense
came with it and so did more money. But it was my firsts [sic] time but I should’ve
gotten my own lawyer had I known this would have happened...”
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54. Customer F.K. in Montana requested a filing of a trademark application through

Trademark Engine, on or about May 2017. F.K. called Plaintiff’s counsel and
confirmed that Trademark Engine’s advertising led him to believe that he would
be represented by a trademark lawyer. F.K. believed that Trademark Engine was
at least providing a lawful service, and his information would be kept private. He
is upset that they waived his privacy and his private information has been
published on USPTO public forms.
55. Customer A.S. in California requested a filing of a trademark application

through Trademark Engine, on or about December 2017. A.S. called Plaintiff’s
counsel as well as wrote “I believe Trademark Engine did utilize non-lawyer
assistants to provide legal information.”
56. Customer E.S. in Maine requested a filing of a trademark application through

Trademark Engine, on or about September 2017. E.S. called Plaintiff’s counsel
and confirmed that Trademark Engine’s advertising led him to believe that he
would be represented by a group of trademark lawyers, and that Trademark
Engine assisted him with modifying his description and selecting his class. E.S.
believed that Trademark Engine was at least providing a lawful service, and his
information would be kept private. E.S. believes he purchased the $5 a month
“Trademark Privacy Protection” service from Trademark Engine. He is upset that
they waived his privacy and his private information has been published on
USPTO public forms.
57. Customer S.P. in Florida requested a filing of a trademark application through

Trademark Engine, on or about June 2017. S.P. called Plaintiff’s counsel and
wrote “I was led to believe that I would have access to a trademark attorney and I
was also not informed that my privacy would be waived once I started working
with Trademark Engine. I thought they were a lawful service.”
58. Customer A.A. in New York requested a filing of a trademark application

through Trademark Engine, on or about June 2017. A.A. called Plaintiff’s counsel
and confirmed that Trademark Engine’s advertising led her to believe that she
would be represented by a group of trademark attorneys. A.A. believed that
Trademark Engine was at least providing a lawful service, and her information
would be kept private. A.A. purchased the $5 a month “Trademark Privacy
Protection” service from Trademark Engine. She is upset that they waived her
privacy and her private information has been published on USPTO public forms.
59. Customer J.D. in Florida requested a filing of a trademark application through

Trademark Engine, on or about January 2018. J.D. left a voice message for the
Plaintiff’s counsel, and forwarded an email from Trademark Engine sent on
January 15, 2018, in which the description of goods and services that he
selected was suggested to be modified.
Page 15
60. Customer B.O. in New York requested a filing of three trademark applications
through Trademark Engine, one of which was on or about October 2017. B.O.
wrote to Plaintiff’s counsel that “I found them (Trademark Engine) online and they
messed up all of my filings. They all got rejected and I had to pay the fee for all
services. They tried to sell me 5$/ month privacy protection package but I told
them it’s not legal and they waive that fee. But I got solicitations about my filings
from many lawyer firms to file an answer to USPTO. I’m not sure if they shared
my information. And yes they also represented themselves as professional
lawyers who is doing the filings for cheaper price because they claim to have too
much traffic that they can keep fees low.” B.O. confirmed to Plaintiff’s counsel
that Trademark Engine’s advertising led him to believe that he would be
represented by experienced trademark attorneys. B.O. also said that Trademark
Engine provided legal advice by updating the description of his trademark and
selected his classification. He is upset that they waived his privacy and his
private information has been published on USPTO public forms. When asked,
B.O. confirmed that he thought Trademark Engine was providing a lawful service.
Travis Crabtree personally signed his name as a “domestic representative
information” for B.O.
61. Customer K.S. in Indiana requested a filing of a trademark application through

Trademark Engine, on or about October 2017. K.S. confirmed with Plaintiff’s
represented by experienced trademark attorneys. K.S. told Plaintiff’s counsel that
Trademark Engine provided legal advice by updating the description of his
trademark and selected his classification. When asked, K.S. confirmed that he
thought Trademark Engine was providing a lawful service. K.S. purchased the $5
a month “Trademark Privacy Protection” service from Trademark Engine. He is
upset that they waived his privacy and his private information has been published
on USPTO public forms.
62. Customer M.R. in Oregon requested a filing of a trademark application through

Trademark Engine, on or about November 2017. M.R. wrote to Plaintiff’s counsel
that “I fully thought I was chatting with a professional attorney when I had
questions through their chat option and fully was with the understanding that my
filing with them was for a legal assistance for application assistance. If my
information was shared without my approving it, I'm not happy about it and want
them held accountable as that is not okay with me what so ever [sic].”
63. Customer H.L. in New Jersey requested a filing of two trademark applications
through Trademark Engine, one of which on or about December 2017. H.L.
confirmed with Plaintiffs' counsel that Trademark Engine’s advertising led him to
believe that he would be represented by experienced trademark attorneys.
When asked, H.L. confirmed that he thought Trademark Engine was providing a
lawful service saying “ I thought it's lawful, of course. If I thought it's illegal, I didn't
use their service. [sic] ” He is upset that they waived his privacy and his private
Page 16
information has been published on USPTO public forms.
64. Customer W.L. in Texas requested a filing of a trademark application through

Trademark Engine, on or about September 2017. W.L confirmed with Plaintiffs'
represented by experienced trademark attorneys “over phone”. When asked,
W.L. confirmed that he thought Trademark Engine was providing a lawful service.
He is upset that they waived his privacy and his private information has been
published on USPTO public forms.
65. Customer J.C. in Arizona requested a filing of a trademark application through

Trademark Engine, on or about August 2017. J.C. wrote to Plaintiffs’ counsel
“Filed and was misled on price. Then payment was deducted from my account.
Continually try to charge my account still.”
66. Customer A.B. in New Hampshire requested a filing of a trademark application

through Trademark Engine, on or about September 2017. A.B. wrote to
Plaintiffs’ counsel “I believed this was a lawful service using licensed attorneys. I
believed my info would be kept private”
67. Customer S.L. in Wisconsin requested a filing of a trademark application

through Trademark Engine, on or about July 2017. S.L. wrote to Plaintiffs’
counsel “Apart from the fact that they were useless I had assumed that they
would not share my data as I have been inundated with junk emails. I had also
assumed that they were prodessionals [sic] ”
68. Customer J.B. in North Carolina requested a filing of a trademark application

through Trademark Engine, on or about January 2018. J.B. wrote to Plaintiffs’
counsel “They made us believe they were professional service able to get us a
trademark. They sent us a serial number and we later received a bill for over
$1300 after we already paid them”
69. Customer D.S. in New Jersey requested a filing of a trademark application

through Trademark Engine, on or about November 2017. D.S. wrote to
Plaintiffs’ counsel “Yes, we trusted them and proceeded with our trademark
registration. We were thinking they are attorneys.” D.S. further wrote “They
have not guided us properly in any aspect and looks like they have no knowledge
about filing. We basically wanted trademark in principal and they filed it under
supplemental registration because of which we are having issues registering our
brand in amazon.”
70. Customer F.W. in Georgia requested a filing of a trademark application through

Trademark Engine, on or about January 2018. F.W. wrote to Plaintiffs’ counsel
“Yes, we trusted them and proceeded with our trademark registration. We were
thinking they are attorneys.” F.W. further wrote “Well I ordered the service for
Page 17
originally one price. Then they came back and said I needed to pay another price
to actually file the trademark. Now the first fee was to ensure that the mark wasn't
already taken. Well it comes to find out its like three different companies with the
same mark. Now I'm in dispute over the mark. Which has cost me thousands of
dollars in delays and if I lose thousands in wasted product. Part of the reason for
this is that they made me change my classification of goods after I had already
choose one classification. This in turn is really what I'm fighting now.”
71. Customer S.D. in New Jersey requested a filing of a trademark application

through Trademark Engine, on or about March 2018. S.D. wrote to Plaintiffs’
counsel “ they sold me on a bunch of lies.”
72. Customer S.E. in Ohio requested a filing of a trademark application through

Trademark Engine, on or about October 2017. S.E. wrote to Plaintiffs’ counsel “I
know this is a fraudulent company as I had to call and request them to stop
charging my credit card for services that they were not providing! Trademark [sic]
refused to stop charging my card and ignored my request..”
73. Customer R.B. in Oregon requested a filing of a trademark application through

Trademark Engine, on or about June 2017. R.B. wrote to Plaintiffs’ counsel “I
seem to be stuck paying them $5/month for something.”
74. Customer S.G. in California requested a filing of a trademark application

through Trademark Engine, on or about November 2017. The customer wrote to
Plaintiffs’ counsel “I filed to trademarks with them and they were never approved
and they kept billing me every month $5.00 to the point where I needed to cancel
my card and reissue a new one”
75. Customer T.G. in Colorado requested a filing of a trademark application

through Trademark Engine, on or about December 2017. The customer wrote to
Plaintiffs’ counsel “I paid trademark engine to file for my trademark and to receive
legal services to avoid any complications is the future. I was under impression
that a legal attorney would be working on my file. I also thought my information
would be private.”
76. Customer T.P. in Maryland requested a filing of a trademark application through

Trademark Engine, on or about July 2017. The customer wrote to Plaintiffs’
counsel “Filed for a trademark and di [sic] think I was speaking with lawyers”
77. Customer T.K. in Washington requested a filing of a trademark application

through Trademark Engine, on or about September 2017. The customer wrote
to Plaintiffs’ counsel “I was under the impression that I had hired professional
lawyers that we're going to file my tradrmark [sic] for me and would only need
their services again if I received an office action”.
Page 18
78. Customer R.E. in Florida requested a filing of a trademark application through

Trademark Engine, on or about January 2018. The customer wrote to Plaintiffs’
counsel “I filed using their service, presuming they were offering legal services.”
79. Customer J.O. in Minnesota requested a filing of a trademark application

through Trademark Engine, on or about January 2018. The customer wrote to
Plaintiffs’ counsel “Trademark Engine also kept billing me for other things I didn't
understand” and “I was so annoyed with Trademark Engine, I asked them to
cancel my trademark and gave up the business.”
80. Customer M.M. in Maryland requested a filing of a trademark application

through Trademark Engine, on or about June 2017. The customer provided
evidence to Plaintiffs’ counsel that Trademark Engine suggested the
classification of goods and services he placed on his online form from [25] be
changed to class [35].
Page 19
EXHIBIT E
EXHIBIT F
FILE DETAILS
Audio Length: 54 minutes
Audio Quality: ☐ High ☒ Average ☐ Low
Number of Facilitators: Three
Number of Interviewees: One
Difficult Interviewee Accents: ☐ Yes ☒ No
Other Comments:
START OF TRANSCRIPT
Facilitator 1: Hi guys, I'm so sorry, my meeting ran over. Jordan, are you there?
Interviewee: Yes, I'm here, hi.
Facilitator 1: Hi Jordan. Yeah, so I was just looking for candidates that have a strong
trademark background and I guess you've already had some talk with Heather
and Ryan, but I'd like to just quickly ask some questions and then just let them
ask questions.
Facilitator 2: No.
Facilitator 1: Is that okay?
Facilitator 2: No, Ryan - I'm sorry, no Raj, Ryan is not on the call and we were waiting for…
Facilitator 3: I'm on the call. I'll been on most of the time.
Facilitator 1: Okay, good, so we're just starting the call now. I'm so sorry Jordan, I was
running - my other meeting was running late and I'm sorry, I'm here now though,
is that okay? Do you still have time to talk with me?
Interviewee: Oh yes, absolutely, it's no problem at all.
Facilitator 1: Okay, so yes, Jordan I was looking for - so we're a trademark law firm and
patent law firm, we're looking for people that have a passion for trademark and
1
Transcript of Initial Candidate Interview - Jordan Franklin
Case No.: 3:17-cv-07303-MMC
interest in trademarks to join us. So we're just trying to find resumes and we
came across yours, this LinkedIn profile and then this other thing on this website,
so we thought we'd talk to you. So tell me a little bit about yourself. Are you -
you've graduated from law school?
Interviewee: I have.
Facilitator 1: You have. Have you taken the bar exam yet?
[Interruption]
Facilitator 1: I'm sorry. I don't know what that was. I'm sorry, can you hear - that's probably
Ryan getting hold music, but are you there Jordan?
Interviewee: Yes sir, yes sir, I'm still here, but to answer your question, I actually just
finished bar exam yesterday.
Facilitator 1: Okay, congratulations. So you're waiting the results from that. When will the
results come out?
Interviewee: From what I've been told, early May I believe.
Facilitator 1: Okay, so did you take the November bar or did you not take the November
bar?
Interviewee: I did, I took Texas and I missed it by nine points, so I had to re-sit the whole
exam instead of just the MBE.
Facilitator 1: I see.
Interviewee: So that's what I did in February.
Facilitator 1: Okay and you want make Texas your home? Are you open to relocating to
Arizona or the Bay area or are you looking to stay in Texas?
Interviewee: I'm definitely open to relocating to staying here because I do have a passion for
trademarks and the opportunities aren't really here, even though I'm from here.
So I realized for I wanted to do for my career, I was going to need to relocate and
I'm totally fine with that.she
Facilitator 1: So you'd be fine with working in Tempe, Arizona, where our office is?
Interviewee: Yeah, yes sir, I'd be totally fine with that.
2
Facilitator 1: Okay, so walk me through your work experience. I have your resume here, so
you're at Gray Reed & McGraw as a filing clerk, legal assistant. So tell me what
you did in that firm.
Interviewee: So when I was there - I'm no longer there, I left about a month before I moved
to go to law school. But that was the kind of job I got fresh out of undergrad and I
was still trying to decide whether or not I actually wanted to go to law school. So I
ended up working there for a few years and at the time, that office only had one
intellectual property attorney, so I actually worked under him. He kind of opened
my eyes a lot to the industry and my first ever trademark application, he taught
me how to file. So it kind of fostered that yearning I had to learn a little bit more,
which of course eventually pushed me to go to law school.
So even though I was a filing clerk there, I did more than just filing clerk duties.
Of course I maintained the physical and the electronic files, the client files, but I
also did legal assistant work, drafting correspondence, drafting discovery
requests and things of that nature, filing - not filing - faxing, mailing, things like
that. But of course because they also knew I was not staying in that position, well
attorneys like the one I worked with, he would take me to CLEs with him. I went
to - had a federal patent case that lasted for a long, long time, so he let me go to
trial with him, kind of sit in on the trial and really get a feel for what to expect
officially. I ended up leaving after two years and going to law school.
Facilitator 1: Okay, so is that attorney still there at Gray Reed? Would he be a reference for
you?
Interviewee: Absolutely because he also is one of the owners for Trademark Engines that's
on my resume.
Facilitator 1: Okay, so what's his name then?
Interviewee: Travis Crabtree.
Facilitator 1: Okay, so you worked with him as - and he was a shareholder of Gray Reed or
is he an associate? Or what was he? Is he still there?
Interviewee: He's a shareholder I think, maybe he may have moved up to partner now, but
at the time I was working for him, he worked shareholding.
3
Facilitator 1: What's the difference, did they have shareholder and partner, was it different or
the same?
Interviewee: There is a difference. I didn’t know exactly what the difference was. He was like
a step right below partners, but I believe since I've left, I believe he is a partner
now.
Facilitator 1: Okay.
Interviewee: I'm not - I didn’t quite understand their ranking system.
Facilitator 1: Okay, I see. So after you left that in June 2014, you went to law school and
then you went to law school - so you worked there right after graduating from
college, I guess, right?
Interviewee: Right.
Facilitator 1: Then so tell me after you graduated law school, did you work more in
trademarks or how did you go from there to your next job?
Interviewee: I actually worked for Travis, because he's in the process of kind of branching
off and doing his own thing, I believe. But he started a web engine, called
Trademark Engines, where people could electronically submit a request for
trademark filing. At the time he started the company, I was, I believe, the only
person that had a law degree or was in the process of getting one, so I
processed a lot of trademark applications and a few copyright applications as
well. So because of the relationship that I'd built with him and working for Gray
Reed before I went to law school, we still maintain a really good rapport.
He told me he had this new opportunity and if I would be interested and I told him
I was definitely interested in that. So I did that for him for a few months and then I
stopped to study for the bar for the summertime. Then when the bar ended, I
picked it back up around November. Then I stopped again just recently to study
for the bar again, this current round. Then prior to that, actually, my last year of
law school, I was one of the pilot students for a newly developed - we called it a
technology entrepreneurship clinic and we did a lot of IP work. So I did a lot of
trademark work through the clinic and like I said, I was the pilot student, so I was
the only one that did trademark work.
4
So I obviously got a lot of [unclear] kind of like one-on-one experience with the
professor, because he did patent trademark work for a long, long time, before he
stopped practicing to teach.
Facilitator 1: Okay, so Trademark Engine, you were like the only law students and others
didn't have a law background, so you did what then? What did you do there?
Interviewee: I did a lot of clearance work, so I would do searches and once the searches
passed, I would do mostly - the searches I mostly did were on the PTO website. I
didn't really do too many common law searchers; he kind of let other people do
those and I mainly did the ones, the national searches on the PTO website. So
once a search is cleared, then I would further with the client's order and process
whatever their logo, their slogan, their name, whatever they were submitting for.
Facilitator 1: So if they needed clarification on their description or classification selection, did

you help them pick that or did you pick that for them or how did that work?
Interviewee: Yes, I would - I wouldn't say I would select it for them, but I would kind of add,
okay, what is it that you do, give me a list of all the things that your company
does and then I would kind of select the class that was close to or exactly,
depending on what it was that they did. Normally they would prefer that I kept it in
one class, so tried to find a class that was general enough to cover if they did
more than one thing, that could cover everything underneath that one class. So it
was a little difficult at times when clients were a little all over the place with what
they did, especially if their company was still kind of getting off the ground, but I
never really had any problems with anything getting kicked back. At times too, as
necessary, he normally answered any type of office actions, but I answered a few
as well.
Facilitator 1: Okay, so you would answer the office actions and then submit it back to the
customer and they would file it or you would file it or how does that work? How
did you guys do the filings?
Interviewee: We would file it actually. Their emails would be on file as well as the secondary
email that they would ask for, would be the one that would be tied to me and to
my account with this company, so that whenever the office would send them
correspondence, I would get it as well, because they're normally going to email
and be like, hey what does this mean? So in that instance, I would already have
5
a copy of it, so I could read it and tell them, okay this is what this means and
going forward, this is what we're going to do to rectify the situation and to correct
it.
So there's been plenty of times where I had a client that got - I think his was
rejected because - it was an ornamental rejection for his logo for a t-shirt that he
had. So I went through, I fixed it, resubmitted another specimen and got it
approved for publication with no extra charge to him.
Facilitator 1: That's interesting. So did you, in that experience when you had to do things
such as file, you also got familiar with the filing system at the USPTO and then
you would file it on behalf of the customer as well, right?
Interviewee: Correct, yes sir, I am super familiar with their filing system and the applications
and what they look for, the types of specimens that they prefer and things of that
nature, so even at the beginning, if I got a certain specimen from a client, I
started to kind of get a little bit more comfortable with being able to look at it and
tell, okay, well I'm going to need this in JPEG or a PDF formation, they're not
going to accept it in this format or do you have an invoice with the business name
on it, because just a blank envelope is not going to help the letterhead, isn't
going to be the type of specimen that will push it through.
Facilitator 2: Hi Jordan, this is Heather.
Interviewee: Hi Heather.
Facilitator 2: I'm the training attorney at Legal Force. So I'm actually curious as to what kind
of training the courts and paralegal, as well as also the attorneys might have
undergone.
Facilitator 1: Are there any attorneys first of all, like are there any attorneys at Trademark
Engine or are you the - did Travis supervise…
Interviewee: Yes, it's run by attorneys, they're all licensed attorneys.
Interviewee: So they supervised - I was the only one that would really like respond to the
office actions because I had, at that point I had JD, well I was working on our JD
6
and then I had a JD, because I was still working with them after I graduated.
So…
Facilitator 1: I'm confused though, so you mentioned that - so Crabtree, did he work full time
at Trademark Engine or was he supervising you? Did he work at Gray…
Interviewee: Yeah, he was supervising me. He did both. He didn't really work as much as
Gray Reed, he was kind of transitioning out, so he did, before I submitted
anything, it had to go to him first.
Facilitator 2: Were there other attorneys on staff at Trademark Engine?
Interviewee: Yes, there is one, his name is Daniel, I don't know his last name. We work
remotely a lot. I knew Travis, because normally that's what we - like it was face to
face with him more.
Facilitator 2: Right. What was your interaction with Daniel, did he ever supervise your work?
Interviewee: He didn't supervise my work as much as Travis. I didn't really have much of a
rapport of David outside of email responses.
Facilitator 1: David or Daniel? Is it David?
Interviewee: Mainly because I think it was Travis' company.
Facilitator 1: David? Is it David or Daniel? Would he be a reference for you as…
Interviewee: Danny.
Facilitator 1: Danny?
Interviewee: Oh no, no, he's not a reference for me, no sir. I didn't really have much of a
relationship with him or for him to be a verifiable reference.
Facilitator 1: What's his last name? Do you know what his last name is?
Interviewee: But because I was…
Facilitator 1: Do you know what his last name is?
Interviewee: I don't [unclear] his last name, I would have to pull up an email that had his…
Facilitator 1: Okay, all right, so you didn't have a good - okay, so tell us why don't you work
for Trademark Engine after you graduate? Like why are you not going to just
continue working there after the bar? Why does our firm or other opportunities
7
interest you? That seems like a similar opportunity, it's your interest area, so are
you looking outside of that?
Interviewee: Yeah, I'm definitely looking for more than just - I wouldn't say just processing
applications…
[Phone ringing]
Interviewee: I'm sorry, I'm actually - I'm home today since I sat the exam yesterday, so I'm
kind of just hanging out and that is the house phone. I would definitely say that I
kind of wanted more. I wasn't quite sure the direction Trademark Engine is going
because it is still a very, very young company, I'd say they've only been around
maybe two years, if that. I kind of offered myself if necessary, but I haven't really
heard anything either. I don't want to kind of sit and wait for nothing to happen.
Facilitator 1: So what salary are you looking for until you pass the bar? Like if we were to
make you an offer prior to you passing the bar, what salary are you making there
and what are you looking for if we had hired you in Tempe, for example?
Interviewee: That's another thing, I was only making about $14 an hour at Trademark
Engine.
Facilitator 1: I see. So if we were to pay you something more and give you an opportunity to
be an attorney, then you potentially could move to Tempe and work, if we were
paying you $18 an hour, would that work for you, to move to Arizona and give
you some relocation allowance to work as a legal assistant until you became a
licensed attorney?
Interviewee: Yes sir, I can definitely do that. What is the cost of living in Arizona? Because
I'm not sure.
Facilitator 1: It's pretty low, I mean I grew up there. I mean you could get an apartment for
about $1000 a month and you can buy a house for $250,000 or so. My wife, by
the way, grew up in Texas. She went to High School for Health Professions in the
city and she grew up in Sugar Lake.
Interviewee: Oh, DeBakey.
Facilitator 1: Yeah, DeBakey, so she has good memories of that. She became a pharmacist
and yeah, so I know Houston.
Interviewee: Yeah.
8
Facilitator 1: Houston is - you know, whenever I - I grew up in Phoenix, I would fly to

Houston, it was always like it just felt the same, they feel very similar except it's
less muggy and more hot though in the summer, but not muggy and otherwise
it's got a similar vibe and culture.
Interviewee: Okay, that's awesome, that's awesome.
Facilitator 1: So tell me, so you're respecting your results in Texas soon and are you more
interested in prosecution or litigation? Do you have interests in litigation or do you
want to just…
Interviewee: I just - I'm sorry, I didn't mean to cut you off.
Facilitator 1: That's okay, go ahead. You were saying…
Interviewee: No sir, I was just saying I do actually have an interest in both prosecution and
litigation.
Facilitator 2: What kind of litigation experience do you have?
Interviewee: Outside of mock trial being in law school?
Facilitator 1: Yeah, I think you were a champion mock trial Louisiana State interstate mock
trial, that's pretty impressive, tell me about that. What happened there? How did
you do that? Is that like part of a team?
Interviewee: Right it was more - it was just my partner and I and then our two witnesses, but
I was in law school in Louisiana and we have an interstate mock trial competition
and my partner and I actually ended up winning last year. That was the first time
our school had won in 17 years, so that was really exciting.
Facilitator 1: Did you compete with other law schools and stuff or was it inter…
Interviewee: We did, yes sir. Actually the final one was between the school I went to, which
is Southern, very small school and we went against Louisiana State University,
LSU, at LSU and we ended up beating them and they were kind of like, we did
not see that happening. But it was a really good competition, great opportunity
and I also clerked for a Court of Appeals judge in Louisiana for my entire three
level year. So I got a chance to sit in on a lot of oral arguments and have him
kind of mentor me on the litigation process, because he actually kind of helped
coach me outside of the practice that we were doing with the mock trial team.
9
Facilitator 1: That's great. So then you have this sports law interest too. When you had
customers in Trademark Engine that might need other services, did you kind of
help them decide what other services they might need or did you just process
trademark applications?
Interviewee: No sir, I didn't have that much freedom. I wish I did, but I didn't. It was just
processing applications.
Facilitator 1: I see, all right. So I don't have more questions for you right now, but I think we
might be interested in bringing you to Tempe for an interview, but I have to talk
with my team. But we are - I have one actually big question for you, but let me
have Heather and Ryan, if they have any questions, ask them and then I'll ask
my last questions. Go ahead Heather.
Facilitator 2: Well I have a pretty minor question. I'm curious, what is Jordan B. Franklin
Day?
Interviewee: I'm sorry, can you say that one more time?
Facilitator 2: It says proclamation Jordan B. Franklin Day. Can you tell me a little bit about
that? This is going back to when you were a bailer.
Interviewee: Yes, so I actually have my own day here in Houston. I'm super, super involved
in the community and I always have been, even in high school and I'm actually in
the process of starting a legal mentor organization between African-American
women that are currently attorneys and African-American women that are in law
school to kind of bridge that gap. Out of the four per cent of African-Americans
that are attorneys, only about 1.2% are women, so we make up a really, really
small percentage of the legal community, so I kind of wanted to start a
mentorship program to kind of help bridge that gap and kind of have a sense of
community amongst our very small minority group.
So I've always been super, super charged with community efforts and
volunteering and I volunteer with a non-profit here now and we do a lot of stuff
with the arts. Almost quarterly we get together and we get a bunch of volunteers
to come out and we'll go to either Houston Food Bank or we meet up in a location
and we make lunches for the homeless and go throughout the city and pass
them out. So I've always been super passionate about just kind of giving back to
10
the city that helped form me into the woman that I am. The Mayor Bill White a
few years ago actually awarded me with my own day, so that's what that is.
Facilitator 1: That is so impressive, that is - it's…
Facilitator 2: It's very impressive.
Interviewee: Thank you.
Facilitator 1: Man, I didn't expect that that's what that was. That's interesting. So what's
Yellow Rose of Texas, what does that mean? I know that's a song, but what does
that mean? It says Yellow…
Interviewee: Right, it's just kind of like an award that it's not quite like a proclamation of a
day, but it is a recognition award that you get from the Governor. So I got one of
those from the Governor around the same time I got the proclamation from the
Mayor.
Facilitator 1: Wow, so is your family all in Texas, you're well settled there? I mean how
difficult would it be if we made you an offer in Arizona to move and how soon are
you looking to potentially work if we made you an offer, had you come to Arizona
and we made you an offer, how soon afterwards could you potentially work with
us?
Interviewee: Well now that the bar's out the of the way, I can start as soon as find
somewhere to lay my head.
Facilitator 1: Really?
Interviewee: Yeah. However quick that is, I normally can find something fairly quickly. I think
I found my apartment in Louisiana in three days when I moved out there and I
moved out there not having any family or friends in Louisiana or anything. I
wholeheartedly believe that sometimes you have to move and isolate yourself for
the betterment of your career and I have absolutely no problem doing that. My
family understands that. I have a super supportive family and a super supportive
significant other and they're kind of like, if we have to help you pack and drive
you there, by all means we'll do so, if this is what you want to do and what you
need to further your career goal. So that absolutely won't be a problem.
Facilitator 1: That's impressive. So Ryan, do you have questions?
11
Facilitator 3: I did. I was going to ask a few more questions just about the work experience
thus far. So you mentioned that in the past you've worked on some office actions
with your previous employment. Now as you probably know, that can mean a lot
of things. So what is your experience with drafting substantive office actions,
have you done like a response based on a, likelihood of confusion or
descriptiveness refusal, or is this more handling - go ahead and describe what
experience you had in responding to office actions.
Interviewee: Yes sir. I haven't had any substantive as far as writing any on, like a likelihood
of confusion. I have written practice ones for the clinic that I was in because it
was just me. Half of the clinic would be practical when we would actually meet
with and kind of counsel clients and the other half would be more lesson based
and he would actually give me practice exercises on searchers or responding to
office actions.
Of the few that he actually gave us to respond to for homework were substantive
about 1B refusals, so - not 1B refusals, excuse me, 2B refusals. So that is about
the extent that I have actually had. They haven't actually been office-office
actions, most of the ones that I've had have been refusals for ornamental
refusals. That was probably the most popular that I've gotten for people who
were trying to submit, well those t-shirts and that rejected for…
Facilitator 3: Another very quick question on that, so with an ornamental refusal, were these
clients that you had spoken with prior to the filing of the trademarks? So when
the client came in and you were working in - did you advise them, if they send
you a specimen, let's say, that has the name of the t-shirt slogan plastered in
huge letters across the center of it, would you advise the client at the time they
sent it to you that the ornamental refusal was likely?
Interviewee: Yes sir. Actually the ornamental refusals that I've gotten were not originally
clients that I had spoken with. They had gotten rejections and didn't understand
why and then it came to me. So then I was supposed to kind of decipher why
they got the refusal and then I would look at the specimen and kind of see. So I
would normally write them in, okay, this is just a PDF, this isn't like the actual
shirt, is there any way you can transcribe the logo maybe into the tag or make it
smaller and put it in like a pocket onto the left breast or something like that.
12
Facilitator 3: So you would, in your initial conversations with clients, you would offer them
that advice?
Interviewee: Yes sir.
Facilitator 3: Okay, all right. The only other question I had is so you are taking the bar the
second time, the hope would be that when you came and joined us and then you
find out in October - or not October, that's the wrong bar, you find out in May that
you passed, that's the hope.
Facilitator 3: If you don't pass, what would your plan be? Would you want to stay in Arizona,
work as a clerk and give it another go, understanding that obviously your mobility
and your earning potential are kind of limited until you can pass the bar.
Interviewee: Right, yes sir.
Facilitator 2: Understand of course that you could try a different bar.
Facilitator 3: Right.
Interviewee: Right, yes ma'am.
Facilitator 2: That's the beauty of trademark law, is it's a federal practice.
Interviewee: Right.
Facilitator 1: To give you an idea, Jordan, like our attorneys, we'll start at $60K a year, we
have full healthcare benefits, even our assistants, you'll get full healthcare
benefits, dental, vision, $60K a year plus bonus. With bonus, attorneys make 80
or more in in their first year. You can go up very quickly from there, the sky's the
limit. We are a law firm and so there's a lot of opportunity for our growth. I'll talk
about that at the end, but let me let Ryan and Heather please go forward with
their questions.
Interviewee: Yes sir. Ryan, to answer your question, if I - I don't want to put it in the universe
if I don't pass again, but I've never…
Facilitator 3: Yeah, I'm confident you will, but…
Interviewee: Right.
13
Facilitator 3: What was, you mentioned you missed it by nine points, what was the score on
the Uniform? Do you remember the number?
Interviewee: Well Texas, I think for Texas you need a 675 out of 1000 to pass and I got a
666. I already hate that number. My MBE score…
Facilitator 3: Understandably.
Interviewee: For Texas, they like the MBE score to be about - the scale for to be about a
135 and my score was 128 and I did well on the essays, that's never been an
issue for me, I can write pretty well, but the MBE is kind of what's caused my
score to fall shorter than…
Facilitator 2: Okay, I think the reason Ryan asked that question is because I think Texas is
not part of the Uniform Bar Exam, correct?
Interviewee: Yes, that's correct, it's not.
Facilitator 3: All right, well thank you for making my question pointless.
Facilitator 2: He was just checking to see if there is any possibility you potentially had
already called by it in a different state.
Facilitator 3: That's correct, that was right in my mind.
Interviewee: Texas is so backward. Because I went to law school in Louisiana, I spent three
years learning civil law, so bit of a transition trying to come back, so I wasn't
happy that I didn't pass, but I scored higher than people who went to law school
in Texas, so that kind of made me feel a little bit better and kind of help with my
approach this second time. But if I don’t pass it, I'm not opposed to sitting for
another state, I don’t have to be barred in Texas.
Facilitator 2: How did you change your approach this time in terms of study?
Interviewee: I studied more on the MBE because I knew that was my biggest weakness and
I worked it backwards. So whereas at the beginning where I knew I could spend
a little more time, I worked on some subjects that I didn't do the best on.
Common law was probably my weakest subject, but my strongest two were
evidence and real property, which was crazy to me because I hated property, so I
14
kind of worked my way backwards and I spent a lot more time on the MBE trying
to learn the tricks and the loopholes and the tactics to attacking it.
Then a little closer to the exam, I kind of switched my focus - because Texas is
actually three days. So on the first day, I wasn't worried about the first say, I
performed well. We have 40 short answer questions and then an NPT that we do
on the first day. Second day we do the MBE and then the third day is straight
essay. So I kind of focused a lot more of my time on the MBE as opposed to the
other way around because I know writing is my stronger skill as opposed to
taking multiple choice tests. So I was like, okay, attack what you're weaker at and
then kind of work your way to what you know you're a little stronger.
I can memorize a lot of things in a short amount of time, so I wasn't quite worried
about the memorization needed for the essays and things like that, it was just
really, really trying to make sure that I had a solid handle on the MBE and then it
weighs heavier in Texas than the first day, so I was like, make sure I have a solid
handle on it.
Facilitator 2: Okay. Did you have any other questions, Ryan?
Facilitator 3: No, you're good to go if you have any others.
Facilitator 2: Okay, I just had just a couple of other things. Now I know you said that you
were - going back to office action responses and you said that you would
communicate with the client and would tell whether or not things could be used
for a specimen or whatnot. What kind of training did you get with respect to that
and also - so that's what we would consider to be a non-substantive response.
What kind of experience did you have drafting what we would refer to as
substantive responses and that would be, let's say, you're likelihood of confusion
refusal arguments, new descriptive arguments, whatnot.
Interviewee: Through Trademark Engine I didn't really have any substantive training or
opportunity to substantive responses, like they left those purely to the attorneys.
But the training that I did have on it, again, was all just in school, through my
professors. I'll have to find - I know I have samples of arguments that I have
written that he gave us on issue from old clients that he dealt with before he
started practicing. He would bring them into class for - I keep saying us but it was
literally just him and myself in the class. So he would bring them in for me to
15
have kind of like, okay, we'll deal with clients on these days, but today we're
going to work on you being able to draft good arguments for any potential
rejection that you get from the PTO.
Interviewee: So that's what I did with him. I definitely have copies of - I know have them
saved on my hard drive, I can email to you all, if you would like to see them.
Facilitator 2: Yeah, if you could, that would be great.
Interviewee: Yes ma'am.
Facilitator 2: Now I know that you worked on the trademark clinic when you were in law
school.
Interviewee: Right.
Facilitator 2: Was that under the auspices of - I don't even remember what it's called, the -
it's where there's like a temporary admission for the purpose of trialing trademark
applications under [unclear] supervision.
Interviewee: Yes ma'am, I believe so, I'd have to get that information from my professor. I
will talk to him too, he's actually one of my references as well.
Interviewee: Because the clinic was like super, super new, like I literally was the first
student. The paperwork that he filed with the PTO was still pending.
Interviewee: So I'm pretty sure it's cleared by now.
Facilitator 2: Yeah.
Interviewee: But I can definitely try to get that information from him. Like I said, he is one of
my references, Mark [Herrmann], on my resume.
Interviewee: Because I do work so closely with him, I felt like we developed a pretty good
bond. He definitely taught me a lot about the trademark world. So you had
another question.
16
Facilitator 2: Yeah, so how did this work in the trademark clinic at the law school? Did you
have a case file that came in and then you decided whether or not - like how did
it work?
Interviewee: Because we were so new, we kind of had to solicit ourselves and so what he
would make me do and at that time too I was also SBA president for my law
school, so he was like, okay, I know people like you and you speak well, so he
would take me to tech incubators around the city or different start-ups where and
we would - or the public library in the city and then I would give a presentation on
kind of like trademark basics, why they're important to a brand, why they're
valuable to a company and things like that. That's actually how we start to get a
lot of traffic throughout the clinic.
We would kind of meet with people first to see whether or not it was an issue we
could handle because you know, if there was anything that dealt with any type of
litigation, technically we could not handle it, they would have to go through a
lawyer. So we would meet with them first and then kind of gauge it and see. He
normally kind of okay it, if it was something that he knew legally that we could
actually do and if not, then he would recommend that they actually go seek a
licensed lawyer.
Facilitator 2: Okay. All right. I don't think I have any other questions.
Facilitator 3: Do you have any questions for us at this time?
Facilitator 1: Actually before she asks questions, I would like…
Interviewee: Yes sir…
Facilitator 1: Before you have questions for us, I'll give you a couple of things. No, why don't
you ask your questions. Go ahead and ask your questions and I'll ask you my
last questions after that, okay?
Interviewee: Okay, cool. Mr. Raj, I have your email but Heather and Ryan, may I have your
emails so I can send you copies of some of the stuff that I've done? I have a few
memorandums that I've written for clients in clinic as well on some of their
trademark issues that I'd be happy to send over.
Facilitator 3: I'll follow up with an email and I'll copy Heather in it after this call so you don't
have to write everything down.
17
Interviewee: Okay. So my first question for you all would be for the position that you're
looking for filling, what are you looking for in a candidate?
Facilitator 1: Well I think number one say that I first approach you , is someone that is
hardworking, who is passionate about trademark law, who wants to succeed and
better themselves and their community. I like the fact that you've done a lot of
outside work. I like the fact that you have all these interests. Experience, we can
give you experience, you just can't give people self-motivation to succeed.
Interviewee: Right.
Facilitator 3: [Life is hard to teach].
Facilitator 1: So that's the number one thing. So I think ultimately obviously they have to be
good attorneys, they have to be ethical attorneys, they have to abide by the rules
of the professional conduct of lawyers, they have to supervise assistants well and
they have to be efficient ultimately, especially in the trademark space, or they
have to be able to generate new work. Either they have to be very efficient in
trademark work or in the prosecution work, or need to be able to develop rapport
with clients so that we can generate new work and do higher end services for
those clients and basically become their outside counsel for life.
That's kind of what we want to have happen for us to transform ourselves to the
next stage. So unlike companies like Trademark Engine and LegalZoom and
others, we are a law firm, we're also a technology company, but we're a law firm
and a technology company and we value the attorney-client relationship heavily
and we value having our attorneys directly interact with clients. So those are
some of the things. Does that sound like someone like you or not?
Interviewee: Oh absolutely, yes sir. Being the first student in Texas, well in our IP clinic, I
had absolutely no problem going out into the community and bringing in clientele
and bringing in traffic. Like I said, I did that by my professor allowing me to do
talks and things like that to kind of give a general overview and not get too legal
on what a trademark was and how important it was to a business. So I have no
problem drawing in clients. I tend to be a very friendly person and I'm good at not
only starting relationships but maintaining them.
I love trademark work, so I mean even outside of class I would read and research
and write articles on different IP issues, mainly in the fashion industry because
18
that's kind of what interests me a lot, IP in fashion, so I would research things

that were beyond what we would be taught in the classroom setting, because it
was something I was so passionate about.
Facilitator 1: Okay. Yeah and so that hopefully answered your question as well, so do you
have any other questions?
Interviewee: I did, I actually have them written down, let me pull them out.
Interviewee: I guess my question for all of you is what is the one thing that keeps you
coming to work every morning?
Facilitator 1: Go ahead, why don't you guys - I can tell you, I'm an entrepreneur and I only
work because at this point I work for things I would like to build. I'm a builder; I'm
an engineer, so I like to build things. I like to build things that will help small
businesses and small entrepreneurs be able to access law through the internet
as well as through qualified attorneys. I mean it's hard to say, what motivates me
every morning is challenge. I get motivated more by challenge than a lack of
challenge. I get more motivated by discomfort than comfort. So I thrive in chaos, I
stumble in stability. But that's very odd and so I realize that, so I'll let the others
talk who probably are less odd.
Facilitator 3: I'm pretty odd too, I think Heather's probably the most normal of us.
Facilitator 2: Okay, did you want to finish, Ryan?
Facilitator 3: Maybe actually I'll let you finish, because I think you'll have the most on-point
answer. So my day to day is I'm an attorney 20 per cent of the time and an
operations manager 80 per cent of the time. For me, what keeps me in is I think
we've built a great culture of collegiality in our Tempe office. The people there are
all passionate about trademark, they're very friendly, the atmosphere feels - we
all want to get our work done, but it's very collegial. There's not a lot of face time,
worries about face time or putting on airs, it's everyone 's there to get a job done.
You'll find that our entire team, both there and the attorneys who work remotely,
are always available and happy to answer questions. So the people, for me, is
one. Any task that you do for 40 hours a week or 50 hours a week is going to get
redundant and boring, but if you're doing it with people that you enjoy working
with as part of a team, that's what drives you to push harder, well at least for me.
19
The tasks that I'm doing aren't going to be that similar to what you're doing, so I
mean that's probably the most relevant answer. Heather does training and she
also spends a lot - most of her time as a trademark attorney in our office, so I'll let
her probably give the most on-point answer of our three to answer that question
for you.
Facilitator 2: Okay, thank you. So for me, what makes me want to continue to stay here and
continue to come to work, like Ryan said, it is a very collegial office. It's a law firm
but it doesn't feel like a law firm. We had lunch with one of our colleagues the
other day, he left to go to the Attorney-General's office and we were commenting
on how, gosh, I don't think I've ever seen him in his eye. He's like, oh no, you did,
remember Halloween when we dressed as a law firm?
Interviewee: [Laughs].
Facilitator 2: I was like, okay, and that's really, I'd say, a very good snapshot of how we are.
We are a law firm, but we're also a technology company. It's very much a Silicon
Valley technology company that found itself over into a law firm in Tempe,
Arizona, if that makes sense. There's definitely a start-up mentality, there's
definitely a laid-back vibe. We work hard but we're not the people who, in general
- I'd say that probably any one of us could probably go to the big fancy firms in
Phoenix if we wanted to. We don’t want to.
Interviewee: All right.
Facilitator 1: We've had a lot of people that have, so we also have had a lot of associates
who have worked with us that have gone on to work at very large firms and I'm
very proud of them, so people have their journeys in different ways. Ultimately
we're trying to create a place where people who enjoy working with clients and
helping them protect their brands can thrive and have a lot of client interaction.
We also just recently hired one of our associates back who went to a large firm,
who then went to Semantic in house and then he came back to us.
We've hired people like Elizabeth [Pesquine] who is at the USPTO, worked at a
large firm, was a partner of a large firm and now is kind of working with us
because she's not as interested in the pressures of that. We also have talent like
Heather who worked at the USPTO for many, many years. She was my law
school classmate and has got lots of great skills, but really enjoys trademark
20
work and mentoring and teaching others and has been a phenomenal help to our
firm.
So we have this kind of mentality, I mean one of the things about our firm is we
are similar in the sense of Trademark Engine, we are a high volume trademark
law firm. We do have a technology that we built, Trademarkia that generates
clients for us, but we all practice law directly through our RAPC law firm. We
have higher cost structures than entities like Trademark Engine or some of the
other LegalZoom and others like that and that higher cost structure makes it
difficult for us to continue competing and we've got a lot of litigation around that
right now. So if you joined us, you would need to be aware that we are in those
litigations in Federal Court with a lot of our competitors. But you wouldn't be
necessarily involved in that aspect, especially in Tempe because all that's being
handled here in Silicon Valley.
But we are trying to innovate within the guidelines of the legal practice realm and
what is possible to do within the confines of the ethical guidelines of the USPTO
and the various state bars. So we're working within the framework as opposed to
outside the framework and we're trying to innovate within that framework. By
doing so, we believe that we create a higher quality experience for our clients
overall. So does that makes sense to you and is that okay with you?
Interviewee: Yes sir, that's absolutely fine.
Facilitator 1: Okay, yeah, so I'd like to potentially bring you in for an interview in Tempe next
week or whenever you're free, probably the seven day advance notice, so you
can let me know which days you're available either next Friday or the week
thereafter and I'll see if Ryan and Heather are available to fly down for a day. I
might do that, I might not. But I think you seem to have the right background for
us to at least explore the next step, if you're interested. Would that be of interest
to you?
Interviewee: Yes sir, absolutely. I'll start looking at flights as soon as we get off the phone.
Facilitator 1: Yeah, we'll pay for the flights, you just need to tell me which days you're
available and which airport you're flying out of or you could book it and then we'll
reimburse you, either way, whatever you prefer.
Facilitator 2: Just for reference, I'm out of the office March 11 to 16.
21
Interviewee: All right, I can definitely come next week if that work fine with you.
Facilitator 3: I will actually be in Austin, Texas next Thursday/Friday for a deposition, so you
might need - if you could get there Wednesday would be possible, that would a
date both Heather and I are there. If not, we need to postpone.
Facilitator 1: Yeah, so why don't you find flights, Jordan, for next Wednesday to Arizona and
let me know which flights you need. I guess if I'm booking it for you, I'll need your
date of birth or you can book it yourself and we'll reimburse you. So you let me
know, we can book it at our end as well, if you'd like.
Facilitator 1: I think that, Ryan and Heather, do you have any other further questions?
Facilitator 3: Not at this time, no.
Facilitator 2: No. It's been very, very nice to speak with you, Jordan.
Facilitator 1: I assume we can find a reasonable - yeah, if the flights are like $1000,
obviously we're not going to fly you out next Wednesday, so if they're
reasonable, then we will do it next Wednesday, otherwise we'll have to wait till
Heather comes back. But we are looking for people with your background, so you
have the right background for what we need. How much do you know about us?
How much do you know about our firm? How much research have you done on
us?
Interviewee: I started doing some research last night after you contacted me, so I have
definitely seen that you guys are in California as well as in Arizona. I do like the
diversity that you have in your team because I was kind of - I didn't want to super
stop everybody, but I was looking at the tab on the website that said about the
team, so I did like that there's an array of people and different backgrounds too, I
thought that was pretty awesome when I was looking.
Facilitator 3: There's a lot more diversity and it doesn't go into those bios as well, so that's
something we pride ourselves in.
Interviewee: That makes me really excited. I like environments like that because I feel like
there's so many different things you can learn from people that went to different
schools, have different professional backgrounds, personal backgrounds and
22
things like that. So I enjoy environments like that. I feel like it makes you a
well-rounded individual when you can kind of pull from different people.
Facilitator 1: Well great, okay. All right, why don't you find flights and then if you want me to
book it, just give me your date of birth and I'll book you a flight. If you want to
book it yourself, you can do that and then just send me the receipt and Ryan can
reimburse you when you're in Arizona. But if it's under $500 it's fine, if it's over
$500, we need to wait for the next week after next week, okay?
Interviewee: Yes sir, I can definitely do that.
Facilitator 1: Okay. Ryan, Heather, do you have any other questions for Jordan?
Facilitator 2: No, I greatly enjoyed speaking with you.
Interviewee: Thank you, I enjoyed speaking with you as well.
Facilitator 3: Just maybe if you work on that and I will follow up with an email so you have
Heather and my emails. If you have any questions between now and when the
next interview is, don't hesitate to ask. I know that we didn't go over sort of B&A,
so if you wanted to set up an interview with just one of us, walk you through what
the B&A process is for both our clerks and our attorneys, I think that would give
you a better idea of what you could expect when and if you accept an offer at our
firm.
Interviewee: Yes sir, I will definitely do that.
Facilitator 3: All right, so I have nothing else then. Thanks for your time, I really appreciate
talking with you today, Jordan.
Interviewee: Thank you Ryan, I enjoyed speaking with you as well.
Facilitator 1: Thank you.
Facilitator 2: Thank you, bye-bye.
Facilitator 1: Bye-bye.
END OF TRANSCRIPT
23
EXHIBIT G
12/12/2017 Trademark/Service
Case 3:17-cv-07303-MMC DocumentMark Application,
107-1 FiledPrincipal Register Page 61 of 73
08/10/18
United States Patent and Trademark Office
Trademark Electronic Application System - TEAS Application
Under the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless it displays a valid OMB control number.
PTO Form 1478 (Rev 09/2006)
OMB No. 0651-0009 (Exp. 02/28/2018)
Trademark/Service Mark Application, Principal Register

Version 5.10 - Validation Page
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(3) Be aware that private companies not associated with the USPTO often use trademark application and registration information from the USPTO's
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EXHIBIT H
RAJ V. ABHYANKER, California SBN 233284

Email: raj@legalforcelaw.com
WENSHENG MA, California SBN 299961
Email: vincent@legalforcelaw.com
LEGALFORCE RAPC WORLDWIDE, P.C.

1580 W. El Camino Real, Suite 10
Mountain View, CA 94040
Telephone: (650) 965-8731
Facsimile: (650) 989-2131
Attorneys for Plaintiff,

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
LEGALFORCE RAPC WORLDWIDE, Case No.: 3:17-CV-07303-MMC

P.C.,
DECLARATION OF RANDALL HULL IN
Plaintiff, SUPPORT OF PLAINTIFF’S SECOND
AMENDED COMPLAINT
v.
TRADEMARK ENGINE LLC;

TRAVIS CRABTREE; and DOES 1-50,
INCLUSIVE,
Defendants.
1. I, Randall Hull, make this declaration in support of Plaintiff’s Second Amended

Complaint.
2. The matters stated in this declaration are true to my personal knowledge, and if called
upon I could and would testify competently thereto.
1
DECLARATION OF RANDALL HULL IN SUPPORT OF PLAINTIFF’S SECOND AMENDED COMPLAINT
CASE NO. 3:17-CV-07303-MMC
3. I am a Legal Assistant of LegalForce RAPC Worldwide, P.C. having a principal place of

business at 1580 W. El Camino Real Suite 10, Mountain View, CA 94040.
4. Prior to becoming a Legal Assistant I worked as a Creative Director and Graphic
Designer for three decades and am experienced with photography and using retouching tools
such as Adobe Photoshop.
5. It is my belief that specimens shown in Exhibits 1-4, which were submitted to the United
States Patent and Trademark Office (“USPTO”) as the specimens of the trademarks’ actual use
in commerce, are fake or fraudulent specimens made up using computer graphic retouching
tools.
6. The Pinch and Whisk specimen image (Serial #87819123, FTK0003.jpg) shown in
Exhibit 1, which was submitted to the USPTO as a specimen of use in commerce, is not actual
photographs of the trademark as it appears on product packaging in commerce. Rather, the
specimen is three contrived images with the trademark retouched onto digitally created labels
which were digitally inserted into two photographs. First, the images on the left and upper right
of the specimen are the same photograph. This can be determined by looking at the highlights
and imperfections on the glass. If these were separate photographs of the front and back of the
jar, with product labels in place, those details would not be exactly the same. Secondly, in the
three images the purported product labels not only do not conform to the shape of the glass jar
or the lid, as they would if they were real labels at the time the photograph was taken, they
contain the Adobe Spark branding, which would not appear in commercially produced product
labels applied to the product. Adobe Spark is a free online and mobile graphic design
application that makes it easy for people without Adobe Photoshop to add text and graphics to
photos. Images created using the free version of Adobe Spark will contain the Adobe Spark
branding which cannot be removed. (See https://spark.adobe.com) This specimen is nothing
more than poorly mocked up images, not photographs of actual product using the trademark in
commerce.
7. The Reaper specimen image (Serial #87787183, FTK0003.jpg) shown in Exhibit 2
alongside photos downloaded from the reaperskateboarding.com website for comparison, was
2
submitted to the USPTO as a specimen of use in commerce by Travis Crabtree. There are
tell-tale signs that the proposed trademark was not on the T-shirt at the time the photograph was
taken, but was digitally added later. First, when a design is applied to the cloth material of a
T-shirt by mechanical means (i.e.: heat transfer appliqué, ink jet, or silkscreen) its texture is
affected by the cloth texture, and being a flexible material itself, it will conform to the wrinkles
and draping of the material as well as the contours of the human body when the shirt is worn. In
the subject photo there is a slight drape descending vertically from the left shoulder blade of the
model wearing the shirt as well as a brighter light in the spine area which darkens as the shirt
material curves to the left and to the right following the contours of the model's back. The
design intersects the draping of the shirt and would arc as it conforms to the shape of the cloth if
it was on the T-shirt at the time the photograph was taken. However, the specimen photo
(FTK0003.jpg) shows no such conforming, but rather a straight line on the design. Further, the
varying ranges of light would cause shadows and highlights on the design itself, particularly on
the right portion of the draping and to the center of the design where the most light appears on
the shirt material. The lack of these variations in light and tone and the “flat” appearance of the
design, indicates the design was digitally "pasted" onto the photo of the shirt. Second, the focal
point of the design is not the same as that of the shirt. The shoulder area in the photo is not as
sharply “in focus” as is the design. These focal points would match if the design were on the
T-shirt at the time the photograph was taken. That is part of the physical properties of how a
camera captures light. Third, the digital artifacts in the shirt and the “rasterizing” along the
edges of the shirt and its background are different than the edges of the design. This difference
would not occur if the design was actually on the surface shirt. The side-by-side comparison of
the three T-shirt photos also shows that a single T-shirt was used as a “base” for making product
images. Note the wrinkles and shadows on the left and right shoulders and harms. In each of the
three side-by-side comparisons they are exactly t he same. A fourth T-shirt with a different
design on it also has the exact same wrinkle and shadow pattern. That would not happen with
different T-shirts even if they were photographed at the same time.
8. The CALIJUANA specimen image (Serial #87817340, FTK0003.jpg) shown in Exhibit
3
3, which was submitted to the USPTO as a specimen of use in commerce, is not a photograph of
the trademark actually printed on a T-shirt with a product hang tag used in commerce. The
specimen is a contrived image with the CALIJUANA trademark and design digitally added to
an existing photograph of a male model wearing a heather fabric T-shirt available from several
Internet Websites. An Internet search using Tineye.com and Google Image Search brought up
several instances of the male model photograph on other Websites—most notably OrangeHalo
(https://bit.ly/2Ot8HAv). There are tell-tale signs of retouching and elements added digitally.
First, the hang tag was digitally inserted into the photograph because what would be the chain
or string to attach it to the T-shirt does not loop through the hole in the top of the hang tag as the
actual fastening material would. The chain or string does not follow the natural contours of the
model’s neck and shoulder nor does it show the shadows real material would create on the
model’s skin. Also, the hang tag itself lacks any shadow which would be present as it hangs
down over the T-shirt neckline and fabric. Further, the hang tag would not hang perfectly
vertical as shown. It would protrude slightly forward at the base following the contours of the
model’s lower neck and upper chest intersection, and consequently have variations in its surface
tone due to the lighting from above, which can be determined by looking at the shadows under
the model’s chin and T-shirt sleeves. Moreover, none of the photographs found on the Internet
had a hang tag. Second, as in Exhibit 3 discussed above, when a design is applied to the cloth
material of a T-shirt its texture is affected by the cloth texture, and being a flexible material
itself, it will conform to the draping of the material as well as the contours of the human body
when the shirt is worn. In the subject photo the trademark and design span the chest of the male
model and would arc slightly conforming to the shape of the cloth if it was on the T-shirt worn
by the model at the time the photograph was taken. However, the specimen photo
(FTK0003.jpg) shows no such conforming, but rather the letters of the trademark appear in a
straight line across the T-shirt.
9. In my specimen research I only sampled a small number of Trademark Engine’s
trademark filings with the USPTO, but from those the instant four stood out as blatantly fake or
fraudulent. Should a larger sampling be searched, I believe even more fabricated specimens
4
would be discovered.
10. I declare under the penalty of perjury that the foregoing is true and correct.
Dated: August 10, 2018 Respectfully submitted,
/s/ Randall Hull_______________

Randall Hull
Signed at Mountain View, California
5
Exhibit 1
Pinch and Whisk Specimen

submitted to USPTO,
Serial No. 87819123,
FTK0003.JPG.
The images on the left and upper right of
Purported photographs of
the specimen are the same photograph.
trademark on product.
This can be determined by looking at the
highlights and imperfections on the glass.
The product label does not The purported labels contain the Adobe
conform to the shape of the Spark application branding, which would
glass jar. not appear in commercially produced
product labels applied to the product.
Exhibit 2
Photo used for USPTO 87787183 Specimen Reaper Skateboarding Website Product Photo: Reaper Skateboarding Website Product Photo:
FTK0003.JPG IMG_3408.PNG 62E819F7-A5A2-4E6F-95AC-108641D9DAA8
The three photos above are the same shirt colorized after the photograph
was taken. NOTE the wrinkle and draping pattern on the shoulders, at
the elbows, and across the back are EXACTLY the same. That would not
happen with different T-shirts.
NOTE the same pattern

appears in this shirt
even though it has a
different logo design on it.
Reaper Skateboarding Website Product Photo:

3F46FFFA-D7F0-499F-9B94-3D57335DAF0B
Exhibit 3
CALIJUANA Specimen 2
submitted to USPTO, Serial
No. 87817340, FTK0003.JPG.
Purported image of trademark
currently used in commerce.
Screen-shot of same male

model in t-shirt image found on
OrangeHalo.com

LegalForce v. Trademark Engine (Second Amended Complaint) Filed August 10, 2018

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Case 3:17-cv-07303-MMC Document 107 Filed 08/10/18 Page 1 of 28

RAJ V. ABHYANKER, California SBN 233284

LEGALFORCE RAPC WORLDWIDE, P.C.

Attorneys for Plaintiff,

UNITED STATES DISTRICT COURT

LEGALFORCE RAPC WORLDWIDE, Case No.: 3:17-CV-07303-MMC

1. LegalForce RAPC Worldwide, P.C. (“Plaintiff” or “RAPC”) complains and alleges

Defendants have waived their objections to personal jurisdiction. ​See ​Dkt. 41 at 2.

c. Customer #9 confirmed to Plaintiff’s counsel that when she saw TE claiming on

f. Advising applicants on substantive examination issues, such as the acceptability

investment services in the nature of purchasing and selling of real

month trying to determine the classification.” ​See Id. a​ t 13.

b. At no time do we review your answers for legal sufficiency, draw legal

Respectfully submitted this Friday August 10, 2018.

LEGALFORCE RAPC WORLDWIDE P.C.

/s/ Raj V. Abhyanker​______

JURY TRIAL DEMANDED

Respectfully submitted this Friday August 10, 2018.

LEGALFORCE RAPC WORLDWIDE P.C.

By__​/s/ Raj V. Abhyanker​______

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List of harmed customers of Trademark Engine LLC:

1. Customer J.R. in California requested a filing of a trademark application

2. Customer C.R. in Indiana ​requested a filing of a trademark application through

3. Customer J.S. in California ​requested a filing of two trademark applications

4. Customer M.C. in New York ​requested a filing of a trademark application

5. Customer M.D. in Maryland ​requested a filing of a trademark application

6. Customer E.T. in California ​requested a filing of a trademark application

7. Customer J.J. in New York ​requested a filing of a trademark application through

8. Customer F.G. in Santa Clara County, California ​requested a filing of a

9. Customer G.C. in Rhode Island ​requested a filing of a trademark application

through Trademark Engine on or about March 2018. G.C. confirmed to Plaintiff’s

10. Customer D.M. in Ohio ​requested a filing of a trademark application through

11. Customer C.P. in Texas ​requested a filing of a trademark application through

12. Customer A.W. in Tennessee ​requested a filing of a trademark application

Defendants have waived their objections to personal jurisdiction. See Dkt. 41 at 2.

month trying to determine the classification.” See Id. a t 13.

/s/ Raj V. Abhyanker______

By/s/ Raj V. Abhyanker____

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2. Customer C.R. in Indiana requested a filing of a trademark application through

3. Customer J.S. in California requested a filing of two trademark applications

4. Customer M.C. in New York requested a filing of a trademark application

5. Customer M.D. in Maryland requested a filing of a trademark application

6. Customer E.T. in California requested a filing of a trademark application

7. Customer J.J. in New York requested a filing of a trademark application through

8. Customer F.G. in Santa Clara County, California requested a filing of a

9. Customer G.C. in Rhode Island requested a filing of a trademark application

10. Customer D.M. in Ohio requested a filing of a trademark application through

11. Customer C.P. in Texas requested a filing of a trademark application through

12. Customer A.W. in Tennessee requested a filing of a trademark application

13. Customer A.A. in Texas requested a filing of a trademark application through

14. Customer C.A. in Texas requested a filing of a trademark application through

15. Customer S.B. in Texas requested a filing of a trademark application through

16. Customer T.O. in Maryland requested a filing of a trademark application

17. Customer T.C. in San Francisco County, California requested a filing of at

18. Customer R.B. in New York requested a filing of a trademark application

19. Customer R.S. in California requested a filing of at least two trademark

20. Customer L.W. in Texas requested a filing of a trademark application through

21. Customer R.A. in Santa Clara County, California requested a filing of a

22. Customer Z.K. in Oregon requested a filing of two trademark applications

23. Customer S.F. in Oregon r equested a filing of a trademark application through

24. Customer S.N. in Texas requested a filing of a trademark application through

25. Customer S.S. in California requested a filing of a trademark application

26. Customer F.D. in Wisconsin requested a filing of a trademark application

27. Customer R.M. in Texas requested a filing of a trademark application through

28. Customer M.S. in Texas requested a filing of a trademark application through

29. Customer H.J. in Michigan requested a filing of a trademark application through

30. Customer S.F. in Texas requested a filing of a trademark application through

31. Customer J.H. in Florida requested a filing of a trademark application through

32. Customer M.P. in Missouri requested a filing of two trademark applications

33. Customer W.K. in Connecticut requested a filing of a trademark application

34. Customer R.F. in Colorado requested a filing of a trademark application

35. Customer J.J. in Georgia requested a filing of a trademark application through

36. Customer L.A. in Utah requested a filing of a trademark application through

37. Customer L.S. in South Carolina requested a filing of a trademark application

38. Customer K.G. in Colorado requested a filing of a trademark application

39. Customer K.K. in Michigan requested a filing of a trademark application

40. Customer K.F. in Texas requested a filing of a trademark application through

41. Customer W.W. in Georgia requested a filing of a trademark application through

42. Customer G.M. in Texas requested a filing of a trademark application through

43. Customer Y.B. in Florida requested a filing of a trademark application through

44. Customer J.S. in Kentucky requested a filing of a trademark application

45. Customer D.P. in New York requested a filing of a trademark application

46. Customer K.A. in Virginia requested a filing of a trademark application through

47. Customer A.G. in Michigan requested a filing of a trademark application

48. Customer B.M. in California requested a filing of two trademark applications

49. Customer P.L. in New York requested a filing of a trademark application

50. Customer T.J.D. in Maryland requested a filing of a trademark application

51. Customer J.F. in Washington requested a filing of a trademark application

52. Customer A.L. in Ohio requested a filing of a trademark application through

53. Customer M.B. in Georgia requested a filing of a trademark application through

54. Customer F.K. in Montana requested a filing of a trademark application through

55. Customer A.S. in California requested a filing of a trademark application

56. Customer E.S. in Maine requested a filing of a trademark application through

57. Customer S.P. in Florida requested a filing of a trademark application through

58. Customer A.A. in New York requested a filing of a trademark application

59. Customer J.D. in Florida requested a filing of a trademark application through

61. Customer K.S. in Indiana requested a filing of a trademark application through

65. Customer J.C. in Arizona requested a filing of a trademark application through

66. Customer A.B. in New Hampshire requested a filing of a trademark application

67. Customer S.L. in Wisconsin requested a filing of a trademark application

68. Customer J.B. in North Carolina requested a filing of a trademark application

69. Customer D.S. in New Jersey requested a filing of a trademark application

70. Customer F.W. in Georgia requested a filing of a trademark application through

71. Customer S.D. in New Jersey requested a filing of a trademark application

72. Customer S.E. in Ohio requested a filing of a trademark application through

73. Customer R.B. in Oregon requested a filing of a trademark application through

74. Customer S.G. in California requested a filing of a trademark application

75. Customer T.G. in Colorado requested a filing of a trademark application

76. Customer T.P. in Maryland requested a filing of a trademark application through

77. Customer T.K. in Washington requested a filing of a trademark application

78. Customer R.E. in Florida requested a filing of a trademark application through