COMPLAINT Against Fraudulent & Misleading Trademark Mailer Entities Via USPS Impersonating The USPTO Against All Defendants

3/25/2019 Complaint - Fraudulent
Case 5:19-cv-01538 Document 1 Filed Mailers - Google Docs

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RAJ V. ABHYANKER, SBN 233284

Email: raj@legalforcelaw.com
WENSHENG MA, 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 JOSE DIVISION
LEGALFORCE RAPC WORLDWIDE, Case No. 19-1538

P.C.;
COMPLAINT FOR:
Plaintiff, 1. LANHAM ACT, 15 U.S.C. § 1125(a);
2. CALIFORNIA FALSE &
v. MISLEADING ADVERTISING;
3. CALIFORNIA UNFAIR
ITP SERVICE; WTP; ITR REGISTER; COMPETITION; AND
GLOTRADE S.R.O.; WTMR LLC; 4. INTENTIONAL INTERFERENCE
PATENT & TRADEMARK RESOURCE WITH PROSPECTIVE ECONOMIC
CENTER LLC, TRADEMARK ADVANTAGE.
RENEWAL SERVICE, PATENT &
TRADEMARK OFFICE LLC, PATENT & JURY TRIAL DEMANDED
TRADEMARK BUREAU, U.S.
TRADEMARK COMPLIANCE OFFICE,
USTM CORPORATION; USA BOX, INC.;
SIGLO-21, INC.; U.S. GLOBAL MAIL,
INC.; SERVCORP WASHINGTON LLC;
PREMIER OFFICE CENTERS, LLC;
REGUS MANAGEMENT GROUP LLC;
LAWYERS’ CHOICE SUITES, INC.; AND
STAT OFFICE SOLUTIONS, and
DOES 1-1000;
Defendants.
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1. LegalForce RAPC Worldwide, P.C. (“RAPC” or “Plaintiff”) alleges as follows

against the above captioned defendants including ITP Service (“ITP”), WTP, ITR Register
(“ITR”), GLOTRADE s.r.o. (“GLOTRADE”), WTMR, LLC (“WTMR”), Patent &
Trademark Resource Center LLC (“PTRC”), Trademark Renewal Service (“TRS”), Patent
& Trademark Office LLC (“PTO”), Patent & Trademark Bureau (“PTB”), U.S. Trademark
Compliance Office (“USTCO”), USTM Corporation (“USTM”) (collectively “Mailer
Defendants”), and USA Box, Inc. (“USA Box”), Siglo-21, Inc., U.S. Global Mail, Inc.
(“U.S. Global Mail”), Servcorp Washington LLC (also known as Servcorp US Holdings
Inc.), Premier Office Centers LLC, Regus Management Group, LLC; Lawyers’ Choice
Suites, Inc., and The Stat Organization, (“Logistics Enablers”) (collectively with Mailer
Defendants as “Defendants”) upon actual knowledge with respect to themselves and their
own acts, and upon information and belief as to all other matters.
INTRODUCTION
Proliferating Trademark Scams
2. There is a troubling trend growing in the shadows of the trademark world.
Unscrupulous profiteers are setting up a revolving door of official-U.S. government
sounding entities to prey on the fears of individual and small business trademark applicants
before the United States Patent & Trademark Office (USPTO). These shadow scammers use
publicly available trademark filer information to send targeted “solicitations” to the
trademark applicants. The “solicitations” are constructed to make the trademark applicant
believe that an official U.S. government agency or the USPTO itself is sending a letter to
them, raising fear among the unsuspecting public that they must pay large amounts of
money or forfeit trademark rights. To attempt covering tracks and evading liability, small
typeface print often appears to disclaim what is obsensibly represented in the larger text and
thematically throughout the postal mailer. Contact information of these companies is
dubious at best. New names, new addresses, and new postal boxes are a common practice
by these entities to make it more difficult to identify them. Most of these mailers and the
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purported services they advertise to provide result in no value to trademark owners.

3. Most of these predatory entities’ tentacles appear to originate, or be strongly tied to,
countries outside the United States (most frequently from eastern Europe), but they work
with enablers in the United States to set up domestic addresses and put on the appearance of
legitimacy in order to further cloak their scheme.
4. Several trademark organizations have tried to raise awareness and warn others
about these harmful unsolicited offers for trademark services.
5. The International Trademark Association (“INTA”), a global association of
intellectual property owners and professionals, warns of these unsolicited offers that cull
public records for trademark owners’ information and then send an official looking form for
payment to “publish” or “register” the trademark, but the offered services are often
“unnecessary or duplicate the services provided by the government office.” See
http://www.inta.org/TrademarkBasics/FactSheets/Pages/UnsolicitedOffersUS.aspx. A
printout of this warning is attached as Exhibit 1.
6. INTA describes the scam as follows:
This is how the trick works. Armed with your trademark, name, and address
and similar information for thousands of other trademark owners, these
companies mass-mail or email an official-looking form requesting the
payment of fees (usually an odd amount, such as $587.00) to “publish” or
“register” your trademark. The services they offer often are unnecessary or
duplicate the services provided by the government trademark office. In other
situations, the mailing may offer what might otherwise be a legitimate service
(e.g., a trademark watch service), but under false pretenses (e.g., by using a
name, such as “USTPA,” that sounds like an official government agency).
Id.
7. Similarly, the United States Patent and Trademark Office (“USPTO”) published a list
and examples of these solicitations with a warning that “[s]ome trademark applicants and
registrants have paid fees to private companies, mistakenly thinking they were paying fees
required by the USPTO. We do not endorse any of these private companies and you are not
required to use them.”
See https://www.uspto.gov/trademarks-getting-started/caution-misleading-notices.
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8. A printout of USPTO’s warning is attached as Exhibit 2 (including highlights of

various entities named or mentioned in this complaint).
9. The USPTO further notes that since it is not an enforcement agency, it cannot
legally stop these companies sending out the deceptive unsolicited offers and can only
attempt to raise awareness of the deceptive conduct. See id. Specifically, the USPTO
asks those who have paid money to companies to send an email to
TrademarkAssistanceCenter@uspto.gov, which in effect appears to do nothing but
document the practice on the USPTO’s website.
10. In order to raise awareness and attempt to address the issue, the USPTO held a
“Roundtable on Fraudulent Solicitations to Trademark Owners” on July 26, 2017. In the
transcript of that event, available on USPTO’s website, the USPTO Commissioner for
Trademarks, Mary Denison, remarked as follows:
Fraudulent solicitations may come in several different forms. They might
come in a renewal scam format, they might come in a useless database scam,
they might be a monitoring scam, or they might be something related to
customs and border protection recordation. So, there are a lot of variations on
this, but the one thing that we do know is that they keep coming.
See
https://www.uspto.gov/sites/default/files/documents/Transcript_FraudulentSolicitations.pdf
at 5:10-17. A printout of the relevant excerpt of the transcript is attached as Exhibit 3. The
Mailer Defendants’ actions described below fall into all of these categories.
11. Internationally, the European Union Intellectual Property Office (“EUIPO”), notes
that “[u]sers are receiving an increasing amount of unsolicited mail from companies
requesting payment for trade mark and design services such as publication, registration or
entry in business directories.” The EUIPO provides a searchable database of examples of
these unsolicited offers to help people “avoid misleading payment requests.” See
https://euipo.europa.eu/ohimportal/en/misleading-invoices. A copy of the EUIPO warning is
attached as Exhibit 4 (including entities named or mentioned in this complaint).
12. Additionally, the World Intellectual Property Organization (“WIPO”), a United
Nations agency that encourages nations to cooperate on protecting intellectual property, also
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has a warning regarding the unsolicited offers, listing examples, and giving advice on
“mitigating this unscrupulous practice.”
13. See https://www.wipo.int/pct/en/warning/pct_warning.html. A printout of WIPO’s
warning is attached as Exhibit 5 (including highlights of various entities named or
mentioned in this complaint).
14. In the past year alone, after RAPC decided to take the added step to further protect
its clients by listing it own address as care of (c/o) owner address, RAPC has received about
3,000 of these deceptive unsolicited offers addressed to Plaintiffs or to RAPC’s clients, and
RAPC continues to receive dozens every week.
15. The deceptive mailers demand payments ranging from $495 (USTM) to $2,890 (Glo
Trade). Often these mailers are sent to U.S. customers from European entities that clearly
provide no service to assist U.S. customers with protecting their U.S. trademarks. RAPC
received several of these mailings from entities such as TMP Register in Poland; Trademark
Edition in Hungary, Malta, or Curacao (depending on which mailer and postmark is received
that day); and multiple confusingly similar entities out of the Czech Republic—IPTR s.r.o.,
IPTA s.r.o., and WPTR s.r.o. See Exhibit 36 (showing copies of these mailers and envelopes
that have been redacted for client privacy).
16. These entities are listed on multiple websites with warnings about the scams that
these entities are running through these misleading mailers. See Exhibit 2 for USPTO’s
warning listing specific entities, Exhibit 4 showing a small sample of entities listed by the
EUIPO, and Exhibit 5 for a list from the WIPO (including highlights of various entities
named or mentioned in this complaint); see also Exhibit 37 showing a warning from the
German Patent and Trade Mark Office (DPMA) and other articles that specifically reference
several of the entities from this complaint (relevant entity names are highlighted). Many of
these entities appear to be related and change their names often in order to continue the
scams by trying to prevent U.S. consumers from easily locating the negative articles and
reviews on the internet.
17. RAPC’s clients regularly reach out to RAPC about the deceptive unsolicited offers
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because they are confused as to whether the notices originate from RAPC, a legitimate U.S.
online advertiser/law firm, or from the U.S. government and worry that by not paying the
fee their trademark is at risk. The fraudulent solicitations have also been directed by email
and attempt to confuse the sender into thinking it is originating from the government or a
legitimate company. A printout of one such email, redacted for privacy and confidentiality,
is attached as Exhibit 35. A percentage of RAPC’s clients have and are likely to continue
acting on such notices resulting in harm to trust in the legal profession as a whole, with
RAPC, the legal framework of the United States of America, and with the USPTO generally.
THE PARTIES
Plaintiff
18. RAPC is a California professional corporation with a principal place of business 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.
Defendants
19. Upon information and belief, ITP is a business entity of unknown form, with an
address at 8345 NW 66 ST #2000, Miami, FL 33166-7896, doing business in Florida,
California, and elsewhere in the United States.
20. Upon information and belief, WTP is a business entity of unknown form, with an
21. Upon information and belief, ITR is a business entity of unknown form, with an
22. Upon information and belief, GLOTRADE is a business entity of unknown form
with an address at 1321 Upland Drive, Suite 8441, Houston, TX 77043-4718, doing
business in Texas, California, and elsewhere in the United States.
23. Upon information and belief, WTMR is a limited liability company with an address
at 1717 Pennsylvania Ave NW, Ste 1025, Washington, DC 20006, doing business in
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Washington, D.C., California, and elsewhere in the United States.

24. Upon information and belief, PTRC is a limited liability company with an address at
17200 153rd Ave SE, Yelm, WA 98597, with Oleg Popko as the sole member/manager, and
doing business in Washington, California and elsewhere in the United States.
25. Upon information and belief, TRS is a suspended California corporation with a
principal place of business at 8380 Miramar Mall Suite 232, San Diego, California 92121,
an address at 910 17th St. NW 8th Floor, Washington, DC 20006, doing business in
Washington, D.C., California, and elsewhere in the United States.
26. Upon information and belief TRS is also known under several alternate names,
including Corporate Compliance Center, United States Patent Renewal Services, Fictitious
Business Name Renewal Service, Renewal Services, Inc., and Compliance Filings, Inc.
27. Upon information and belief, PTO is a limited liability company with an address at
299 Park Avenue, 6th Floor, New York, NY 10171, doing business in New York, New
Jersey, California and elsewhere in the United States.
28. Upon information and belief, PTB is a business entity of unknown form, with an
address at 1500 Market Street, 12th Floor, East Tower, Philadelphia, PA 19102, doing
business in New York, Pennsylvania, California, and elsewhere in the United States.
29. Upon information and belief, USTCO is a Delaware corporation with an address at
1201 N. Orange St. Suite 7459, Wilmington, DE 19801, doing business in Delaware,
30. Upon information and belief, USTM is an Idaho corporation with an address of PO
BOX 51688, Idaho Falls, Idaho 83405-1688, Directors, Ernesto Melo and John (Jack)
Briggs, doing business in Idaho, California, and elsewhere in the United States.
31. Upon information and belief, USA Box is a Florida corporation with a principal
place of business at 84345 NW 66 ST, Miami, Florida 33166.
32. Upon information and belief, Siglo-21, Inc. is a New York corporation with a
principal place of business at 244 Madison Ave, New York, NY 10016.
33. Upon information and belief, U.S. Global Mail is a Texas corporation with a
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principal place of business at 1321 Upland Drive, Houston, TX 77043.

34. Upon information and belief, Servcorp Washington LLC (also known as Servcorp
US Holdings, Inc.) is a Delaware limited liability company with a place of business at 1717
Pennsylvania Ave NW, Ste 1025, Washington, D.C. 20006.
35. Upon information and belief, Regus Management Group LLC is a Texas limited
liability company with places of business at 299 Park Avenue, 6th Floor, New York, New
York, 10171 101 Hudson Street, Suite 2100, Jersey City, New Jersey 07302, and 1500
Market Street, 12th Floor, East Tower, Philadelphia, Philadelphia 19102.
36. Upon information and belief, Lawyers’ Choice Suites, Inc. is a Washington, D.C.,
corporation with a principal place of business at 910 17th Street NW #800, Washington, DC
20002.
37. Upon information and belief, Stat Office Solutions (also known as Stat International,
a division of the Stat Organization) is a Delaware company with a principal place of
business at 1201 N. Orange Street, Suite 700, Wilmington, Delaware 19801.
JURISDICTION AND VENUE
38. This Court has subject matter jurisdiction under federal question jurisdiction (28
U.S.C. § 1331) because the Mailer Defendants violated the Lanham Act and USA Box
knowingly aided and abetted those violations, which is ongoing. This court has
supplemental jurisdiction over the California FAL and UCL claims under 28 U.S.C. § 1367
because the state law claim arises from the same nucleus of operative facts as the Lanham
Act claim.
39. This Court has general personal jurisdiction over TRS because it is a California
corporation. This Court has specific personal jurisdiction over the Defendants because each
has minimum contacts with California. Each Mailer Defendant has purposefully directed its
unsolicited offers to consumers in California and USA Box has directly enabled ITP, WTP,
and ITR’s offers sent to consumers in California. USA Box also purposefully directs its
website to consumers in California to provide a mailbox and forwarding service in Florida.
These activities are intentional acts expressly aimed at California consumers and are likely
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to cause harm in California. Plaintiff’s claims arose out of these activities and exercising
jurisdiction over Defendant would not be unreasonable.
40. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391.
FACTS COMMON TO ALL CLAIMS
Plaintiff’s Business
41. RAPC has clients for intellectual property services in all 50 states and more than 300
cities and towns across America. RAPC offers services including trademark preparation and
prosecution, patent preparation and prosecution, copyright registration and counseling,
international trademark and patent filings, and corporate formation and stock and equity
structuring, etc.
42. RAPC’s clients include individuals and small, midsize, and large businesses and
organizations. RAPC’s trademark attorneys are qualified to practice before the United
States Patent and Trademark Office (“USPTO”). Among other services, RAPC specializes
in assisting its clients with obtaining and maintaining trademark and patent protection for
their intellectual property rights.
Defendants’ Activities
43. Upon information and belief, the Mailer Defendants choose company names meant
to appear as “official” as possible to elicit payments from the public for unnecessary
services that duplicate what the USPTO and other government agencies do without charge.
This includes using website addresses with the top level domains of “.org”, “.us”, and
“.world” as part of the address to further cloak the private companies with the false
appearance of an official governmental entity.
44. An appearance of being an official agency is furthered by using names that sound
similar to official international and U.S. agencies like WIPO or EUIPO and the United
States Patent and Trademark Office. The Mailer Defendants in this case use this same trick:
ITP, WTP, ITR, WTMR (also marketed as World Trademark Register), ITR, GLOTRADE
(also marketed as Global Trademarks Protection), Patent & Trademark Resource Center,
Patent & Trademark Office, Patent & Trademark Bureau, U.S. Trademark Compliance
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Office, USTM Corporation (also marketed as U.S. Trademark Trademark Assistance and
USTM Information Services), Trademark Renewal Service, etc.1
45. Upon information and belief, the Mailer Defendants also manipulate their mailing
addresses to further the illusion of an official agency. This includes using a U.S. address
rather than a foreign address or not listing the city in the address.
A. ITP, WTP, and ITR
46. ITP lists on its unsolicited offers an Internet website address of
www.itp-service.com. A printout of the website homepage is attached as Exhibit 6.
47. WTP lists on its unsolicited offers an Internet website address of
www.wtp-register.com. A printout of the website homepage is attached as Exhibit 7.
48. ITR lists on its unsolicited offers an Internet website address of
www.itr-service.com. A printout of the website homepage is attached as Exhibit 8.
49. ITP, WTP, and ITR all list foreign addresses on their websites—Croatia for ITP, and
Poland for WTP and ITR; however, all provide the same Miami, Florida address in the
unsolicited offers for where to send the checks—8345 NW 66 ST #2000, Miami, FL
33166-7896. In fact, ITP and WTP do not reference any other country or foreign address
anywhere in the unsolicited offers. Examples of the ITP, WTP, and ITR unsolicited offers,
redacted for client privacy, are attached as Exhibits 9, 10, and 11, respectively.
50. ITP, WTP, and ITR all use unsolicited offers that appear very similar. The unsolicited
offers include some kind of reference number, an application date, and application number
and a picture of the trademark. The application number is really just the serial number of the
underlying trademark application to the USPTO. The bottom of the unsolicited offers lists a
filing fee, additional tax, and a total filing fee, with a prominent box directing recipients to
pay by check and where to send the check. ITR also includes directions on how to pay by
wire transfer.
1
Other cases have been brought in the Southern District of New York against similar
companies that resulted in consent judgments. See Leason Ellis LLP v. USA Trademark
Enterprises, Inc. et. al. (No. 12-cv-00620-ER); Leason Ellis LLP v. Patent & Trademark
Agency LLC (No. 13-CV-2880-VB); Leason Ellis LLP v. Patent & Trademark Association,
Inc. (No. 17-cv-05185-KMK).
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51. The very bottom of the unsolicited offers describes in smaller, denser print that the
recipient is purchasing the registration of the trademark in ITP, WTP, or ITR’s private
database. They charge between $1,340 to $1,380 for this service that, upon information and
belief, has no real value. No where on the unsolicited offers does it mention that trademark
applications are a matter of public record that can be searched and checked online or that
when a trademark application is approved by the USPTO, it is published in the USPTO’s
public Official Gazette.
52. The EUIPO includes examples of unsolicited offers by ITP, WTP, and ITR in its
warning to consumers. See https://euipo.europa.eu/ohimportal/en/misleading-invoices. The
USPTO also includes an example of ITR’s unsolicited offer in its warning to consumers. See
https://www.uspto.gov/trademarks-getting-started/caution-misleading-notices.
53. ITP and ITR state on their website “About Us” pages that the private database on
each of their websites “includes only registered trademarks either in the form of a word or a
logo/ an image/ a design;” however, both databases include brands that are NOT registered
trademarks. Printouts of the website About Us pages are attached as Exhibits 33 and 34.
54. The WTP website states on its homepage, “Hence, There Is The WTP Database,
Which Upon fee, Enables Users The Detailed Access To The Registered Patents And
Trademarks List;” however, upon information and belief, the WTP database only includes
one entry as of February 5, 2019 and it is not a registered trademark. The site promises users
entry into the database of registered trademarks and patents upon paying the fee, but WTP
does nothing to ensure the entries are registered or existing in any way.
55. The ITP, ITR, and WTP databases provide no value to consumers. There is no way
to tell if any marks are registered or in what country or jurisdiction they are registered. The
databases include applications that are only pending at the USPTO and attempts to convey
that they have already been approved and are registered trademarks.
56. In their unsolicited offers, ITP, ITR, and WTP all included in small print at the
bottom, that “the publication of the public registration of your trademark is the basis of our
offer,” which conveys a very specific legal meaning to recipients who are concerned about
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protecting their trademark by either registering or publishing the registration of the

trademarks. Neither is true for ITP, ITR, or WTP.
57. The marketing and sale of services by ITP, WTP, and ITR through the unsolicited
offers and their websites are false and create false and misleading appearances of
equivalence with the legitimate legal services provided by trademark practitioners, such as
Plaintiff RAPC.
58. RAPC has received a total of over 1,100 unsolicited offers from ITP, WTP, and ITR
in the past year, directed to both RAPC’s clients and employees of the firm.
B. WTMR
59. WTMR lists on its unsolicited offers an Internet website address of www.wtmr.org.
A printout of the website homepage is attached as Exhibit 12. A copy of one of WTMR’s
unsolicited offers, redacted for client privacy, is attached as Exhibit 13.
60. The USPTO includes an example of WTMR’s unsolicited offer on its website as a
warning to consumers. See https://www.uspto.gov/trademarks-getting-started/caution-
misleading-notices.
61. WTMR’s unsolicited offers only reference a Washington, D.C. address. Its website
also only references the Washington D.C. address; however, the IP address for its domain
name, www.wtmr.org, is located in Hungary. Furthermore, to increase the appearance of
legitimacy and authenticity, WTMR uses the top level domain .org for its website, rather
than the typical commercial domain of .com.
62. WTMR also directs recipients to address the check to WTMR, LLC; however, it is
not discernable whether WTMR registered as a limited liability company in Washington
D.C.
63. The address provided by WTMR (1717 Pennsylvania Avenue NW, Ste 1025,
Washington, DC 20006) is a virtual office rented from Servcorp. Upon information and
belief, WTMR is not operated out of Washington D.C. and only uses that address for an
appearance of legitimacy and authenticity while operating the entity from outside of the
U.S., likely Hungary or some other location in Europe.
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64. WTMR’s unsolicited offers include a picture of the recipient’s trademark image at
the top, and immediately below, in the middle of the page, it states in large, bold print
“YOUR ACCOUNT INFORMATION” and “REGISTRATION FEE.”
65. WTMR directs recipients to pay $980 as a registration fee, with the overall format of
the unsolicited offer constructed to appear as an invoice, including a due date, and telling
recipients that “WE MUST RECEIVE PAYMENT BY THE DUE DATE.”
66. In smaller type WTMR’s unsolicited offer mentions that by sending a check the
recipient will have his or her trademark listed in WTMR’s publication, but nowhere does it
mention that trademark applications are a matter of public record that can be searched and
checked online or that when a trademark application is approved by the USPTO, it is
published in the USPTO’s public Official Gazette.
67. The WTMR unsolicited offers state in small print that website references “register”
or “registration” of customer’s marks throughout the website, stating to customers that by
purchasing their services, the customer’s mark(s) will be registered and protected.
68. Upon information and belief the format of the unsolicited offer is deliberately
constructed to deceive recipients into thinking the unsolicited offer is a bill so the recipient
will send a check as a payment for something they think is already owed to protect a
trademark.
69. Indeed, the appearance created is that the recipient’s trademark is at risk if he or she
does not pay the $980 registration fee. Immediately prior to stating that payment results in
listing the trademark information in the World Trademark Register, the offer reads as
follows: “The law considers a trademark to be a form of property. Your trademark is an
important component of your successful business marketing strategy. Protecting your
trademark for confusing similar names is your responsibility. The above mentioned data
represents a sample of your trademark registration . . . .”
70. The WTMR website also states that WTMR’s publication is an annually produced
catalog of registered trademarks; however, upon information and belief, WTMR does not
produce the catalog annually and it is not a catalog of registered trademarks.
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71. The marketing and sale of services by WTMR through the unsolicited offers and its
website is false and creates a false and misleading appearance of equivalence with the
legitimate legal services provided by trademark practitioners, such as Plaintiff RAPC.
72. The false promise of an annually produced catalog of only registered trademarks is
also false.
73. RAPC has received over 40 unsolicited offers from WTMR in the past year, directed
to both RAPC’s clients and to individuals employed by RAPC.
C. GLOTRADE
74. GLOTRADE lists on its unsolicited offers an Internet website address of
www.glotrade.world. A printout of the website homepage is attached as Exhibit 14. A copy
of one of GLOTRADE’s unsolicited offers, redacted for client privacy, is attached as
Exhibit 15.
75. The USPTO also includes an example of GLOTRADE’s unsolicited offer on its
website as a warning to consumers.
76. See https://www.uspto.gov/trademarks-getting-started/caution- misleading-notices.
77. The website, www.glotrade.world, uses the top level domain of .world rather than
the typical commercial domain of .com to advance the illusion that it is an official
government entity or closely affiliated with one.
78. The unsolicited offer, directs recipients to send a check for payment to an address in
Houston, Texas and another version directs payment to an address in New York City;
however, upon information and belief, GLOTRADE is operating out of Czech Republic.
79. Both domestic addresses provided by GLOTRADE are for mail forwarding services.
The New York address (244 Madison Ave, New York, NY 10016) is for a UPS location that
states at “[t]he UPS Store Madison Ave, you'll get a real street address, package acceptance
from all carriers and quick and easy access to your mail and deliveries.” The mailbox
service includes holding and forwarding mail.
80. Similarly, the Houston address (1321 Upland Drive, Suite 8441, Houston, TX
77043-4718) is the address of US Global Mail, a service used to provide a U.S. street
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address to customers and allow them to receive mail at a U.S. address that can then be
forwarded internationally.
81. Upon information and belief, GLOTRADE uses these domestic mailbox addresses to
appear as though they have a physical location in the U.S. that is not a post office box and to
hold and forward all U.S. mail to an international location. By doing so, GLOTRADE
masks its true identity from people sending the checks and attempts to retain its anonymity
and appearance of an official entity critical to protecting intellectual property rights.
82. Although the website is only available in English or Spanish, it states in the terms of
service that the registered office of the company is in Brno, Czech Republic. A printout of
the website terms of service is attached as Exhibit 16.
83. On the unsolicited offers, GLOTRADE includes a title of “Global Trademarks
Protection” directly under its name to again project an appearance as an official entity that
provides a critical service to protect intellectual property rights.
84. GLOTRADE also designed its mailer to look like an invoice. It includes information
about the recipient’s trademark registration number, lists some kind of “GLOTRADE
USERNAME” and direct recipients to reference the username and send a check to a U.S.
address, that despite its appearance is not a physical address, but an address to have the
check redirected to an international location.
85. The GLOTRADE unsolicited offers provide an astonishing total due of $2,890, and
directs recipients to detach the stub of and mail in with the check. The service that
GLOTRADE actually provides for this amount is another publishing of the public
registration; however GLOTRADE also includes one year of sending reports to the payor of
other newly published trademark applications, informing the payor that he or she can comb
through the reports to find any potentially conflicting brands himself or herself.
86. Nowhere does GLOTRADE’s unsolicited offer mention that trademark applications
are a matter of public record that can be searched and checked online or that when a
trademark application is approved by the USPTO, it is published in the USPTO’s public
Official Gazette.
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87. Instead the appearance created by the unsolicited offer is that a trademark owner
needs GLOTRADE’s services to protect the trademark rights.
88. Furthermore, in the unsolicited offer, in the only place describing the service being
sold, GLOTRADE states that “WE OFFER OUR SIMILARITY SERVICE THAT
PROTECTS YOUR TRADEMARK FROM COPYRIGHT INFRINGEMENT.” This is a
false statement because the service sold by GLOTRADE does not protect a trademark from
copyright infringement.
89. Additionally, the unsolicited offer continues, stating “THEREFOR [sic] YOU WILL
RECEIVE TIMELY REPORTS ON NEWLY PUBLISHED TRADEMARK
APPLICATIONS IN KEY MARKETS TO UNCOVER POTENTIAL CONFLICTS WITH
YOUR BRAND.” This again is a false statement because, upon information and belief,
GLOTRADE does not send out timely reports on newly published trademark applications in
the recipients key markets and any report sent out by GLOTRADE does not provide
recipients with protection promised by GLOTRADE.
90. The marketing and sale of services by GLOTRADE through the unsolicited offers
and its website is false and creates a false and misleading appearance of equivalence with
the legitimate legal services provided by trademark practitioners, such as Plaintiff RAPC.
91. RAPC has received over 140 unsolicited offers from GLOTRADE in the past year,
directed to both RAPC’s clients and employees of the firm.
D. Patent & Trademark Resource Center
92. Patent & Trademark Resource Center LLC (“PTRC”) uses a name very similar to the
USPTO. In fact, Patent & Trademark Resource Center is the actual name of certain libraries
across the United States that have been designated by the USPTO “to support the public
with trademark and patent assistance.”
93. See https://www.uspto.gov/learning-and-resources/support-
centers/Patent-and-trademark-resource-centers-ptrcs. PTRC uses the exact same name as
these USPTO designated resource centers to cause confusion and more easily obtain
payments from unsuspecting victims for unnecessary services.
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94. PTRC uses a top level domain of .us for its website, rather than the typical
commercial domain of .com. Its address, as provided in its unsolicited offer, is an address to
a virtual office in Bothell, Washington; however, just two years ago, PTRC was sending out
the same mailers with an address in Yelm, Washington. The Yelm address is the same
address shown on the bottom of a 2016 PTRC unsolicited offer that USPTO publishes on its
website as a warning to the public about PTRC. See
https://www.uspto.gov/sites/default/files/documents/Patent_and_
Trademark_Resource_Center_Redacted.pdf. A printout of this unsolicited offer is included
as Exhibit 17. This address also matches the current address in PTRC’s latest annual report,
filed with the Washington Secretary of State in April 2018.
95. Suspiciously, the Yelm address is also listed as the physical address for PTRC’s
registered agent, American Corporate Services, Inc. which is California business
specializing in “international tax planning. . . the registration of companies in the US,
offshore companies . . . as well as additional services such as legalization of documents,
etc.” See https://usa-acs.com/. They also highlight that they have experienced Russian and
Chinese speaking U.S. attorneys. A printout of American Corporate Services, Inc.’s
homepage is included as Exhibit 18. Upon information and belief, American Corporate
Services, Inc. is the registered agent for multiple other entities, managed by different
individuals but with the same mobile home physical address for the entities.
96. Upon information and belief, despite the Bothell virtual address and Yelm mobile
home address, PTRC is actually run from outside of the United States. The initial filing
report for PTRC lists it as a foreign company, the only member manager of the LLC is Oleg
Popko, who also lists himself as CEO, and his address is listed as Lastekodu 26-31, Talinn,
Estonia.
97. Upon information and belief, PTRC uses these domestic addresses to appear as
though they have a physical location in the U.S. By doing so, PTRC masks its true identity
from people sending the checks and attempts to retain its anonymity and appearance of an
official entity critical to protecting intellectual property rights.
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98. The unsolicited offer that PTRC sends out is designed to look very similar to a
government form, listing an official sounding form version at the top corner, such as “Form:
Section 8” or “Form: 3.5 Years USA 1.1.” Two copies of the unsolicited offers that RAPC
received from PTRC, redacted for privacy, are included as Exhibit 19. The forms also
include a “Case Id.” or “Order” under the form name, prominent statements about the patent
or trademark expiring, with a Section 8 Filing Fee starting at $850 for a trademark renewal
or a Maintenance Fee of $1,450 to maintain the recipient’s patent for three and a half years.
99. The USPTO includes an example of PTRC’s unsolicited offer on its website as a
misleading-notices.
100. Additionally, upon information and belief, PTRC is not a law firm; however, it is
soliciting legal services and engaged in the practice of law. PTRC’s unsolicited offers state
that by paying the listed fee, the payor is granting PTRC a power of attorney to represent
him or her in “filing the Patent Maintenance” for patents or to empower PTRC to represent
the payor in “filing the declaration concerning your trademark renewal” for trademarks.
101. The marketing and sale of services by PTRC through the unsolicited offers and
its website is false because it conveys to consumers that they will receive sufficient legal
representation to protect their intellectual property and it creates a false and misleading
appearance of equivalence with the legitimate legal services provided by trademark
practitioners, such as Plaintiff RAPC.
102. Upon information and belief recipients have sent money to PTRC because the
format of the unsolicited offer, the confusing official-sounding name of PTRC, and the
domestic U.S. offices mislead the recipient into thinking either that they were getting
legitimate legal services or that they were paying a bill that was owed to protect a patent or
trademark.
103. RAPC has received multiple unsolicited offers from PTRC in the past year,
directed to employees of RAPC.
E. Trademark Renewal Service
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104. Trademark Renewal Service, Inc. (“TRS”) lists a Washington, D.C. address on
its mailer; however, the Washington DC Department of Consumer and Regulatory Affairs
shows that it is a California entity and its status is Revoked. Likewise, in California, the
status shows as suspended on the Secretary of State’s website. There have been no filings
since 1999.
105. Upon information and belief, (“TRS”) is also known as Compliance Filings, Inc.,
which has a website at http://www.compliancefilings.com and lists TRS as one of the
services at http://www.compliancefilings.com/trs.html. A printout of the homepage and TRS
specific page is included as Exhibit 20.
106. Upon information and belief, TRS is also known by alternate names of Corporate
Compliance Center, United States Patent Renewal Services, Fictitious Business Name
Renewal Service, and Renewal Services, Inc., with several complaints of fraud and
deception. A print out of the Better Business Bureau’s page giving these companies an
F-rating and posting a fraudulent warning at the top of the page is included as Exhibit 21.
107. The TRS unsolicited offers include TRS’ name in large bold letters at the top
with a Washington, D.C. address directly below the name. The next largest type is
“TRADEMARK CANCELLATION ADVISORY” and demanding payment by specific
date to avoid “potential late fees,” noting that failure to act will result in cancellation and
loss of exclusive use of the mark.
108. The design of TRS’ unsolicited offers is formatted to mimic a bill and
government form, including a bottom portion to tear off and return with a check or credit
card information to pay the $250 and official looking form names and labels. However,
upon information and belief, the actual service being sold by TRS is only to receive
documentation for the recipient to file on his or her own to renew the trademark. A copy of
one of the TRS unsolicited offers that RAPC received, redacted for privacy, is included as
Exhibit 22.
109. The USPTO also includes an example of TRS’ unsolicited offer on its website as
a warning to consumers. See https://www.uspto.gov/trademarks-getting-started/caution-
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misleading-notices.
110. TRS’ unsolicited offers also state that their service is to assist “trademark owners
in timely complying with all steps necessary to renew trademarks and avoid losing the right
to the exclusive use of their trademarks.”
111. Upon information and belief, TRS is not a law firm; however, it is soliciting legal
services and engaged in the practice of law by offering and presumably engaging in or
advising on “all steps necessary to renew trademarks” and avoid losing trademark rights.
112. The marketing and sale of services by TRS through the unsolicited offers is false
because it cannot provide the legal services necessary for renewal and trademark protection
and it creates a false and misleading appearance of equivalence with the legitimate legal
services provided by trademark practitioners, such as Plaintiff RAPC.
113. Upon information and belief recipients have sent money to TRS because the
format of the unsolicited offer, the confusing official-sounding name of TRS, and the
domestic U.S. offices deceived the recipient into thinking either that they were getting
trademark.
114. RAPC has received multiple unsolicited offers from TRS in the past year,
F. Patent & Trademark Office LLC
115. Patent & Trademark Office LLC (“PTO”), uses a name almost identical to the
USPTO. PTO has one website at www.patentandtrademarkoffice.org, which again uses the
.org top level domain, rather than the typical .com commercial domain. PTO also has
another website at www.ptoffice.us, again trying to appear as an official United States entity.
116. Additionally, the websites claim that the company is headquartered in New York
City, but one version of its unsolicited offer directs recipients to send the signed form to an
address in Jersey City, New Jersey. Additionally, the IP Address for their website
www.ptoffice.us, states that the website is located in Latvia. Printouts of PTO’s websites,
along with a printout of the lookup information for www.ptoffice.us, are included as Exhibit
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23.
117. Upon information and belief all of PTO’s United States addresses are merely
virtual offices or shared offices rented by Regus PLC.
118. PTO also shows an F-rating by the Better Business Bureau and lists a complaint
by a customer who sent PTO money before realizing it was a scam and was unable to get the
money back. A print out of the Better Business Bureau’s pages is included as Exhibit 24.
119. PTO’s unsolicited offer is designed to look very similar to a government form,
with its name and .org website prominent on the page, and directing recipients to “[s]ign and
return this document in order to renew your trademark.” A copy of one of the PTO
unsolicited offers that RAPC received, redacted for privacy, is included as Exhibit 25. The
unsolicited offer states that the “renewal fee” is $890 for one class and $295 for each
additional class.
120. The USPTO includes an example of PTO’s unsolicited offer on its website as a
misleading-notices.
121. Upon information and belief, PTO is not a law firm; however, it is soliciting
legal services and engaged in the practice of law by offering and presumably engaging in or
advising on all of the steps necessary to renew trademarks. PTO’s unsolicited offers state
that by paying the listed fee, the payor is empowering PTO “to renew the trademark state
above on your behalf.”
122. The marketing and sale of services by PTO through the unsolicited offers and its
website is false because it conveys to consumers that they will receive sufficient legal
representation to protect their trademarks and it creates a false and misleading appearance of
Plaintiff RAPC.
123. Upon information and belief recipients have sent money to PTO because the
format of the unsolicited offer, the confusing official-sounding name of PTO, and the
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trademark.
124. RAPC has received multiple unsolicited offers from PTO in the past year,
G. Patent & Trademark Bureau
125. Another Mailer Defendant with an official looking name, Patent & Trademark
Bureau (“PTB”) follows the same tactics as PTO—a name that appears official, uses .us as
the top level domain for its website (www.patentandtrademarkbureau.us) rather than .com,
provides a “headquarters” in New York City and also another address in its mailer
(Philadelphia), and an F-rating from the Better Business Bureau with a complaint by
someone who lost money. A print out of the Better Business Bureau’s pages is included as
Exhibit 26.
126. Upon information and belief, both of PTB’s addresses in New York City and
Philadelphia are also addresses for Regus PLC virtual or shared offices. The PTB website is
also not hosted in the U.S., the IP address for its domain name is located in Russia. Upon
information and belief, despite the domestic address, PTB is actually run from outside of the
United States. A printout of PTB’s website is included as Exhibit 27.
127. Upon information and belief, PTB uses these domestic addresses to appear as
though they have a physical location in the U.S. By doing so, PTB masks its true identity
from people sending money and attempts to retain its anonymity and appearance of an
official entity critical to protecting intellectual property rights.
128. PTB’s unsolicited offer is designed to look very similar to a government form,
with its name and .us website prominent on the page, and directing recipients to “[s]ign and
return this document in order to renew your trademark.” A copy of one of the PTB
unsolicited offers that RAPC received is included as Exhibit 28. The unsolicited offer states
that the “renewal fee” is $925 for one class and $325 for each additional class.
129. The EUIPO includes an example of an unsolicited offers by PTB in its warning
to consumers. See https://euipo.europa.eu/ohimportal/en/misleading-invoices. The USPTO
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also includes an example of PTB’s unsolicited offer in its warning to consumers. See
https://www.uspto.gov/trademarks-getting-started/caution-misleading-notices.
130. Upon information and belief, PTB is not a law firm; however, it is soliciting legal
services and engaged in the practice of law by offering and presumably engaging in or
advising on all of the steps necessary to renew trademarks. PTB’s unsolicited offers state
that by paying the listed fee, the payor is empowering PTB “to renew the trademark state
above on your behalf.”
131. The marketing and sale of services by PTB through the unsolicited offers and its
website is false because it conveys to consumers that they will receive sufficient legal
representation to protect their trademarks and it creates a false and misleading appearance of
Plaintiff RAPC.
132. Upon information and belief recipients have sent money to PTB because the
format of the unsolicited offer, the confusing official-sounding name of PTB, and the
trademark.
133. RAPC has received multiple unsolicited offers from PTB in the past year,
H. U.S. Trademark Compliance Office
134. U.S. Trademark Compliance Office (“USTCO”) is another entity using a
carefully chosen name to appear as an official U.S. entity. USTCO also makes it difficult for
anyone to find out more information about it.
135. The USTCO unsolicited offer sent to consumers is an official looking invoice
directing recipients to send checks for their trademark to an address in Delaware, but no
website is provided. On the Delaware Secretary of State website, there is also no
information publicly available for free about any of the officers or directors or even a
principal place of business.
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136. The USTCO unsolicited offer discusses the USPTO and Customs and Border
Patrol, with some partial text of “Trademark Act § 1063” included with references to the
USPTO and USTCO blended into the same paragraph. Although, buried at the bottom of the
page of small text is a disclaimer that USTCO is not affiliated with the USPTO, the general
appearance of the mailer is that of an invoice from an official sounding and looking U.S.
compliance office.
137. USTCO’s unsolicited offer is designed to look very similar to a government form
and bill. The top of the unsolicited offer includes “IMPORTANT NOTIFICATION
REGARDING YOUR FEDERAL TRADEMARK” next to a large arrow pointing to
information about the trademark, and a “PROCESSING FEE” of $495. It also includes a
bottom “stub” to tear off and return with the payment. A copy of one of the USTCO
unsolicited offers that RAPC received, redacted for privacy, is included as Exhibit 29. The
unsolicited offer states that the “renewal fee” is $925 for one class and $325 for each
additional class.
138. The USPTO includes an example of USTCO’s unsolicited offer on its website as
a warning to consumers. See https://www.uspto.gov/trademarks-getting-started/caution-
misleading-notices.
139. Additionally, upon information and belief, USTCO is not a law firm; however, it
is soliciting legal services and engaged in the practice of law. USTCO’s unsolicited offers
state that by paying the listed fee, USTCO will send the payor “electronic notice(s) should
infringement pertaining to your IP occur” and that USTCO will “advise you regarding
possible third party infringement(s).”
140. Upon information belief this is false because USTCO will not send notices when
infringement to the payor’s intellectual property occurs and will not advise regarding
possible infringement.
141. Additionally USTCO’s attempts to do so is an authorized practice of law that
provides payors with a false assurance that their intellectual property will be protected.
142. The marketing and sale of services by USTCO through the unsolicited offers is
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false because it conveys to consumers that they will receive sufficient legal representation to
protect their intellectual property and it creates a false and misleading appearance of
Plaintiff RAPC.
143. Upon information and belief recipients have sent money to USTCO because the
format of the unsolicited offer, the confusing official-sounding name of USTCO, and the
trademark.
144. RAPC has received multiple unsolicited offers from USTCO in the past year,
directed to RAPC’s customers.
I. USTM Corporation
145. USTM Corporation (“USTM”) is another entity using a carefully chosen name to
appear as an official U.S. entity. It has sent out unsolicited offers under the name USTM,
Information Services and US Trademark, Trademark Assistance. The latest received mailers
now omit references to USTM’s website and only include a post office box number with a
zip code, avoiding specifically identifying the city and state (Idaho Falls, Idaho). This
contributes to making the unsolicited offer appear more official.
146. The website, if recipients are able to find it, includes .us within the website
address to appear more official—www.ustm.us.com. A printout of USTM’s website
homepage is included as Exhibit 30.
147. Upon information and belief, the two directors of USTM were also both involved
with a California entity that had actions brought against it by the State of California and the
Federal Trade Commission (“FTC”) for false and misleading marketing of debt services.
148. Upon information and belief, the FTC action resulted in an $8,000,0000
judgement against one of USTM’s directors (John “Jack” Briggs) and a permanent ban from
him ever participating in any type of debt relief services again. That order also required
specific monitoring of compliance steps for sales personnel of any company for which Mr.
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Briggs directly or indirectly manages or controls and where it uses a website to sell its
services or assist others. A copy of the FTC judgment is included as Exhibit 31.
149. USTM’s unsolicited offer is designed to look very similar to a government form
and bill. It includes alarming language about being an important advisory regarding the
recipient’s trademark and directing the recipient to contact USTM for more information
about the trademark and “PLEASE HAVE THE INCIDENT NUMBER AVAILABLE.” A
copy of one of the USTM unsolicited offers that RAPC received, redacted for privacy, is
included as Exhibit 32.
150. The USPTO includes an example of USTM’s unsolicited offer on its website as a
warning to consumers. See
https://www.uspto.gov/trademarks-getting-started/caution-misleading-notices (referring to
USTM as USTM Information Services).
151. Additionally, upon information and belief, USTM is not a law firm; however, it
is soliciting legal services and engaged in the practice of law. USTM’s unsolicited offers
solicit recipients to call for more information where USTM then provides legal advice on
trademark status and procedures required to protect the caller’s trademark.
152. Additionally, the USTM unsolicited offer includes the statement that
“ANOTHER COMPANY HAS FILED AN APPLICATION TO REGISTER A SIMILAR
NAME, CLAIMING THE EXCLUSIVE RIGHT TO USE THE NAME.” Upon information
and belief, this statement is false and the unsolicited offer was sent with this statement even
though there was no application for a similar name, claiming the exclusive right to use the
name. This is merely a false statement meant to get recipients to call in and be sold
unnecessary services and legal services by non-attorneys.
153. The marketing and sale of services by USTM through the unsolicited offers and
its website is false because it conveys to consumers that they will receive sufficient legal
representation to protect their intellectual property and it creates a false and misleading
appearance of equivalence with the legitimate legal services provided by trademark
practitioners, such as Plaintiff RAPC.
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154. Upon information and belief recipients have sent money to USTM because the
format of the unsolicited offer, the confusing official-sounding name of USTM, and the
trademark.
155. RAPC has received multiple unsolicited offers from USTM in the past year,
directed to employees of RAPC and its customers.
J. USA Box
156. Upon information and belief, USA Box works with ITP, WTP, and ITR to
provide them with a domestic Florida address to aid and abet the deception on consumers
while actively masking the true foreign origin of ITP, WTP, and ITR.
157. Upon information and belief USA Box also forwards the mail received in Florida
to other foreign addresses for ITP, WTP, and ITR.
158. Upon information and belief, if these companies used their foreign addresses
rather than the domestic address supplied by USA Box, then there would be significantly
fewer people, if any, who would be deceived and send ITP, WTP, or ITR money.
159. Upon information and belief, USA Box has received complaints about ITP, WTP,
and ITR using USA Box’s address and services to execute their scams, but USA Box
continues to provide the necessary assistance to keep the scam going.
K. Siglo-21, Inc.
160. Upon information and belief, Siglo-21, Inc. owns and operates a UPS Store in
New York City at 244 Madison Ave, New York, NY 10016.
161. Upon information and belief, Siglo-21, Inc. through its UPS Store, provides
GLOTRADE with a domestic New York City address to aid and abet the deception on
consumers while actively masking the true foreign origin of GLOTRADE.
162. Upon information and belief Siglo-21, Inc. also forwards the mail received in
New York City to a foreign address or addresses for GLOTRADE.
163. Upon information and the mail collected and forwarded to GLOTRADE in
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Hungary by Siglo-21, Inc. includes checks for thousands of dollars from deceived
consumers in the United States.
164. Upon information and belief, if GLOTRADE used its foreign addresses rather
than the domestic address supplied by Siglo-21, Inc., then there would be significantly fewer
people, if any, who would be deceived and send GLOTRADE money.
165. Upon information and belief, Siglo-21, Inc. has received complaints about
GLOTRADE using Siglo-21, Inc’s address and services to execute its scams, but Siglo-21,
Inc. continues to provide the necessary assistance to keep the scam going.
L. U.S. Global Mail, Inc.
166. Upon information and belief, U.S. Global Mail, Inc. (“USGM”), provides
GLOTRADE with a domestic Houston, Texas address to aid and abet the deception on
consumers while actively masking the true foreign origin of GLOTRADE.
167. Upon information and belief USGM also forwards the mail received in Houston
to a foreign address or addresses for GLOTRADE.
168. Upon information and the mail collected and forwarded to GLOTRADE in
Hungary by USGM includes checks for thousands of dollars from deceived consumers in
the United States.
169. Upon information and belief, if GLOTRADE used its foreign addresses rather
than the domestic address supplied by USGM, then there would be significantly fewer
people, if any, who would be deceived and send GLOTRADE money.
170. Upon information and belief, USGM has received complaints about
GLOTRADE using USGM’s address and services to execute its scams, but USGM
continues to provide the necessary assistance to keep the scam going.
M. Servcorp Washington LLC
171. Upon information and belief, Servcorp Washington LLC (“Servcorp”), provides
WTMR with an address and mail service in Washington, D.C. to aid and abet the deception
on consumers while actively masking the true origin of WTMR.
172. Upon information and belief Servcorp also forwards the mail received in
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Washington, D.C. to a different address or addresses for WTMR.

173. Upon information and the mail collected and forwarded to WTMR by Servcorp
includes checks for thousands of dollars from deceived consumers in the United States.
174. Upon information and belief, if WTMR used its true address rather than the
Washington, D.C. address supplied by Servcorp’s services, then there would be significantly
fewer people, if any, who would be deceived and send WTMR money.
175. Upon information and belief, Servcorp has received complaints about WTMR
using Servcorp’s address and services to execute its scams, but Servcorp continues to
provide the necessary assistance to keep the scam going.
N. Premier Office Centers, LLC
176. Upon information and belief, Premier Office Centers, LLC dba Premier Business
Centers (“PBC”), provides PTRC with an address and mail service in Washington state to
aid and abet the deception on consumers while actively masking the true origin of PTRC.
177. Upon information and belief PBC also forwards the mail received in Washington,
to a different address or addresses for PTRC.
178. Upon information and the mail collected and forwarded to PTRC by PBC
179. Upon information and belief, if PTRC used its true address rather than the
address supplied by PBC’s services, then there would be significantly fewer people, if any,
who would be deceived and send PTRC money.
180. Upon information and belief, PBC has received complaints about PTRC using
PBC’s address and services to execute its scams, but PBC continues to provide the necessary
assistance to keep the scam going.
O. Regus Management Group, LLC
181. Upon information and belief, Regus Management Group, LLC (“Regus”),
provides PTO and PTB with domestic addresses in New York, New Jersey, and
Pennsylvania and with and mail collection and forwarding services to aid and abet the
deception on consumers while actively masking the true foreign origin of PTO and PTB.
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182. Regus has provided PTO with addresses and services at 299 Park Avenue, 6th
Floor, New York, New York 10171, 101 Hudson Street, Suite 2100, Jersey City, New Jersey
07302, and 387 Park Ave. S FL 5, New York, NY 10016-8810.
183. Regus has provided PTB with addresses at 1500 Market Street, 12th Floor, East
Tower, Philadelphia, Pennsylvania 19102 and 230 Park Avenue, 3rd Floor West, Helmsley
Building, New York, New York 10169.
184. Upon information and belief Regus also forwards the mail received in New York,
New Jersey, and Pennsylvania to foreign addresses for PTO and PTB.
185. Upon information and the mail collected and forwarded to PTO and PTB by
Regus includes checks for thousands of dollars from deceived consumers in the United
States.
186. Upon information and belief, if PTO and PTB used their foreign addresses rather
than the domestic addresses supplied by Regus, then there would be significantly fewer
people, if any, who would be deceived and send PTO and PTB money.
187. Upon information and belief, Regus has received complaints about PTO and
PTB using Regus’ addresses and services to execute their scams, but Regus continues to
provide the necessary assistance to keep the scams going.
P. Lawyers' Choice Suites, Inc.
188. Upon information and belief, Lawyers' Choice Suites, Inc. (“LCS”), provides
TRS with an address and mail service in Washington, D.C. to aid and abet the deception on
consumers while actively masking the true origin of TRS.
189. Upon information and belief LCS also forwards the mail received in Washington,
D.C., to a different address or addresses for TRS.
190. Upon information and the mail collected and forwarded to TRS by LCS includes
checks for thousands of dollars from deceived consumers in the United States.
191. Upon information and belief, if TRS used its true address rather than the address
supplied by LCS’ services, then there would be significantly fewer people, if any, who
would be deceived and send TRS money.
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192. Upon information and belief, LCS has received complaints about TRS using
LCS’ address and services to execute its scams, but LCS continues to provide the necessary
Q. Stat Office Solutions
193. Upon information and belief, Stat Office Solutions (“SOS”), provides USTCO
with an address and mail service in Delaware state to aid and abet the deception on
consumers while actively masking the true origin of USTCO.
194. Upon information and belief PBC also forwards the mail received in Washington,
to a different address or addresses for USTCO.
195. Upon information and the mail collected and forwarded to USTCO by SOS
196. Upon information and belief, if USTCO used its true address rather than the
address supplied by SOS’ services, then there would be significantly fewer people, if any,
who would be deceived and send USTCO money.
197. Upon information and belief, SOS has received complaints about USTCO using
SOS’ address and services to execute its scams, but SOS continues to provide the necessary
R. Harm to Plaintiff
198. The actions of the Mailer Defendants amount to unfair competition because they
deceptively divert significant business from trademark owners, who have limited funds to
protect their intellectual property and would otherwise have engaged RAPC’s services.
199. RAPC has received inquiries from its clients confused about the unsolicited
actions by the Mailer Defendants and worried that RAPC’s services to the clients were
somehow deficient.
200. The unsolicited offers by Mailer Defendants cost RAPC valuable time and
expenses to investigate the facts to appropriately advise its clients.
201. Upon information and belief, each of the Mailer Defendants is a scam enterprise
structured to protect the anonymity of the beneficiary owners and that do not provide any
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service to consumers that is commensurate with the costs.

202. The solicitation activities by Mailer Defendants have damaged RAPC and its
clients and will continue to do so unless Mailer Defendants are otherwise restrained.
FIRST CLAIM FOR RELIEF
FALSE ADVERTISING AND UNFAIR COMPETITION
THE LANHAM ACT, 15 U.S.C. § 1125(a)
(Against each of the Mailer Defendants and Logistics Enablers)
203. RAPC repeats each and every allegations contained in the paragraphs above and
incorporates by reference each preceding paragraph as though fully set forth herein.
Mailer Defendants
204. Each of the Mailer Defendants violated 15 U.S.C. § 1125(a) by making false
statements in commercial speech as alleged above.
205. The statements were made in connection with the services offered by the Mailer
Defendants. The statements relate to descriptions or representations of fact that misrepresent
the nature, characteristics, quality, origin, necessity, and/or affiliation of Mailer Defendants’
services.
206. The Mailer Defendants publicly disseminated the unsolicited offers to RAPC and
consumers in California. The unsolicited offers contain commercial speech, as described
above, that is either literally false or at least likely to deceive or confuse consumers.
207. The Mailer Defendants’ false and misleading advertisements have caused and,
unless enjoined, will continue to cause immediate and irreparable harm to RAPC and its
clients for which there is no adequate remedy at law.
208. In addition, as a result of the Mailer Defendants’ false and misleading
advertisements that have been publicly distributed with , RAPC has been injured, including
but not limited to, decline in sales and market share, loss of goodwill, and additional losses
and damages.
209. Upon information and belief RAPC’s clients have been actually deceived and
have been harmed by sending money to the Mailer Defendants because the format of
unsolicited offers, the confusing official-sounding names of the Mailer Defendants, and the
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domestic U.S. offices led RAPC clients into thinking either that they were getting legitimate
legal services or that they were paying a bill that they owed to protect a patent or trademark.
210. Furthermore, the Mailer Defendants have been unjustly enriched at the expense
of RAPC and its clients as a consequence of the Mailer Defendant’s false advertising.
Accordingly, RAPC is entitled to injunctive relief and to recover three times the damages
sustained by RAPC, enhanced profits and costs, as well as the Mailer Defendant’s profits,
and reasonable attorneys’ fees under 15 U.S.C. §§ 1114, 1116, and 1117.
211. The Mailer Defendants’ unsolicited offers above were mailed or otherwise made
available to the public at least on, or earlier than, February 5, 2019 and continued onward
through the filing of this complaint.
212. The Mailer Defendants’ unsolicited offers contain commercial speech that is
either literally false or at least likely to confuse or deceive consumers.
Logistics Enablers - Aiding and Abetting
213. The Logistics Enablers provide ITP, WTP, ITR, GLOTRADE, WTMR, PTRC,
PTO, PTB, TRS, and USTCO with domestic addresses in the United States which enables
them to further their false advertising and unfair competition scheme against California and
other United States consumers.
214. Upon information and belief, the Logistics Enablers have each received
complaints about the unlawful actions of ITP, WTP, ITR, GLOTRADE, WTMR, PTRC,
PTO, PTB, TRS, and USTCO but continue to actively provide each with a mailbox address
and forward money received at that address to a different address.
215. The Logistics Enablers’ actions provide substantial assistance to ITP, WTP, ITR,
GLOTRADE, WTMR, PTRC, PTO, PTB, TRS, and USTCO and amounts to a substantial
factor in causing harm to RAPC and its clients.
216. Upon information and belief, without the domestic addresses provided by the
Logistics Enablers to ITP, WTP, ITR, GLOTRADE, WTMR, PTRC, PTO, PTB, TRS, and
USTCO, which they use to hide their foreign origins from recipients of the unsolicited offers
and to appear associated with the U.S. Government, ITP, WTP, ITR, GLOTRADE, WTMR,
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PTRC, PTO, PTB, TRS, and USTCO would receive substantially less money from
unsuspecting consumers ensnared by the scheme.
217. As a result of the Logistics Enablers’ wrongful acts, Plaintiff has suffered and
will continue to suffer loss of revenue, loss of profits, loss of market share, reduced asset
value, diverted sales to the ITP, WTP, ITR, GLOTRADE, WTMR, PTRC, PTO, PTB, TRS,
and USTCO, increased advertising costs and loss of valuable business opportunities, all
belonging to or vesting to Plaintiff but taken away by ITP, WTP, ITR, GLOTRADE,
WTMR, PTRC, PTO, PTB, TRS, and USTCO as a result of the Logistics Enablers’
substantial assistance.
218. Plaintiff seeks an order of this Court that preliminarily and permanently enjoins
the Logistics Enablers from continuing to engage in the unlawful and unfair acts or practices
set forth herein.
SECOND CLAIM FOR RELIEF
CALIFORNIA FALSE & MISLEADING ADVERTISING
CAL. BUS. & PROF. CODE § 17500 ET SEQ.
219. Plaintiff repeats each and every allegation contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
Mailer Defendants
220. Each of the Mailer Defendants’ advertisements is false, misleading, and untrue,
as further described in this Complaint.
221. Each of the Mailer Defendants’ advertisements is likely to and has deceived
consumers. Consumers have purchased the Mailer Defendants’ services instead of RAPC’s
services as a result of the deception.
222. RAPC has suffered and will continue to suffer loss of revenue, loss of profits,
loss of market share, reduced asset value, diverted sales to the Mailer Defendants, increased
advertising costs and loss of valuable business opportunities, all of which belonged to or
vested to RAPC but were taken away by the Mailer Defendants as a result of their wrongful
acts.
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223. The Mailer Defendants have been unjustly enriched through their false and
misleading advertising.
224. If the Mailer Defendants are not preliminarily or permanently enjoined, they will
continue to derive revenue, profits, market share and sales from RAPC by wrongful acts.
Unless restrained by this court, the Mailer Defendants will cause additional injury to RAPC
for which RAPC has no adequate remedy at law.
225. RAPC seeks an order of this Court under California Business & Professions
Code § 17500 to preliminarily and permanently enjoin the Mailer Defendants from
continuing to engage in the false and misleading advertising set forth herein.
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set forth herein.
THIRD CLAIM FOR RELIEF
CALIFORNIA UNFAIR COMPETITION IN VIOLATION OF
CAL. BUS. & PROF. CODE § 17200 ET SEQ.
Mailer Defendants
233. Plaintiff has standing because it has suffered injury in fact and lost money,
including diverted sales to the Mailer Defendants, lost revenue, loss of market share,
reduced asset value, and increased advertising costs.
234. Each of the Mailer Defendants violated the unlawful prong of UCL because:
a. Each of the Mailer Defendants violates Cal. Bus. & Prof. Code § 17500 et seq. as
alleged supra.
b. PTRC, PTB, PTO, USTCO, USTM, and TRS violate Cal Bus. & Prof. Code §
6125 which provides that “[n]o person shall practice law in California unless the
person is an active member of the State Bar.”
235. PTRC, PTB, PTO, USTCO, USTM, and TRS violated the unfair prong of UCL
because of, and not limited to, the following:
a. It is unfair to the competition in the practice of law if PTRC, PTB, PTO, USTCO,
USTM, and TRS are able to offer legal services by violating state laws, federal
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regulations and California ethics rules without being punished, while the vast
majority of trademark attorneys and legal technology companies, including
Plaintiff, abide by the laws, federal regulations and California ethics rules.
b. The consumer injury caused by PTRC, PTB, PTO, USTCO, USTM, and TRS
violating the state laws, federal regulations and ethics rules is substantial. As these
laws, regulations and ethics rules regulate non-lawyers practicing law, they are
there to protect the interests of the public at large. When they are violated by
PTRC, PTB, PTO, USTCO, USTM, and TRS, consumers become susceptible to
the harm of bad legal advice given by non-attorneys whose independent judgment
may be insufficient and not bound to the same ethical obligations. The contract
for legal services between consumers and PTRC, PTB, PTO, USTCO, USTM,
and TRS may be voided by the operation of law. The public interest is greatly
harmed.
c. Providing legal advice to clients by the means of violating state laws, federal
regulations and ethics rules offers no countervailing benefits to consumers or
competition.
d. Consumers themselves are unable to reasonably avoid the injury because
reasonable consumers are not aware of these laws, regulations and ethics rules
and are not aware that they are being harmed or will be harmed.
236. Each of the Mailer Defendants also violated the unfair prong of UCL because of,
and not limited to, the following:
a. It is unfair to the competition in the practice of trademark and patent law for the
trademark defendandants to send out their unsolicited offers with the entity
names, addresses, language, and format of the offers purposefully constructed, as
alleged above, to convey an official government connection and/or perception of
incurred debt to deceive consumers into sending money.
b. Furthermore, the consumer injury is substantial, because even if the consumer is
able to get any services at all in exchange for a fee, those services are unnecessary
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for the purpose being advertised, protection of intellectual property, and not nearly
commensurate with the amount of fee being paid.
c. Consumers themselves are unable reasonably avoid the injury because reasonable
consumers are not aware of the trademark and patent law requirements, laws,
regulations and are not aware that they are being harmed or will be harmed.
237. The Mailer Defendants prevented competition from Plaintiffs by unfairly gaining
potential clients through illegal solicitation and misleading advertisements. But-for their
unlawful and unfair competition, many of these potential clients would have otherwise gone
to Plaintiff.
238. The Mailer Defendants’ conduct of unlawful and unfair competition proximately
caused Plaintiff injury. The Mailer Defendants advertise directly to trademark owners and
applicants. Thus, the Mailer Defendants directly compete (unfairly) with Plaintiff. If the
Mailer Defendants did not engage in the alleged unlawful solicitations and PTRC, PTB,
PTO, USTCO, USTM, and TRS in the unauthorized practice of law, they would not have
unfairly competed with Plaintiffs. Therefore, the Mailer Defendants conduct of unfair
competition took away potential sales belonging to Plaintiff and proximately caused injury
to Plaintiff, the intellectual property law market, and consumers.
239. As a result of the Mailer Defendants’ wrongful acts, Plaintiff has suffered and
value, diverted sales to the Mailer Defendants, increased advertising costs and loss of
valuable business opportunities, all belonging to or vesting to Plaintiff but taken away by the
Mailer Defendants as a result of their wrongful acts.
240. Plaintiff seeks an order of this Court under California Business & Professions
Code § 17200 that preliminarily and permanently enjoins the Mailer Defendants from
continuing to engage in the unlawful and unfair acts or practices set forth herein.
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set forth herein.
FOURTH CLAIM FOR RELIEF
INTENTIONAL INTERFERENCE WITH PROSPECTIVE
ECONOMIC ADVANTAGE
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Mailer Defendants
248. Plaintiff has standing because it has suffered injury in fact and lost money,
including diverted sales to the Mailer Defendants, lost revenue, loss of market share,
reduced asset value, and increased advertising costs.
249. Plaintiff has an economic and contractual relationship with all of its clients,
which also is likely to continue to provide continued future economic benefit to RAPC as
the clients seek repeat and additional services.
250. RAPC is listed as the filing correspondent for its clients in the USPTO records of
the clients’ patents and trademark registrations.
251. Upon information and belief, the Mailer Defendants intentionally mine the
USPTO data to obtain information about the trademark owners and applicants before
sending unsolicited offers to the unsuspecting recipients, which include RAPC and its
clients.
252. The Mailer Defendants are aware, from the USPTO public data, that RAPC
represents its clients in trademark and patent matters and knew or reasonably should have
known that there is an attorney-client relationship between RAPC and its clients to whom
the Mailer Defendants sent solicitations for trademark and patent services.
253. By directing the unsolicited offers to RAPC’s clients, the Mailer Defendants
have harmed the relationship between RAPC and its clients who receive unsolicited offers.
254. As a result of the Mailer Defendants’ wrongful acts, Plaintiff has suffered and
value, diverted sales to the Mailer Defendants, increased advertising costs and loss of
valuable business opportunities, all belonging to or vesting to Plaintiff but taken away by the
Mailer Defendants as a result of their wrongful acts.
the Mailer Defendants from continuing to engage in the unlawful and unfair acts or practices
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set forth herein.

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set forth herein.

REQUEST FOR RELIEF
WHEREFORE, Plaintiff requests that this Court:
262. Enter judgment against Defendants;
263. Award RAPC all available damages against Defendants in an amount to be
proven at trial;
264. Declare this case as an exceptional case under 15 U.S.C. § 1117(a);
265. Award Plaintiff its costs and expenses of this action against Defendants,
including its reasonable attorneys’ fees necessarily incurred in bringing and pressing this
case, as provided in 15 U.S.C. § 1117(a);
266. Award Plaintiff compensatory and punitive damages if available;
267. Award Plaintiff pre- and post-judgment interest at the applicable rates on all
amounts awarded;
268. Grant permanent injunctive relief to prevent the recurrence of the violations for
which redress is sought in this complaint against Defendants and all related entities,
including, affiliates, branches, divisions, subsidiaries, successors, predecessors, parents,
wholly owned and partially owned entities, and any entity acting or purporting to act on
behalf of each of the foregoing, including directors, officers, members, managers, agents,
employees, partners, representatives, from promoting, soliciting, offering for sale, and
selling any intellectual property related services.
269. Order any other such relief as the Court deems appropriate.
Respectfully submitted this 25th day of March 2019.
LegalForce RAPC Worldwide P.C.
By /s/ Raj V. Abhyanker

Raj V. Abhyanker
California State Bar No. 233284
Attorney for Plaintiff:
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JURY TRIAL DEMAND

Plaintiffs hereby request a bench trial for the declaratory judgment and injunction
causes of action, and a jury trial for all other causes of action alleged in this Complaint.
Respectfully submitted this 25th day of March 2019.
LegalForce RAPC Worldwide P.C.
By /s/ Raj V. Abhyanker
Raj V. Abhyanker
California State Bar No. 233284
Plaintiff & Attorney for Plaintiff:
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About INTA Unsolicited
Case 5:19-cv-01538 Offers for Trademark-Related
Document Services in thePage
1-1 Filed 03/25/19 United States
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Fact Sheets Maintaining a Registration
Fact Sheets Home
Unsolicited Offers for Trademark-Related Services in the United

States
Updated, June 2015
Brand owners, beware! If you have ever filed a trademark application with your country’s trademark office, it is likely that you will
be the target of companies that attempt to confuse applicants into paying unnecessary fees.
Trademark filings are a matter of public record. Thus, anyone with an Internet connection and a minimal amount of training has
access to the particulars of trademark applications and registrations. As a result, some companies try to trick trademark filers
into paying fees for unnecessary services.
This is how the trick works. Armed with your trademark, name, and address and similar information for thousands of other
trademark owners, these companies mass-mail or email an official-looking form requesting the payment of fees (usually an odd
amount, such as $587.00) to “publish” or “register” your trademark. The services they offer often are unnecessary or duplicate
the services provided by the government trademark office. In other situations, the mailing may offer what might otherwise be a
legitimate service (e.g., a trademark watch service), but under false pretenses (e.g., by using a name, such as “USTPA,” that
sounds like an official government agency).
The United States Patent and Trademark Office (USPTO) maintains a notice warning trademark owners to be wary of unsolicited
offers that may have an official appearance. A number of entities that mail or email unsolicited offers are listed in the warning
notice, along with examples of the offers they send to unsuspecting trademark owners. Be aware that this is not an exhaustive
list, as the entities change their names from time to time and new entities emerge to engage in this practice.
See WARNING: Non-USPTO Solicitations That May Resemble Official USPTO Communications
How do I know which notices are legitimate?

Before paying any trademark-related fees, verify that the invoice is from an authorized entity. If the notice appears to be from a
government agency, make sure it is the government trademark office with which you filed your application (e.g., the USPTO). No
other government entity will contact you regarding your application. Of course, many of the companies that try to confuse
trademark owners attempt to appear as “official” as possible. Note that most government trademark offices do not write directly
to an applicant that is represented by local counsel of record. Accordingly, if you are represented by an attorney or agent, pay
particular attention to any unsolicited mail you may receive that purports to relate to your trademark. When in doubt, contact your
trademark counsel about documents of questionable authenticity or merit that are related to your trademark before providing any
financial or other sensitive or confidential information.
Please give us your feedback on whether this fact sheet was helpful or if you have suggestions for other fact sheet
topics.
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EXHIBIT 2
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Filednotices | USPTO Page 5 of 174
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Caution: misleading notices

Don't be fooled by potentially misleading offers and notices from
private companies
Some trademark applicants and registrants have paid fees to private companies, mistakenly thinking they were paying fees
required by the USPTO. We do not endorse any of these private companies and you are not required to use them.
Keep reading for information on potentially misleading offers and notices—also called solicitations—and how to identify
them. You can also watch our "Solicitation Alert" video below.
On this page:
Trademark Information Network News Video: Solicitation Alert

What is a trademark-related solicitation?
What kinds of trademark-related services do private companies offer?
How can I tell the difference between potentially misleading trademark offers and notices and legitimate USPTO
emails and notices?
Are the deadlines in these offers and notices accurate?
I received a misleading trademark offer or notice. What should I do?
Do you have any examples of potentially misleading offers or notices?
Trademark Information Network News Video: Solicitation Alert

Watch this video to learn about potentially misleading trademark offers and notices, the types of services they offer, and
how to detect them.
TMIN News 16: Solicitation Alert
https://www.uspto.gov/trademarks-getting-started/caution-misleading-notices 1/5
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Enhanced accessibility version of the "Solicitation Alert" video
Printable transcript of video
What is a trademark-related solicitation?

A solicitation is an offer of services, or a notice of an upcoming filing deadline with an offer of services, usually requiring a
fee. Private companies often use trademark application and registration information from USPTO databases to mail or
email trademark-related solicitations to trademark applicants and registrants. While these solicitations may often contain
correct information (for example, that a filing is due to keep a registration active), you are never required to use the
services offered by these companies.
What kinds of trademark-related services do private companies offer?

They may offer legal services, assistance with filings, or other services. Although some services may be legitimate—for
example, assistance in responding to an office action—others are not—for example, offering to record trademarks in a
private registry. Beware of all types of offers and notices not from the USPTO. In March 2017, the operators of a private
company—the Trademark Compliance Center—were convicted of money laundering in a trademark renewal scam.
How can I tell the difference between potentially misleading trademark offers and
notices and legitimate USPTO emails and notices?
All official correspondence about your trademark application or registration will be from the “United States Patent and
Trademark Office” in Alexandria, Virginia, and all emails will be from the domain “@uspto.gov.”
Don’t be fooled by company names that sound like government agencies or offers that contain government data. Some
company names may include terms like “United States,” “U.S.,” “Trademark,” “Patent,” “Registration,” “Office,” or “Agency.”
Some offers and notices may include official government data publicly available from USPTO records, or refer to other
government agencies and sections of the U.S. Code.
So read these offers and notices carefully before deciding whether to respond. We cannot help you get a refund from a
private company if you paid money or signed up for services based on a misleading offer or notice.
Are the deadlines in these offers and notices accurate?

Some offers or notices may refer to upcoming deadlines related to your application or registration. We can’t vouch for the
accuracy of the deadlines in these solicitations. Instead, check your application or registration deadlines using our
database, Trademark Status and Document Retrieval. For information about why and how to check your status, read our
page on checking the status of an application or registration.
Though legal representation is not required, most applicants and registrants use private trademark attorneys for legal
advice about filing an application and maintaining a registration. If you need help understanding deadlines for your
application or registration, you can contact the attorney referral service of a state bar or local bar association for help
identifying a qualified attorney.
I received a misleading trademark offer or notice. What should I do?

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03/25/19
If you receive a trademark-related offer or notice that you believe is misleading, file a consumer complaint with the
Federal Trade Commission (FTC) immediately. Keep the offer or notice and the envelope; these may be requested later.
Although the FTC does not resolve individual consumer complaints, as the nation's consumer protection agency it may
begin investigations and prosecutions based on widespread complaints about particular companies or business practices.
We also encourage you to contact your state consumer protection authorities. Many states, if not all, have the authority to
issue investigative subpoenas and file complaints against companies engaged in misleading practices directed toward
state residents.
The USPTO is not an enforcement agency, and we don’t have the legal authority to stop private companies from sending
trademark-related offers and notices. But we can raise awareness and work closely with the Department of Justice, the
Federal Trade Commission, and the United States Postal Inspection Service to combat the problem.
Do you have any examples of potentially misleading offers or notices?

Yes. To educate the public and help trademark owners identify these potentially misleading offers and notices, we publicly
post some solicitations that we receive complaints about. Please click on the names below to see an image of the listed
entity's solicitation. None of these examples are official U.S. government or international governmental notices.
For examples of solicitations concerning international applications and registrations, see the official World Intellectual
Property Organization "Warning" webpage .
If you were misled and paid money to any companies not on this list, we encourage you to email us at
TrademarkAssistanceCenter@uspto.gov. Please include copies of the solicitation and the envelope it came in so we can
assess whether to add the sender to the list. We do not need to be notified about companies already on the list below.
New Patent and Trademark Office (2200 Pennsylvania Ave., N.W., 4th Floor East, Wash., D.C.) New
Brand Registration Office (Trademark Selection Edition) (Washington, DC)
GBO, Inc., Trademark and Patent Dep. (Miami, FL)
GLOPAT Global Patents & Trademarks (Bratislava, Slovak Republic)
GLOTRADE (New York, NY)
Intellectual Property Agency Ltd. (London, U.K.)
Intellectual Property Services USA Incorporated (Alexandria, VA)
IOPR - Intellectual Office Property Register (Beaverton, OR)
IP Direct - Registration of the International Trademark (Czech Republic)
IPTA Registration of the International Trademark (Brno, Czech Republic)
IPTI - International Patent & Trademark Index (Czech Republic)
IPTO International Patent & Trademark Organization (Brno, Czech Republic)
IPTR Registration of the International Trademark (Brno, Czech Republic)
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ITR Trademark Publication (Miami, FL)
P.T.M.A. Patent and Trademark Association (New York, NY)
Patent & Trademark Agency (New York, NY)
Patent & Trademark Bureau (Philadelphia, PA)
Patent and Trademark Bureau (New York, NY)
Patent & Trademark Office (250 Park Ave., New York, NY)
Patent & Trademark Office (299 Park Ave., New York, NY)
Patent & Trademark Office (555 Madison Ave., New York, NY)
Patent & Trademark Office (Jersey City, NJ)
Patent & Trademark Resource Center (Seattle, Woodinville, & Bothell, WA)
New Patent and Trademark Office (2200 Pennsylvania Ave., N.W., 4th Floor East, Wash., D.C.) New
Patent and Trademark Organization (New York, NY)
Patent Trademark Register
PTMI – Register of Protected Patents and Trademarks (Staten Island, NY)
Register of International Patents and Trademarks (Bratislava, Slovak Republic)
RPT Servis - Registration of the International Trademark (Czech Republic)
TM Collection (Szombathely, Hungary)
TM Edition (2012 version) (Szentendre, Hungary)
TM Edition (2015 version) (Szentendre, Hungary)
TM-DB Register of Protected Trademarks (Minneapolis, MN)
TM-DB Register of Protected Trademarks (Pearland, TX)
TM-DB Register of Protected Trademarks (Washington, DC)
TM-DB Register of Protected Trademarks (Wilmington, DE)
TPP - Trademark & Patent Publications (Poland)
Trademark and Patent Office (Los Angeles, CA)
Trademark Compliance Center (version 2) (Alexandria, VA)
Trademark Compliance Center (version 1) (Alexandria, VA)
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Trademark Compliance Center (Washington, DC)
Trademark Compliance Office (Arlington, VA)
Trademark Office Ltd. (New York, NY)
Trademark Registration and Monitoring Office (Intellectual Property Rights Recordation Alert) (Los Angeles, CA)
Trademark Registration and Monitoring Office (Past Due Notice) (Los Angeles, CA)
Trademark Renewal Service (New York, NY)
Trademark Renewal Service (Washington, DC)
Trademark Safeguard - Trademark Monitoring Service (New York, NY)
U.S. Trademark Compliance Office (Wilmington, DE)
U.S. Trademark Compliance Service (Phoenix, AZ)
United States Trademark Maintenance Service (version 2) (Arizona)
United States Trademark Maintenance Service (version 1) (Arizona)
United States Trademark Registration Office (Los Angeles, CA)
USTM Information Services (Idaho Falls, ID)
WDTP Registration of International Trademark (Praha, Czech Rep.) (v.1)
WDTP Registration of International Trademark (Praha, Czech Rep.) (v.2)
IPT World Patents Trademarks (Bratislava, Slovak Republic)
World Organization for Trademarks (WOTRA) (Hungary) (NEW)
WPAT World Patents Trademarks (Bratislava, Slovak Republic) (version 1)
WPAT World Patents Trademarks (Bratislava, Slovak Republic) (version 2)
WPTR (Czech Republic)
WTMR World Trademark Register (Washington, D.C.) (version 1)
WTMR World Trademark Register (Washington, D.C.) (version 2)
WTR World Trademark Register (Poland)
1/3/2019 Exhibit cover1-1
Filed - Google Docs
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EXHIBIT 3
Case 5:19-cv-01538 Document 1-1 Filed 03/25/19 Page 11 of 174
UNITED STATES PATENT AND TRADEMARK OFFICE
ROUNDTABLE ON FRAUDULENT SOLICITATIONS
TO TRADEMARK OWNERS
Alexandria, Virginia
Wednesday, July 26, 2017

Page: 2
1 PARTICIPANTS:
2 Welcome Remarks:
3 MARY BONEY DENISON
Commissioner for Trademarks
4 United States Patent and Trademark Office
5 Opening Remarks:
6 JOSEPH MATAL
Acting Under Secretary of Commerce for
7 Intellectual Property and Director
United States Patent and Trademark Office
8
Public Speakers:
9
DEE ANN WELDON-WILSON, Moderator
10 Chair
Trademark Public Advisory Committee
11
PETER SLOANE
12 Leason Ellis LLP
13
DARLENE KLINKSIECK
14 Smith, Gambrel & Russell, LLP
15
ERIC PERROT
16 Gerben Law Firm, PLLC
17
CAROL McCALLISTER
18 Champion Business Services Inc.
Denver, Colorado
19
PATRICIA COTTON (Written Statement)
20 Pillsbury Winthrop Shaw Pittman LLP
21
MICHAEL HALL (Written Statement)
22 Kacvinsky Daisak Bluni PLLC
Anderson Court Reporting -- 703-519-7180 -- www.andersonreporting.net
Page: 3
1 PARTICIPANTS (CONT'D):
2 GEORGE BOWMAN (Written Statement)
3
GEORGE CHEN
4 CPATCOCA
San Jose, California
5
CARRIE DEVORAH
6 The Center for Copyright Integrity
7
JOHN HEINBOCKEL
8 Erik M. Pelton & Associates
9
CHARLOTTE BEAUMARTIN (Written Statement)
10 Intellectual Property Regional Counselor
National Industrial Property Institute, France
11 Alexandria, Virginia
12 STEPHANIE BALD
American Intellectual Property Law Association
14 PATRICK FLAHERTY
International Trademark Association
16 Government Agencies:
17 MARY BONEY DENISON, Moderator
19 ALISON L. ANDERSON
Trial Attorney, Criminal Division, Fraud
20 Section
United States Department of Justice
21
THOMAS L. CASAGRANDE
22 Associate Solicitor
United States Patent and Trademark Office
Page: 4
1 PARTICIPANTS (CONT'D):
2 KATI DAFFAN
Assistant Director, Division of Marketing
3 Practices
Federal Trade Commission
4
DAVID FREDERICK
5 U.S. Postal Inspector
United States Postal Inspection Service
6
CLAYTON GERBER
7 U.S. Postal Inspector
United States Postal Inspection Service
8
GOLI GHARIB
9 Attorney-Advisor
United States Customs and Border Protection
10
G. NAGESH RAO
11 Chief Technologies, Office of Investment and
Innovation
12 Small Business Administration
13 Closing Remarks:
14 MARY BONEY DENISON
16 * * * * *
17
18
19
20
21
22

Page: 5
1 P R O C E E D I N G S
2 (2:02 p.m.)
3 COMMISSIONER DENISON: On behalf of the
4 USPTO and the Trademark Public Advisory Committee
5 I want to welcome everyone here today. We're
6 delighted that you're here in our office in
7 Alexandria as well as in the regional offices
8 around the country to discuss this very important
9 topic of fraudulent solicitations.
10 Fraudulent solicitations may come in
11 several different forms. They might come in a
12 renewal scam format, they might come in a useless
13 database scam, they might be a monitoring scam, or
14 they might be something related to customs and
15 border protection recordation. So, there are a
16 lot of variations on this, but the one thing that
17 we do know is that they keep coming.
18 So, we're delighted that Joe Matal is
19 here with us today. He is performing the
20 functions and duties of the Undersecretary of
21 Commerce for Intellectual Property and Director of
22 the United States Patent and Trademark Office --
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EXHIBIT 4
1/29/2019 Misleading
Case 5:19-cv-01538 Document 1-1 Filedinvoices
03/25/19 Page 17 of 174
Protect your intellectual property in the European Union
Misleading invoices
Users are receiving an increasing amount of unsolicited mail from companies requesting payment for trade mark and design services such as
publication, registration or entry in business directories.
A searchable list of the firms or registers that users have complained of as having sent
Avoid Misleading misleading invoices is published below (along with copies of the actual invoices) for your
information. Please note that these services are not connected with any official trade
Payment Requests mark or design registration service provided by public bodies within the European Union
such as the European Union Intellectual Property Office (EUIPO).
You can browse through the list of invoices below or search directly by sender name in
Don't pay until you have checked that the source
the “Quick Search” box.
is official.
EUIPO never sends invoices or letters requesting If you receive a letter or invoice please check carefully what is being offered to you and
direct payment for services to users whether its source is genuine.
If you have any doubts or if you identify any new cases, please check with your legal
advisors or contact us.

Search by sender
Quick search
Company
WPTR_-_World_Patent_and_Trademark_register
WIPOT - Trademark Protection
WTP - World Trademark Publication
ITPR - International Trademarks Publication Register
WOIP - World Organization Intellectual Property
ITP - IPT Service
IPATD - Iternational Patent and Trademark Directory
WOTRA - World Organization for Trademarks
EUIPD - European Union Intellectual Property Directory
IPTA - International Patent Trademark Agency
Showing 1 to 10 of 133 entries
Related content
Fees & payments

File online from €850
Manage
KeepWe
youruse cookies
EU trade mark on our website to support technical features that enhance your user experience. We also use analytics.
up-to-date
Click for more information x

Page last updated 03-07-2018
https://euipo.europa.eu/ohimportal/en/misleading-invoices 1/2
1/29/2019 Misleading
Case 5:19-cv-01538 Document 1-1 Filedinvoices
03/25/19 Page 18 of 174
Avenida de Europa, 4, E-03008 Alicante, Spain

Information centre: +34 965 139 100
© EUIPO 1995-2018
Translated from English into the other languages of EU by the Translation Centre for the Bodies of EU
We use cookies on our website to support technical features that enhance your user experience. We also use analytics.
Click for more information x
https://euipo.europa.eu/ohimportal/en/misleading-invoices 2/2
Filed - Google Docs
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EXHIBIT 5
2/6/2019 WARNING:
Case 5:19-cv-01538 Document Requests
1-1 Filedfor Payment
03/25/19of FeesPage 20 of 174
WARNING: Requests for Payment of Fees

It has come to the attention of the International Bureau that PCT applicants and agents are receiving
invitations to pay fees that do not come from the International Bureau of WIPO and are unrelated to the
processing of international applications under the PCT. Whatever registration services might be offered
in such invitations, they bear no connection to WIPO or to any of its official publications.
PCT applicants and agents should note that it is the International Bureau of WIPO alone which
publishes all PCT applications promptly after the expiration of 18 months from the priority date
(see PCT Article 21(2)(a)); there is no separate fee for such international publication, and the legal
effects of international publication are set out in PCT Article 29.
The invitations often identify a particular PCT

application by its international publication number
(eg: WO 02 xxxxxx), publication date, title of the
invention, international application number, priority
information and IPC symbols; examples of such
invitations can be viewed below.
WPTR – World Patent and

Trademark Register
Published on November 26,
2018
IPTA – International Patent

and Trademark Agency
Published on July 23, 2018
IPTR – Intellectual Patent

and Trademark Register
Published on February 13,
2018
https://www.wipo.int/pct/en/warning/pct_warning.html 1/22
2/6/2019 WARNING:
IPRS – Intellectual
property register services Invitation not listed here? E-
Published on February 5, mail us a copy
2018 Trademarks (Madrid System)
Patents (PCT System)
Mitigating this unscrupulous

practice
WPT service – World Patent
and Trademark Service WIPO invites its customers to use and adapt this
standard text to notify applicants and inventors about
Published on October 25, such fee requests.
DOC
2017 Circular letter addressed by WIPO Director General,
Francis Gurry to all PCT Contracting States and
Regional Organizations.
PDF
IRO – The Patent Office How to make a complaint?

Published on July 28, 2017 WIPO works closely with its member States with the goal of
putting an end to this practice, and has assembled the
following list of government authorities and consumer
protection associations which assist applicants in enforcing
local laws against the purveyors of these invoices.
Complaints can be filed through the websites listed in the
various countries.
Filing a complaint enables investigations to begin, which

may in turn result in legal action against these entities. To
ITMORG – International facilitate the making of a complaint, you may consider
Trademark Monitoring using the following sentence:
Organization “I request that these unsolicited invoices be investigated

and any corrective legal action, including civil or criminal
Published on May 16, 2017 proceedings, be taken based on a contravention of the
applicable laws on unfair business practice, unfair
competition and general criminal law.”
A scanned copy of the invoice received, plus any further

evidence, should also be attached. In the past, WIPO has
provided expert testimony at trial, describing the harm
IP Direct – International caused by this practice and the lack of value of the
Patent & Trademark services provided, and is willing to continue to support
applicants in this way.
Directory
Published on January 24,
2017 Successful legal actions
WIPO works closely with its member States with the goal of
putting an end to this practice, and has assembled the
following list of judgments against certain entities.
IRO – Intellectual Property Office
Published on November 1, 2016
Envelopes
2/6/2019 WARNING:
PCT applicants and agents have informed the International

Bureau that some of these requests to pay fees are being
sent in envelopes which appear to bear the WIPO/OMPI
logo and the address of the organization. Please carefully
review all such requests. The services which are being
offered in these invitations do not come from WIPO.
Payment
IRPT – International The invitations typically refer to a payment, which is to be
made in euro or US dollars, by cheque and/or money
Register of Patents & transfer to addresses in:
Trademarks
AT: Austria; CH: Switzerland; CY: Cyprus; CZ:
Published on October 26, Czechia; CN(HK): Hong Kong; DE: Germany; DK:
Denmark; ES: Spain; GB: United Kingdom; IS:
2016 Iceland; PL: Poland; SK: Slovakia; US: United States
of America
PATR Servis – Worldwide

Patent Service
Published on June 30, 2016 Other industrial property
Offices have made similar
warnings
AT: Austrian Patent Office (in German)
AU: Australian Patent Office
IPWTO – Intellectual CA: Canadian Intellectual Property Office
CH: Swiss Federal Institute of Intellectual Property
Property World Trade CZ: Industrial Property Office (Czechia)
Organization DE: German Patent and Trade Mark Office (in German)
DK: Danish Patent and Trademark Office (in Danish)
Published on June 28, 2016 EM: European Union Intellectual Property Office
(EUIPO)
EP: European Patent Office
ES: Spanish Patent and Trademark Office (in Spanish)
FR: National Institute of Industrial Property (France)
GB: United Kingdom Intellectual Property Office
IIP – International HU: Hungarian Intellectual Property Office (HIPO)
IE: Patents Office (Ireland)
Intellectual Property Office IL: Israel Patent Office (in Hebrew)
IT: Italian Patent and Trademark Office (in Italian)
Published on February 22, JP: Japan Patent Office (in Japanese)
2016 KR: Korean Intellectual Property Office (in Korean)
NZ: Intellectual Property Office of New
Zealand (IPONZ)
SK: Industrial Property Office (Slovakia)
US: United States Patent and Trademark Office
IPTI – International Patents
The sending of these notices appears to not be
& Trademark Index restricted to the patent context; within WIPO, the
administration of the Madrid System for the
Published on February 15, International Registration of Marks has placed a
2016 general warning on its website in relation to such
invitations to pay fees.
2/6/2019 WARNING:
WIPD – Registration of
International Patents
Intellectual Property Office
2016
OPT – Organization for

Patents and Trademarks
Published on December 18,
2015
WPAT – Registration of
Published on October 14,
2015
IP Save
Published on September 24,
2015
Patent Registration - R & W

Stretch Ceilings Ltd.
Published on May 8, 2015
WPTS - World Patent & Trademark

Service
Published on April 16, 2015
2/6/2019 WARNING:
WPTO - World Patent &

Trademark Organization
2015
Search Index Registration

Department - Registration
of International Patent
2014
WIPO - World Intelligent

Property Office
2014
RPT Servis - World Wide

Patent Service
2014
WIPP - World Intellectual

Property Publisher
2014
2/6/2019 WARNING:
IP World – Registration of
International Patent
2014
IPTO - International Patent

& Trademark Organization
2014
IPT Patents
2014
IPTG - International Patent and

Trademark Guide
Published on August 19, 2014
WOPD - Worldwide Online

Patent Database
UPTS - Universal Patents and

Trademarks Service
2/6/2019 WARNING:
Commercial Center for

Industry and Trade
Euro IP Register
WIPD - World Intellectual

Property Database
WPTI - World Patent and

Trademark Index
UPTS - Universal Patents

and Trademarks Service
2/6/2019 WARNING:
IPT PATENTS - Register of

2014
FOIP - Federated
Organization for
Intellectual Property
2014
IPTS - International Patent

and Trademark Service
2013
IPTR - International Patent

2013
IP DATA - Register of
2013
WBIP - World Bureau for Intellectual

Property
Published on September 10, 2013
2/6/2019 WARNING:
TPS - Trademark and

Patent Service
Novislink limited
European Register of
Brands and Patents
(REGIPAT)
IPTS - International
Patent and Trademark
Service
2/6/2019 WARNING:
UPTS - Universal Patents

and Trademarks Service
Published on March 1,
2013
WIPT - Registration of
2013
2013
WDTP - Worldwide
Database of Trademarks
and Patents
2012

Trademark Index
2012
2/6/2019 WARNING:
Published on June 8, 2012
ODM - Patent Trademark

Register
2012
RIPT - Registration of
2012

Register
2012
2012
2/6/2019 WARNING:
European Central
Register of Brands and
Patents
2012
Euro IP Register
2012
2012
2012
IOPR - Intellectual Office

Property Register
2012
Euro IP Register
2/6/2019 WARNING:

2011
WDTP - Worldwide
and Patents
2011

Register
2011
2011
CPTD - Central Patent &

Trademark Database
Published on September
2, 2011
2/6/2019 WARNING:
WDTP - Worldwide
and Patents
Published on August 2,
2011
WDTP - Worldwide
and Patents
ODM - Patent &

Trademark Office
WOIP - Globex World

Organisation Intellectual
Property
2011
WOIP - Globex World

Property
Published on March 3, 2011
2/6/2019 WARNING:

Property Database
Published on March 3, 2011
WDTP - Worldwide
and Patents
2011

Property Database
2011

Property Database
2011

Register
2011
2/6/2019 WARNING:
2011

Property Database
2010
ITPD - International
Trademarks & Patents
Database
2010

Trademark Index
2010
WOIP - Globex World

Property
28, 2010
2/6/2019 WARNING:

Property Database
13, 2010
13, 2010
2010
WBIP - World Bureau for

IPTD- International
Patents and Trademarks
Database
2010
2/6/2019 WARNING:
IBIP - International
Bureau for Intellectual
Property
2010

2010

2009
IOPTS - International
Organization for Patent &
Trademark Service
2009
IRTP - International
Register for Trademark &
Patent
2/6/2019 WARNING:
IBFTPR Service - Register

of International Patent
Application
Published on May 4,2009

Register
2009
IPTR - International Patent

2008
Property
2008
RIPT - Register of
International Patents and
Trademarks
2008
2/6/2019 WARNING:
Property

Register
2008
IBFTPR - International
Bureau for Federated
Trademark & Patent
Register
Published on November
21,2007
IOIP - International
Organization for
2007
ODM - Register of
2007
2/6/2019 WARNING:
ODM - Office Data

Management
IOPTS - International
Organization for Patent &
Trademark Service
FIPTR - Federated
Institute for Patent and
Trademark Registry Inc.
2007
CPTD - Central Patent &

Trademark Database
22, 2006
Commercial Center for

Industrie and Trade
2006
CPD - Central Patent Database

2/6/2019 WARNING:
Register of International
Patents
Register of International
Patent Bulletin/Registre
des données bulletin
européen des brevetes
2003
Institut of Commerce for

Industry, Trade,
Commerce/Wirtschaftsins
titut für Industrie, Handel,
Handwerk AG
2003
Central Data-Register of
2002
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EXHIBIT 6
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EXHIBIT 7
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EXHIBIT 8
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EXHIBIT 9
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EXHIBIT 10
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EXHIBIT 11
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EXHIBIT 12
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EXHIBIT 13
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EXHIBIT 14
1/30/2019 Case 5:19-cv-01538 Documentnimbus
1-1 screenshot app print
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screenshot-glotrade.world-2019.01.30-16-25-46
https://glotrade.world/
30.01.2019
chrome-extension://bpconcjcammlapcogcnnelfmaeghhagj/edit.html 1/2
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EXHIBIT 15
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EXHIBIT 16
1/30/2019 Terms1-1
Case 5:19-cv-01538 Document & Conditions
Filed- 03/25/19
GLOTRADE Page 68 of 174
Home Trademarks Search News  Patents Search Service  About Us Language 
Terms of Service
Home Privacy Policy Terms of Service Cookies Policy
General Terms & Conditions

General provisions
1.1 Glotrade (registered office: Mlýnská 326/13, Trnitá, 602 00 Brno) central email address: office@glotrade.world; hereinafter
referred to as the Service Provider) operates the database.
1.2 These General Terms and Conditions (hereinafter referred to as GTC) contain the general terms and conditions for the use
of the prepaid service provided by the Service Provider as set out in section 1.5 of these GTC and the rights and obligations of
the contracting parties when using the prepaid service. These GTC apply to the Service Provider as well as to the customers
who conclude a contract with the Service Provider for the use of the prepaid service provided by the Service Provider. The
legal relationship between Service Provider and Customer shall not be subject to the Customer's general terms and conditions
or similar documents, if any. Service Provider. The Service Provider shall make the GTC available to the Customer in such a
way that allows them to print them.
1.3 A customer of the Provider is any person who pays the Provider the fee to access the Provider’s Prepaid Service
(hereinafter the "Customer"). The Customer has a Journal Number, as specified on the first page, which also acts as a LOGIN.
Using that number, the Customer can access our entire database after paying the Fee. The database provided by GLOTRADE
s.r.o. is available for downloading at the web address www.glotrade.world. The Customer is enabled, within the framework of
the search function in the database, to use the results to track similarities in the “US-TRADEMARK” and identify infringements
of its own trademark or trademarks and assert claims against persons who benefit from those trademarks or pre-empt such
infringements.
1.4 A database for the purposes of these General Terms and Conditions (hereinafter the "GTC") means the Provider’s
operated integrated set of generally available information, arranged into categories, that permits the Customer after paying the
Fee to gain access to the Prepaid Service, while the Provider guarantees its functionality (hereinafter the "Database").
1.5 For the purposes of these GTC, Prepaid Service means access to the paid sections of the Database under the current
service offered by the Provider published on www.glotrade.world through the Provider system after payment of the Fee, and in
the prepaid period during an unlimited time period (hereinafter "Prepaid Services").
1.6 Fee for the purposes of these GTC means the amount the Customer pays the Provider for access to the Prepaid Service
for a limited period and according to the current offer the Provider sends to Interested Parties (hereinafter the "Fee").
https://glotrade.world/Terms 1/4
1/30/2019 Terms1-1
Filed- 03/25/19
Customer withdrawal from the offer and the order
2.1 An agreement can be reached between the Service Provider and the Customer on the provision of the Prepaid Service: (i)
without conclusion of a contract, by submitting the order form available for this purpose on the homepage of the Service
Provider glotrade.world, provided this has been confirmed by the Service Provider in writing – within 7 days from dispatch of
order – and the Customer has paid the Service Fee specified in the current offer by the Service Provider; the Service Provider
is not obliged to enter into a contract, to accept or confirm the order; (ii) with conclusion of a specific contract, provided the
Customer has paid the Service Fee specified in the current offer by the Service Provider.
2.2 A poorly or incorrectly filled out order form does not constitute a declaration forming the basis for a conclusion of a contract
for the provision of the Prepaid Service. Such order forms do not constitute any obligation for the Service Provider.
2.3 The Customer may withdraw from the contract within 8 days after conclusion of the contract for the provision of the
Prepaid Service without giving reasons. The effective date for the contract on the provision of the Prepaid Service is the day
on which the Service Fee is paid.
General terms of payment
3.1 The Service Provider shall render the Prepaid Service for the Customer against payment of the Service Fee in accordance
with its current offer.
3.2 The Customer has to pay the Service Fee by bank transfer to the bank account designated by the Service Provider.
Payment shall be considered as made when the relevant gross amount is credited to the Service Provider's bank account.
Exclusion of liability and miscellaneous terms
4.1 The Service Provider uses the contents of the national, EU and international registers for the compilation of the database
"as is" and assumes no liability for the correctness and completeness of the information contained in these registers.
4.2 The Service Provider shall not be liable for any direct or indirect damages, for loss of profits, loss of business, for loss of
business opportunities or cessation of business development resulting from the access to, use or non-usability of
glotrade.world, even if the Service Providers could have known of the possibility of such damages or loss.
4.3 The Service Provider reserves the right to suspend, restrict or interrupt the use of the database by the Customer at any
time without separate notice at its sole discretion, especially, but not exclusively, if the use of the database by the Customer is
aimed at unlawful purposes.
Termination and cancellation
5.1 The contract on the provision of the Prepaid Service shall automatically end upon expiry of the fixedperiod of one year and
cannot be cancelled by ordinary termination.
5.2 Each of the parties is entitled to terminate the contract for provision of the Prepaid Service with immediate effect in the
case of a breach by the other party. Before immediate termination of the contract for the provision of the Prepaid Service, the
contracting party is required to give the other contracting party a reasonable period of time for taking corrective actions of the
defaults which constitute reason for the termination (as far as they can be remedied ). Any circumstance which makes further
cooperation with the other contracting party unacceptable is considered a valid reason for termination.
Confidentiality
1/30/2019 Terms1-1
Filed- 03/25/19
6.1 In particular, all information or documents and other data carriers of the contracting parties, which were classified
confidential by the parties concerned in writing or otherwise or whose confidential nature results from the nature of the relevant
information, documents or data carrier, including the business secrets of the contracting parties, is considered confidential
information.
6.2 Both parties are committed to the confidential treatment of all confidential information and documents. They have to make
sure that unauthorised persons do not have access to confidential information. The duty of confidentiality of the contracting
parties does not end, even after the cancellation or termination of the individual contract, irrespective of the reason thereof.
Applicable law legal disputes
7.1 These GTC and the individual contracts are subject to law.
7.2 The parties shall attempt to settle controversial issues relating to these GTC or the contract for the provision of the Prepaid
Service through negotiations, initially out of court. Should these negotiations be unsuccessful, the parties may apply to the
court having jurisdiction over the registered office of the Service Provider within 30 days after the start of the negociations.
These Terms and Conditions shall come into force on 01.11.2017.
Data protection
8.1 The privacy policy of the Service Provider for the homepage glotrade.world is available under the link Privacy Policy &
Cookies Policy.
SERVICES
Trademark Protection Google Play® Monitoring
Trademark Research App Store™ Monitoring
Domain Monitoring
SHORT POSTS & ARTICLES
Domain name registration continues to grow

POSTED ON JAN 2019
Managing Trademark Clutter in a Busy IoT World

POSTED ON DEC 2018
Imitation Is No Longer Flattering

POSTED ON NOV 2018
1/30/2019 Terms1-1
Filed- 03/25/19
Home / Privacy Policy / Terms of Service / 2019-01-29 / Cookies Policy   
© 2019 Glotrade.world. All Rights Reserved.
Filed - Google Docs
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EXHIBIT 17
PATENT & TRADEMARK RESOURCE
Case CENTER Document 1-1 Filed 03/25/19 Page 73 of 174
5:19-cv-01538 Form: Section 8
trademark renewal Order: 2076A 7203055
Your Trademark is about to expire. Renewal date: 2016-12-27
r 1. Address and Name: , 2. Graohic reoresentation:
L
IMPORTANT TRADEMARK RENEWAL OFFER UNDER DECLARATION SECTION 8
A
3. Trademark Name: 6. Serial Number:
4. Type: 7. Number of Classes:

Trademark 1
5. Registration Date: 8. Classes:
Dec. 27,
9 . ORDER FORM and POWER OF ATTORNEY
Please sign and return this document to Patent & Trademark Resource Center, LLC in the enclosed envelope in order to start the Trademark Renewal
process. Trademark registration requires an Act of the filling between the 5th and 6th years after registration to remain valid. You will
receive an invoice from Patent & Trademark Resource Center, LLC after receiving this signed document from you. By signing this document. you are
placing an order for filling the declaration of the identified trademark registration for the classes identified in this Order Form and you confirm it, you
have reviewed and accepted the Terms and Conditions (appearing in internet site www.ptrc.us) and the terms of this Order Form. By signing this
document, you grant Patent & Trademark Resource Center LLC a power of attorney to represent you in filling the declaration concerning your
trademark renewal. One class renewal fee is $ 850 and each subsequent class $ 300. This Order and Power of Attorney is optional and acts
only as a reminder. This is not a bill. Patent & Trademark Resource Center, LLC is a private, non-governmental company and isn't connected to any of
the governmental organizations. If you have any questions regarding the renewal of your Trademark, please contact Patent & Trademark Resource
Center, LLC renewal department via e-mail : info@ptrc .us.
1 O. Additional services:
DPease check box if you are interested in filling a Trademark Incontestability (15 U.S.C. § 1065) for additional Fee$ 400 per class
11. Section 8 Filling Fees: 12. SIGN AND RETURN IN THE ENCLOSED ENVELOPE:
One class Renewal fee : $ 850
Each subsequent class : $ 0
-
TOTAL Fee: (Name and Title)
$ 850
(e-mail)
(Date and Signature)
13. The renewal and update process looks as follows:

1. You receive the Order Form from Patent & Trademark Resource Center, LLC;
2. You submit siqned Order Form and mail it back to Patent & Trade Resource Center, LLC in the provided Business Reply envelope;
3. Receive an invoice and Order confirmation from Patent & Trademark Resource Center, LLC that we received your application within the deadline;
4. Upon receipt of all the fees the trademark renewal documents will be submitted by our expert in United States Patent and Trademark Office
and Government fee paid;
5. After procedure conclusion Patent & Trademark Resource Center, LLC will send an Acceptance Notice of Renewal from United States Patent and Trademark Office.
10·17·2016
111111111111111111111111111111111111111111111111111111111111
Patent & Trademark Resource Center LLC, 17200 153rd Avenue, Yelm, SE, WA 98597
tel. : 1-844-888-8018 Business hours: Mon-Fri from 9:00 am to 3:00 pm EDT
www.ptrc.us U.S. Pat ent & TMOIC/TM Mall Rcpt Ot #1 1
PATENT & TRADEMARK RESOURCE CENTER PRES<
FIRST-C
17200 153rd AVENUE, SEATTLE, WA 98597
U .S. PC
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PERMIT
IMPORTANT- OPEN IMMEDIATELY
11 •• i 1111111·1·1111 11 111•1 1II'11II···1·1111 11 11•1 1··11 1•111

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NO POSTAG
NECESSARY
IF MAILED
IN THE
UNITED STAT
BUSINESS REPLYWOODINVILLE,
FIRST-CLASS MAIL
PERMIT NO. 54
MAIL WA
POSTAGE WILL BE PAID BY ADDRESSEE
PATENT & TRADEMARK RESOURCE CENTR

P/0 BOX: 643
WOODINVILLE WA 98072-9930
1•11•11··•·1•111 1•1l•11111l'l'••l'1ll1•··'lll1ll1llllll llll11•'•

1
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Home
Corporate Compliance Center
Fictitious Business Name

Renewal Center
United States Patent Renewal Service

Compliance Filings, Inc. (“CFI”) is a full service nationwide filings compliance
company, providing businesses and business owners in all states with
United States Trademark Renewal
assistance in complying with various State and Federal laws relating to their
Service businesses. Please contact us by phone for more information on our services.
About CFI
Compliance Filings Divisions
CFI has several divisions to assist its clients in meeting all of their compliance
requirements.
Assumed Business Name Renewal Service
Assumed Business Name Renewal Service assists businesses in various

states requiring compliance notices and filings with respect to Assumed
Business Names. Services include renewal registration and modifications of
Assumed Business Names.
Corporate Compliance Center assists corporations in various states in

maintaining their required annual corporate minutes, filing amendments to
Articles of Incorporation, name changes, abandonment of names, name
reservations, formation and dissolution of corporations.
Fictitious Business Name Renewal Service
Fictitious Business Name Renewal Service division assists business owners

operating under Fictitious Business Names in meeting their compliance filings
requirements with respect to registration, renewal, assignment, abandonment
and modifications.
Labor Poster Compliance Center
Labor Poster Compliance Center assists businesses in complying with the

various State and Federal notice and posting requirements to employees by
providing a complete labor poster compliance solution.
United States Patent Renewal Service
United States Patent Renewal Service provides United States patent owners
with assistance in renewing patents.
United States Trademark Renewal Service
United States Trademark Renewal Service provides trademark owners with

assistance in renewing their United States trademarks.
http://www.compliancefilings.com/index.html 1/2
03/25/19 Page 83 of 174
EU Trademark Registration Service
EU Trademark Registration Service provides owners of United States Patents

with registration of their existing US Patents in all EU countries.
Home | Corporate Compliance Center | Fictitious Business NameRenewal Center | United States Patent Renewal Service |
United States Trademark Renewal Service About CFI
http://www.compliancefilings.com/index.html 2/2
03/25/19 Page 84 of 174
Home
Fictitious Business Name

Renewal Center
United States Patent Renewal Service United States Trademark Renewal Service
United States Trademark Renewal United States Trademark Renewal Service provides trademark
Service owners with assistance in renewing their United States
trademarks.
About CFI
Your United States Trademark Is Scheduled For Cancellation If You Have
Not Renewed It.
Your United States Trademark will be cancelled by the United States Patent
and Trademark Office (PTO) unless you take the necessary action to preserve
it.
Avoid Cancellation By Timely Filing Your Declaration(s)
To prevent cancellation of the mark, you must file a Declaration of Use stating
your use of the mark in commerce or that your non-use is due to special
circumstances. If you qualify, you may also file a Declaration of Incontestability
to acquire certain additional rights.
United States Trademark Renewal Service Can Help You Renew Your
Trademark Now
We can prepare and forward to you for your signature all documents necessary
to avoid cancellation if you take the steps outlined below.
You Must Complete Both Sides Of The Form That You Received And Mail
It With Your Payment. Please Print Or Type the Requested Information on
the Form
1. Review the accuracy of the data on the form;

2. Make corrections if necessary;
3. Complete the answers to the questions on the back; and
4. Return the form in the enclosed envelope with your check for $250 made
payable to USTRS.
Home | Corporate Compliance Center | Fictitious Business NameRenewal Center | United States Patent Renewal Service |
United States Trademark Renewal Service About CFI
http://www.compliancefilings.com/trs.html 1/1
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Patent & Trademark Office

Once you have filed your trade mark there are a number of things you must do to
maintain your application or registration. It is your responsibility to meet deadlines.
You may also wish to make limited changes as outlined below.
(/trademarks)
Trademarks (/trademarks)
A trademark is a word, phrase, symbol, and/or design that identifies and distinguishes the source of the
goods of one party from those of others.
(/patents)
Patents (/patents)
A patent is a limited duration property right relating to an invention.
(/renewal)
http://www.patenttrademarkoffice.org/ 1/2
Filed 03/25/19 Page 91 of 174
Trademark Renewal (/renewal)
The Renewal process looks as follows:
1. You receive the Reminder from Patent Trademark Office

2. You sign it and mail it back to us in the Reply Paid envelope provided
3. We send you the invoice after we receive the signed Reminder from you
4. Upon receipt of all the fees the trademark is renewed
(/patents-maintenance)
Patents Maintenance (/patents-maintenance)

All utility patents are subject to maintenance fees, which must be paid to maintain the patent in force.
Maintenance fees are due three times during the life of a patent.
Copyright © 2019. Patent & Trademark Office. All rights reserved.
http://www.patenttrademarkoffice.org/ 2/2
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Filedus 03/25/19 Page 92 of 174
About us
For many businesses, the process for registering and renewing patents and trademarks can be difficult,
complicated, and fraught with chances for error. Every year, businesses and individuals lose millions of dollars in
valuable intellectual property because of missed deadlines and procedural mistakes. The Patent Trademark
Office provides the expertise that modern businesses need to navigate the Trademark and Patent renewal
processes.
You need experienced, professional assistance to protect your assets. Don’t let your hard-earned property go to
waste!
Headquartered in New York City, the Patent Trademark Office is the nation’s premier Trademark and Patent
renewal service.
Copyright © 2019. Patent & Trademark Office. All rights reserved.
http://www.patenttrademarkoffice.org/about-us 1/1
Filed 03/25/19 Page 93 of 174
Services
1. Trademark registration:
One of the primary requirements for trademark registration is that a mark be used in commerce. This means you need to already be selling a
product or service using the name you wish to trademark. In the United States, However, the United States Patent and Trademark Office
(USPTO), has a special exception where trademark applicants can file under “intent to use” to preserve the rights to a name they are not
currently using in commerce. There are, however, two caveats applicants must be aware of: (1) the filer has six months to use the mark from
time the USPTO issues a “notice of allowance” (this time can be extended up to three years), and (2) there is a filing fee associated with filing the
Statement of Use (this fee depends on the number of classes in which you are using your mark).
2. Trademark renewal
The owner of the registration must renew his trademark during the following time periods:
First Filing Deadline: File between the 5th and 6th years after the registration date. If the renewal is accepted, the registration will continue in
force for the remainder of the ten-year period from the registration date.
Subsequent Filing Deadline: File between the 9th and 10th years after the registration date, and between every 9th and 10th year after the
registration date thereafter.
NOTE regarding Grace Period Filings: The above documents will be accepted as timely if filed within six months after the deadlines listed above
with the payment of an additional fee.
The renewal process looks as follows:
1. Receive the Order Form from Patent & Trademark Office, sign it and mail back in the reply paid envelope provided;
2. Receive an invoice and after payment the trademark renewal process will be started;
3. Electronic filing copy and renewal Notice from United States Patent and Trademark Office will be sent to your e-mail.
3. International trademark registration and renewal

The United States’ membership in the Madrid Protocol has made it easy and affordable for U.S. trademark holders to protect their trademarks in
roughly 80 countries around the globe. Moreover, protection can be secured in non-member nations as well; it just takes a few extra steps.
a. Own a U.S. trademark application or registration;
Be a U.S. citizen, a U.S. business entity, or have a real and effective presence in the U.S.
c. Know which specific countries in which they would like protection that are part of the Madrid Protocol. For a list of those countries Click Here.
An application to extend their U.S. trademark rights may then be made with the U.S. Patent and Trademark Office directly seeking protection in
specific countries who have also signed the Madrid Protocol.
4. Trademark transfer
There are a variety of reasons why you may want to transfer ownership of your federally registered trademark (or acquire ownership of a
trademark). For example, trademarks may need to be assigned during a business acquisition or as part of reorganization. How to transfer
ownership of trademarks and why you should ensure you transfer your trademarks correctly? Transferring your trademark includes two major
steps: documenting the transfer between the parties and then documenting the transfer with the U.S. Patent and Trademark Office (USPTO).
Before you can document your transfer with the USPTO, you’ll need to put together a trademark transfer (or assignment) agreement. This
document will lay out the terms of the transfer, including payment terms, what rights are being assigned, the USPTO registration number of the
trademark, and any representations and warranties from the current owner of the trademark—the current owner typically represents to the new
owner that they own all rights to the trademark, have the authority to transfer the mark, and are not aware of pending claims against the
trademark or its use.
If you fail to properly transfer ownership of your trademarks and the individual or company that you sell your rights to does something with the
trademark that infringes on another trademark, then, because you still technically own the trademark (at least as far as the USPTO records go),
you may be roped into the dispute.
On the flipside, if you purchase the rights and interest to a trademark and never properly record the transfer with the USPTO, then you may end
up in a battle over ownership with the prior owner—the prior owner technically still owns the trademark until the transfer is recorded with the
USPTO.
In order to move forward with transferring ownership of the registered trademark with the USPTO, you are first required to have a signed
trademark transfer agreement.
5. U.S. Customs and Border Control

The U.S. Customs and Border Protection maintains an aggressive trademark enforcement program to target, intercept, detain, seize and forfeit
shipments of goods which violate your trademark rights. Their enforcement is accomplished through the cooperative efforts of trained
enforcement officers, other government agencies, and the trade community to prohibit infringing goods from entering the United States. All
that is needed to block the importation of infringing goods is to “record” registered trademarks with the U.S. Customs and Border Protection.
6. Patents Maintenance
All utility patents which issue from applications filed on or after December 12, 1980 are subject to maintenance fees, which must be paid to
maintain the patent in force.
Maintenance fees are due three times during the life of a patent, and may be paid without surcharge at:
Three to three and a half years after the date of issue for the first payment;
Seven to seven and a half years after the date of issue for the second payment;
11 to 11 ½ years after the date of issue for the third and final payment.
Maintenance fees may be paid with a surcharge during the following "grace periods:"
Three and a half years and through the day of the fourth anniversary of the grant of the patent; Privacy - Terms
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Filed 03/25/19 Page 94 of 174
Seven and a half years and through the day of the eighth anniversary of the grant of the patent;
11 ½ years and through the day of the 12th anniversary of the grant of the patent.
About us
Patent & Trademark Office is a private service firm assisting customers in understanding U.S. federal and
international trademark registration and renewal.
For many businesses, the process for registering and renewing patents and trademarks can be difficult,
complicated, and fraught with chances for error. Every year, businesses and individuals lose millions of dollars in
valuable intellectual property because of missed deadlines and procedural mistakes. The Patent Trademark Office
Registration & Renewal Service provides the expertise that modern businesses need to navigate the Trademark and
Patent renewal processes.
You need experienced, professional assistance to protect your assets. Don’t let your hard-earned property go to
waste!
Headquartered in New York City, the Patent Trademark Office Registration & Renewal Service is the nation’s
premier Trademark and Patent renewal service.
Contact Us
Full Name
Patent & Trademark Office Registration & Renewal Service
Correspondence address: Email Address
387 Park Avenue South, 5th Floor, New York, NY 10016
Phone Number
Toll Free:
888-829-8316 Message
Fax:
1-855-276-5199
E-mail:
info@ptoffice.us
Contact Us
 Services
FAQ
About Us Contact Us FAQ
We are often asked do I need a trademark for my slogan? Can I patent my idea? How do I keep others from copying seminar materials that I
have written? Well, here’s a primer for what all small business owners should know to protect their valuable intellectual property assets
First, you need to know what the various forms of intellectual property are and how they can help you protect what is yours.
Patents
Patents, generally speaking, protect inventions that are useful, original, and an improvement upon an existing machine or invention. Today they
can be used to protect everything from new and unique computer components to specially engineered geniuses of plant species. There is even
a statute that allows for the protection of unique manners or inventive manners of transacting business know as a business method patent. So
the easiest way of thinking about patents is that they protect inventions.
Privacy - Terms
Filed 03/25/19 Page 95 of 174
Trademarks
Trademarks are your brand identifiers. They tell consumers who produced the product (e.g., Coca Cola used for soda) or who is providing the
service (e.g., McDonalds for restaurant services). They can include any word, name, symbol, or device, or any combination used, or intended to
be used, in commerce to identify and distinguish the goods or services of one manufacturer or seller from goods manufactured or sold by
others, and to indicate the source of the goods. In short, they are the way the consumer identifies what they are buying and who is providing
the goods or services behind what they purchase.
Copyrights
Copyrights protect original works of artistic expression including literary, dramatic, musical, artistic, and certain other intellectual works. They
include protection for books, articles, music, lyrics, plays, screen plays, scripts, dance routines, works of art, statutes, movies, television
broadcasts, albums, CDs, and even components of a web site. A copyright gives the author of the work at issue the exclusive right to reproduce
the artistic creation.
Protecting Your Patents, Trademarks, and Copyrights

At this point most people ask what do they need to do to protect their trademarks, patents, and copyrights from others using the same without
permission (i.e., infringement). The answer depends.
Trademarks generally exist from the moment you start using your trademark in commerce or interstate commerce. Registration with the U.S.
Patent and Trademark Office is not required to acquire trademark rights but it is highly recommended to deter others from infringing upon your
trademark and quite useful should you ever be required to enforce your rights in the same.
Patents are a creature of statute and must be registered with the U.S. Patent and Trademark Office to receive protection.
Copyrights are, to some degree, for registration purposes, are a hybrid between patents and trademarks. Copyright protection exists in a
protected work from the moment the work is created. However, in order to enforce a copyright it is generally the rule that a copyright
registration from the U.S. Copyright Office must first be attained.
And there’s a brief overview of the distinctions between the three major forms of intellectual property protection all small business owners
should be aware of to protect their business’s intellectual property assets.
As always, if you have any questions regarding this or any related topics Contact Us.
Privacy - Terms
3/4/2019 Case 5:19-cv-01538 PtOffice.us
Document WHOIS,
1-1DNS,Filed
& Domain Info - DomainTools
03/25/19 Page 96 of 174
Home > Whois Lookup > PtOffice.us
Whois Record for PtOffice.us

 Domain Profile
Registrant Kristopher Kristopher
Registrant Org Patent & Trademark Office
Registrant Country US
Registrar GoDaddy.com, Inc.

IANA ID: 146
URL: whois.godaddy.com
Whois Server: whois.godaddy.com
(p)
Registrar Status clientRenewProhibited, clientDeleteProhibited, clientTransferProhibited,

clientUpdateProhibited
Dates 332 days old 

Created on 2018-04-06
Expires on 2019-04-06
Updated on 2018-04-11
Name Servers NS55.DOMAINCONTROL.COM (has 50,979,255 domains) 

NS56.DOMAINCONTROL.COM (has 50,979,255 domains)
Tech Contact Kristopher Kristopher

Patent & Trademark Office
387 Park Avenue South,,
New York, New York, 10016, US
(p)
IP Address 91.105.27.50 is hosted on a dedicated server 
IP Location - Riga - Riga - Sia Lattelekom
ASN AS12578 APOLLO-AS Latvia, LV (registered Aug 03, 1999)
Domain Status Registered And Active Website
IP History 13 changes on 13 unique IP addresses over 1 years 
Hosting History 3 changes on 2 unique name servers over 1 year 
 Website
http://whois.domaintools.com/ptoffice.us 1/4
Document WHOIS,
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Website Title Patent & Trademark Office 
Server Type Kestrel
Response Code 200
Terms 1,720 (Unique: 576, Linked: 17)
Images 0 (Alt tags missing: 0)
Links 7 (Internal: 0, Outbound: 1)
Whois Record ( last updated on 2019-03-04 )
Domain Name: ptoffice.us

Registry Domain ID: D5DD2351D84B4439F97E4302E706843E8-NSR
Registrar WHOIS Server: whois.godaddy.com
Registrar URL: whois.godaddy.com
Updated Date: 2018-04-11T18:08:16Z
Creation Date: 2018-04-06T18:08:15Z
Registry Expiry Date: 2019-04-06T18:08:15Z
Registrar: GoDaddy.com, Inc.
Registrar IANA ID: 146
Registrar Abuse Contact Email:
Registrar Abuse Contact Phone: +1.4806242505
Domain Status: clientRenewProhibited https://icann.org/epp#clientRenewProhibited
Domain Status: clientDeleteProhibited https://icann.org/epp#clientDeleteProhibited
Domain Status: clientTransferProhibited https://icann.org/epp#clientTransferProhibited
Domain Status: clientUpdateProhibited https://icann.org/epp#clientUpdateProhibited
Registry Registrant ID: C80ADD12D99B044D0A469CE6E2ED95EA6-NSR
Registrant Name: Kristopher Kristopher
Registrant Organization: Patent & Trademark Office
Registrant Street: 387 Park Avenue South,
Registrant Street: 5th Floor,
Registrant Street:
Registrant City: New York
Registrant State/Province: New York
Registrant Postal Code: 10016
Registrant Country: us
Registrant Phone: +1.8888298316
Registrant Phone Ext:
Registrant Fax:
Registrant Fax Ext:
Registrant Email:
Registrant Application Purpose: P1
Registrant Nexus Category: C12
Registry Admin ID: C7C8B0C738EC74A77BD43F96F95D8434C-NSR
Admin Name: Kristopher Kristopher
Admin Organization: Patent & Trademark Office
Admin Street: 387 Park Avenue South,
Admin Street: 5th Floor,
Admin Street:
Admin City: New York
Admin State/Province: New York
Admin Postal Code: 10016
Admin Country: us
Admin Phone: +1.8888298316
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Admin Email:
Admin Application Purpose: P1
Document WHOIS,
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03/25/19 Page 98 of 174
Admin Nexus Category: C12
Registry Tech ID: CAB6648B971CF44519D0EB32F2F623E96-NSR
Tech Name: Kristopher Kristopher
Tech Organization: Patent & Trademark Office
Tech Street: 387 Park Avenue South,
Tech Street: 5th Floor,
Tech Street:
Tech City: New York
Tech State/Province: New York
Tech Postal Code: 10016
Tech Country: us
Tech Phone: +1.8888298316
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
Tech Email:
Tech Application Purpose: P1
Tech Nexus Category: C12
Name Server: ns55.domaincontrol.com
Name Server: ns56.domaincontrol.com
DNSSEC: unsigned
URL of the ICANN Whois Inaccuracy Complaint Form: https://www.icann.org/wicf/
For more information on Whois status codes, please visit https://icann.org/epp
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EXHIBIT 24
2/1/2019 Case 5:19-cv-01538 Patent & Trademark
Document 1-1OfficeFiled
| Better03/25/19
Business Bureau®
PageProfile
101 of 174
Better Business Bureau® & Trademark Office

Home > New Jersey > Jersey City > Patent
101 Hudson St Fl 21
Patent & Trademark Office Jersey City, NJ 07302-
Trademark Consultant 3929
http://www.patenttrade
markoffice.org/
(212) 796-6899
Accredited BBB Rating Customer Customer

Reviews Complaints
2 complaints
This business closed in last 3
is not BBB THIS years
Accredited F BUSINESS 2 complaints
HAS 0 closed in last 12
Length of time
months
business REVIEWS
Business Details
BBB File Opened: 2/1/2018
Business Categories
Trademark Consultant
Customer Complaints
2 Customer Complaints
Customer Reviews
0 Customer Reviews
https://www.bbb.org/us/nj/jersey-city/profile/trademark-consultant/patent-trademark-office-0221-90184149 1/2
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Document 1-1OfficeFiled
| Better03/25/19
Business Bureau®
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Business Categories
Trademark Consultant
Local BBB
BBB Serving New Jersey
More Info on Local BBB
BBB Business Profiles may not be reproduced for sales or promotional purposes.
BBB Business Profiles are provided solely to assist you in exercising your own best judgment. Information in this BBB Business Profile is
believed reliable, but not guaranteed as to accuracy.
When considering complaint information, please take into account the company's size and volume of transactions, and understand that
the nature of complaints and a firm's responses to them are often more important than the number of complaints.
BBB Business Profiles generally cover a three-year reporting period. BBB Business Profiles are subject to change at any time. If you
choose to do business with this business, please let the business know that you contacted BBB for a BBB Business Profile.
As a matter of policy, BBB does not endorse any product, service or business.
© 2019, Council of Better Business Bureaus, Inc., separately incorporated Better Business Bureau
organizations in the US, Canada and Mexico, and BBB Institute for Marketplace Trust. All Rights
Reserved.
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Case 5:19-cv-01538 Trademark Office
1-1| Complaints
Filed |03/25/19
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Better Business Bureau® & Trademark Office > Complaints

Home > New Jersey > Jersey City > Patent
101 Hudson St Fl 21
Jersey City, NJ 07302-
Complaints 3929
Patent & Trademark Office http://www.patenttrade

markoffice.org/
(212) 796-6899
Complaint Type: Advertising/Sales Issues Status: Unanswered

12/06/2018
Complaint Details Unavailable
Complaint Type: Problems with Product/Service Status: Unanswered

02/02/2018
I received a statement to renew my patent through Patent and Trademark office. I sent the
check and then realized this company is a scam and is not needed to renew. I contacted
them via phone and requested a refund. The gentleman I spoke with stated his name was
"Bob E****". I received an e-mail from Jane W*** / Client Manager stating that a refund
would be sent by 1/17/18. I have not received any refund and have sent subsequent e-mails
and called and have gotten no reply. THe amount paid was $1690. Thank you, ****** ******
BBB Business Profiles may not be reproduced for sales or promotional purposes.
BBB Business Profiles are provided solely to assist you in exercising your own best judgment. Information in this BBB Business Profile is
believed reliable, but not guaranteed as to accuracy.
When considering complaint information, please take into account the company's size and volume of transactions, and understand that
the nature of complaints and a firm's responses to them are often more important than the number of complaints.
BBB Business Profiles generally cover a three-year reporting period. BBB Business Profiles are subject to change at any time. If you
choose to do business with this business, please let the business know that you contacted BBB for a BBB Business Profile.
As a matter of policy, BBB does not endorse any product, service or business.
https://www.bbb.org/us/nj/jersey-city/profile/trademark-consultant/patent-trademark-office-0221-90184149/complaints 1/2
2/1/2019 Patent &Document
Case 5:19-cv-01538 Trademark Office
1-1| Complaints
Filed |03/25/19
Better BusinessPage
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© 2019, Council of Better Business Bureaus, Inc., separately incorporated Better Business Bureau
organizations in the US, Canada and Mexico, and BBB Institute for Marketplace Trust. All Rights
Reserved.
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1-646-616-7529
info@patentandtrademarkbureau.us
Patent and Trademark Bureau

Trademarks
Registration Once you have obtained a U.S. federal trademark registration, you
must take certain steps to maintain the registration. Failure to
renew your Trademark on time might result the cancellation of the
Renewal
Trademark. It is your responsibility to meet the renewal dates.
Patents
Contacts
Trademarks Patent and Trademark Bureau
http://patentandtrademarkbureau.us/ 1/7
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1-646-616-7529
Registration Once you have obtained a U.S. federal trademark registration, you
must take certain steps to maintain the registration. Failure to

renew your Trademark on time might result the cancellation of the
Renewal
Trademark. It is your responsibility to meet the renewal dates.
Patents
Contacts
For many businesses, the process for registering and renewing patents and trademarks can be di cult, complicated,
and fraught with chances for error.
Every year, businesses and individuals lose millions of dollars in valuable intellectual property because of missed
deadlines and procedural mistakes.
The Patent and Trademark Bureau provides the expertise that modern businesses need to navigate the Intellectual
Property's registration and renewal process. You need experienced, professional assistance to protect your assets.
Don't let your hard-earned property go to waste!
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1-646-616-7529
Trademark information
A trademark or trade mark is a distinctive sign or indicator used by an individual, business

organization, or other legal entity to identify that the products or services for consumers with
which the trademark appears originate from a unique source, and to distinguish its products or
services from those of other entities.
A trademark is designated by the following symbols:
TM - for an unregistered trade mark, that is, a mark used to promote or brand goods
SM - for an unregistered service mark, that is, a mark used to promote or brand services
® - for a registered trademark
A trademark is a type of intellectual property, and typically a name, word, phrase, logo, symbol,
design, image, or a combination of these elements. There is also a range of non-conventional
trademarks comprising marks which do not fall into these standard categories.
The owner of a registered trademark may commence legal proceedings for trademark
infringement to prevent unauthorized use of that trademark. The owner of a common law
trademark may also le suit, but an unregistered mark may be protected only within the
geographical area within which it has been used or in geographical areas into which it may be
reasonably expected to expand. The term trademark is also used informally to refer to any
distinguishing attribute by which an individual is readily identi ed, such as the well known
characteristics of celebrities.
When a trademark is used in relation to services rather than products, it may sometimes be
called a service mark. If you want to establish a brand for your product or service, you should
consider creating a distinctive trade mark. A trade mark protects the identity of your goods and
services.
Once you register a trademark, you have the legal right to use, license or sell it within the USA
for the goods and services for which it is registered. You also have the right to prevent others
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from using it. If you do not register, another party could register your brand as a trade mark and
1-646-616-7529
you could be forced to defend your rights – you may even need to rebrand.
Registration process
In the United States the registration process entails several steps prior to a trademark
receiving its Certi cate of Registration.
First, an Applicant, the person or persons applying for the registration, les an application to
register the respective trademark. The application is then placed in line in the order it was
received to be examined by an examining attorney.
Second, following a period of anywhere from three to six months the application is reviewed by
an examining attorney to make sure it complies with all requirements in order to be entitled to
registration. This review includes procedural matters such as making sure the Applicant's
goods or services are identi ed properly. It also includes more substantive matters such as
making sure the Applicant's mark is not merely descriptive or likely to cause confusion with a
pre-existing applied-for or registered mark. If the application runs afoul of any requirement, the
examining attorney will issue an o ce action requiring the Applicant to address certain issues
or refusals prior to registration of the mark.
Third, and after the examination of the mark has concluded with no issues to be addressed or
an Applicant has responded adequately to an examining attorney's concerns, the application
will be published for opposition. During this 30-day period third-parties who may be affected by
the registration of the trademark may step forward to le an Opposition Proceeding to stop the
registration of the mark. If an Opposition proceeding is led it institutes a case before the
Trademark Trial and Appeal Board to determine both the validity of the grounds for the
opposition as well as the ability of the Applicant to register the mark at issue. Fourth, provided
that no third-party opposes the registration of the mark during the opposition period or the
opposition is ultimately decided in the Applicant's favor the mark will be registered in due
course.
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1-646-616-7529
Renewal process info@patentandtrademarkbureau.us
The owner of the registration must renew his trademark during the following time periods:
First Filling Deadline: File between the 5th and 6th years after the registration date. If the
renewal is accepted, the registration will continue in force for the remainder of the ten-year
period from the registration date.
Subsequent Filling Deadline: File between the 9th and 10th years after the registration date, and
between every 9th and 10th year after the registration date thereafter.
The renewal and update process looks as follows:
1. You receive the Reminder from Patent and Trademark Bureau
2. You sign and mail it back to Patent and Trademark Bureau in the provided Business Reply
envelope
3. We send you the invoice after we receive the signed Reminder from you
4. Upon receipt of all the fees the trademark is renewed
Failure to renew your trademark on time might result the cancellation of the trademark and a
new application to pursue registration of the mark again must be led.
Patent and Trademark Bureau, LLC is a private, non-governmental company and isn't
connected to any of the governmental organizations.
Patents
A patent is a limited duration property right relating to an invention.

The de nition of patent usually refers to an exclusive right granted to anyone who invents any
new, useful, and non-obvious process, machine, article of manufacture, or composition of
matter, or any new and useful improvement thereof, and claims that right in a formal patent
application. The additional quali cation utility patent is used in the United States to distinguish
it from other types of patents (e.g. design patents). Examples of particular species of patents
for inventions include biological patents, business method patents, chemical patents and
software patents.
There are different options for protecting your invention with a patent. Patents are territorial. A
national patent is enforceable only in your country and you will need to apply for foreign
patents, should you require protection in other countries. The call for foreign patents depends
on what type of invention you have made, potential export markets and whether you intend to
retain or sell the patent.
If the invention is intended mainly for the national market, a national patent may su ce. Be
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aware then, that anyone may manufacture, sell or use your invention abroad.
1-646-616-7529
One alternative is to invest in an International or European application directly bypassing a
National application route. This may be advantageous if, for example, you are certain that the
main market of your invention is not domestic. An international application can result in
protection in about 140 countries. Using a European application you can obtain protection in
just over thirty countries in Europe. Another option is to le separate patent applications
directly to the individual countries where you want a patent. This route is good if you know that
your market is to be found in certain countries. Nevertheless, it is advisable to compare the
total cost with that of an international application.
Send request and get free consultation
E-mail
Phone
Name
Trademark registration number
Your comments
Send
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1-646-616-7529
Patent and Trademark Bureau
Address:
230 Park Avenue, 3rd Floor West
Helmsley Building
New York, NY 10169
United States of America
Phone: 1-646-616-7529
Fax: 1-646-616-7529
E-mail: info@patentandtrademarkbureau.us
Assistance is available from Monday to Friday, 9AM till

4PM ET.
Report
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WILLIAM E. KOVACIC
General counsel
JOHN D. JACOBS (Cal. Bar No. 134154)
KENNETH H. ABBE (Cal. Bar No. 172416)
BARBARA Y.K. CHUN (Cal Bar No. 186907)
10877 Wilshire Blvd., Ste. 700
Los Angeles, CA 90024
(310) :824-4343; Fax (310) 824-4380
L"r
~ti+n&s fdr Plaintiff

FEPERAL' TRADE COMMISSION
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Plaintiff,
INNOVATIVE SYSTEMS TECHNOLOGY,

INC. dba Briggs & Baker;
STIPULATED FINAL JUDGMENT AND
DEBT RESOLUTION SPECIALISTS, ORDER FOR PERMANENT
INC . ; INJUNCTION AGAINST DEFENDANT
JACK BRIGGS, AKA JOHN BRIGGS
TODD A. BAKER; and
JACK BRIGGS, aka JOHN BRIGGS,
Defendants.
Plaintiff, the Federal Trade Commission ('Commission" or

"FTC") has commenced this action by concurrently filing its
'omplaint and this Stipulated Final Judgment and Order for
?ermanent Injunction Against Defendant Jack Briggs, aka John
3riggs. The Complaint seeks a permanent injunction and other
relief pursuant to Section 13(b) of the Federal Trade Commission
ict ("FTC Act") , 15 U.S.C. § 53 (b). The Complaint alleges that
lefendants Innovative Systems Technology, Inc. dba Briggs &
Baker, Debt Resolution Services, Inc., Todd A. Baker, and Jack

Briggs, aka John Briggs, have engaged in unfair and deceptive
acts or practices in violation of Section 5 of the FTC Act, in
connection with the advertising, marketing, promoting, offering
for sale, or sale of their debt negotiation services.
Defendant Briggs (hereafter "Defendant") has waived service
of the Summons and Complaint. Plaintiff and Defendant Briggs,
represented by the attorneys whose names appear hereafter, have
agreed to the entry of this Order and have requested that the
Court enter the same to resolve all matters in dispute in this
sction without trial or adjudication of any issue of law or fact
herein. The parties having requested the Court to enter this
3rder, the Court hereby finds and orders as follows:
FINDINGS
1. This Court has jurisdiction of the subject matter of
:his case and of the parties consenting hereto;
2. Venue is proper as to all parties in the Central
Iistrict of California;
3. .The activities of Defendant are in or affecting
:ommercer as defined in Section 4 of the FTC Act, 15 U.S.C. § 44;

4. The Complaint states a claim upon which relief may be
!ranted against Defendant under Sections 5 and 13(b) of the FTC
at, 15 U.S.C. §§ 45 (a,)and 53 (b).
5. Defendant has waived all rights that may arise under the
lqual Access to Justice Act, 28 U.S.C. § 2412, amended bv Pub. L.
04-121, 110 Stat. 847, 863-64 (1996);
6. Defendant has waived all rights to seek appellate review

or otherwise challenge or contest the validity of this Order, and
has further waived and released any claim he may have against the
Commission, its employees, and agents;
7. Defendant enters into this Order freely, without
admitting liability for any allegation or charge made in the
Commission's Complaint, without coercion, and acknowledges that
he understands the provisions of this Order and is prepared to
abide by them.
8. Entry of this Order is in the public interest.
ORDER
Definitions
"Defendant" means Defendant Jack Briggs, also known as John
Briggs ("Briggs"), by whatever name he might be known.
"Assisting OthersM means knowingly providing any of the
following goods or services to another entity: (A)
performing customer service functions, including, but not
limited to, receiving or responding to consumer complaints;
(B) formulating or providing, or arranging for the
formulation or provision of, any marketing material; (C)
providing names of, or assisting in the generation of,
potential customers; (D) hiring, recruiting or training
personnel; ( E ) advising or consulting others on the
commencement or management of a business; or (F) performing
marketing services of any kind.
I. PERMANENT BAN
IT IS THEREFORE ORDERED that Defendant, whether acting
directly. or through any corporation, limited liability company,
subsidiary, division, or other device, is hereby permanently
restrained and enjoined from engaging in, or receiving any
remuneration of any kind whatsoever from, or holding a majority
ownership interest, .share, or stock in, or serving as an officer,
director, trustee, or general manager of, any business entity
engaged in whole or in part in, the advertising, marketing,
promoting, offering for sale, or sale.of any debt negotiation,
debt reduction, or debt consolidation service.
11. PROHIBITED MISREPRESENTATIONS
IT IS FURTHER ORDERED that in connection with the
advertising, marketing, promoting, offering for sale, or sale of
any good or service, Defendant, and his agents, servants,
empl.oyees, and all other persons or entities in active concert or
participation with him who receive actual notice of this Order by
personal service or otherwise, whether acting directly or through
any corporation, limited liability company, subsidiary, division,
or other device, are hereby permanently restrained and enjoined
from misrepresenting, or assisting others in misrepresenting,
expressly or by implication, any fact material to a consumer's
decision to buy or accept the good or service.
111. SUSPENDED JUDGMENT
IT IS FURTHER ORDERED that:
A. Judgment in the amount of $8 million is hereby entered
in favor of.the Commission against Defendant, for'equitable

monetary relief; provided, however, that this judgment shall be
suspended subject to the conditions set forth in Paragraph IV of
this Order.
.B. All funds paid pursuant to- this Order shall be deposited
into a 'fund administered by the Commission or its agent
used for equitable relief, including but not limited to consumer
redress and any attendant expenses for the administxation of any
redress funds. In the event that direct redress to consumers is
wholly or partially impracticable or funds remain after redress
is completed, the Commission may apply any remaining funds for
such other equitable relief (including consumer information
remedies) as it determines to be reasonably related to the
Defendant's practices alleged in the Complaint. Any funds not
used for such equitable relief shall be deposited to the Treasury
as disgorgement. Defendant shall have no right to challenge the
Commission's choice of remedies under this Paragraph.
IV. TERMINATION OF SUSPENSION
IT IS FURTHER ORDERED that the Commission's agreement to,
2nd the Court's approval of, this Order is expressly premised
lpon the truthfulness, accuracy, and completeness of Defendant's
financial condition, as represented in his financial statement
iated April 2, 2003, including attachments, and in any other
iocuments submitted by Defendant, upon which the Commission
relied in negotiating and agreeing to the terms of this Order.
Cf, upon motion by the Commission to the Court, the Court finds
that Defendant, in his above-referenced financial statement and

information, failed to disclose any asset with'a value in excess
of $1,000, materially misrepresented the value of any asset, or
made any other material misrepresentation or omission, the
suspension of the monetary judgment will be terminated and the
entire judgment amount of $8 million, representing the
approximate amount of consumer injury, will become immediately
due and payable, less any payments already made. For purposes of
this Paragraph, and any subsequent proceedings to enforce
payment, including but not limited to a non-dischargeability
complaint filed in a bankruptcy proceeding, Defendant waives any
right to contest any of the allegations set forth in the
Complaint filed in this matter or the $8 million judgment
referenced above.
V. CUSTOMER LISTS
IT IS FURTHER ORDERED that Defendant, as well as his
~Eficers,agents, servants, employees, and attorneys, and all
persons entities in active concert participation with
him who receive actual notice of this order by personal service
otherwise, whether acting directly or through corporation,
mbsidiary, division, or other entity, are permanently restrained
2nd enjoined from selling, renting, leasing, transferring, or
~therwisedisclosing the name, address, telephone number, social
security number, credit card number, bank account number, e-mail
$ddress, or other identifying information of any person who paid
iny money to any Defendant, who was solicited to pay money to any
Defendant, or whose identifying information was obtained for the

purpose of soliciting them to pay money to any Defendant, at any
time prior to the date this Order is entered, in connection with
the advertising, marketing, promoting, offering for sa.le or sale
of any debt negotiation, debt reduction, or debt consolidation
service. Provided, however, that any party subject to this
provision may disclose such identifying information to a law
enforcement agency or as required by any law, regulation, or
court order.
VI. DISTRIBUTION OF ORDER BY DEFENDANT
IT IS FURTHER ORDERED that, for a period of five (5) years
from the date of entry of this Order,
A. Defendant shall deliver a copy of this Order to the
principals, officers, directors, managers, and employees under
the Defendant's control for any business that (a) employs or
contxacts for personal services from Defendant and (b) has
responsibilities with respect to the subject matter of this
Order. Defendant shall secure from each such person a signed and
dated statement acknowledging receipt of the Order within thirty
(30) days after the date of service of the Order or the
commencement of the employment relationship.
VII. MONITORING COMPLIANCE OF SALES PERSONNEL
IT IS FURTHER ORDERED that Defendant, in connection with any
business where :
Defendant is the majority owner of the business or
directly or indirectly manages or controls the
business',and where
2. the business is engaged in radio advertising or a
website to market or sell its products or services, or
assists others in said activities
is hereby permanently restrained and enjoined from:
A. Failing to take reasonable steps sufficient to monitor
and ensure that all employees and independent contractors engaged
in sales or other customer service functions comply with
Paragraphs 1-11 of this Order. Such steps shall include adequate
monitoring of sales presentations or other calls with customers,
and shall also include, at a minimum, the following: (1)
listening to the oral representations made by persons engaged in
sales or other customer service functions; (2) establishing a
9rocedure for receiving and responding to consumer complaints;
3nd ~ ( 3 )ascertaining the number and nature of consumer complaints
regarding transactions in which each employee or independent
zontractor is involved; provided that this Paragraph does not
2uthorize or require Defendant to take any steps that violate any
federal, state, or local laws;
B. Failing to investigate promptly and fully any consumer
:omplaint to which this Paragraph applies; and
C. Failing to take corrective action with respect to any
sales person whom Defendant determines is not complying with this
Irder, which may include training, disciplining, and/or
:erminating such sales person.
I / /
VIII. RECORD KEEPING PROVISIONS

IT IS FURTHER ORDERED that, for a period of eight ( 8 ) years
from the date this Order is entered, where Defendant is the
majority owner or directly or indirectly controls the business,
Defendant and his agents, employees, officers, corporations,
successors, and assigns, and those persons in active concert or
participation with them who receive actual notice of this Order
by personal service or otherwise, are hereby restrained and
enjoined from failing to create and retain the following records:
A. Accounting records that reflect the cost of goods or
services sold, revenues generated, and the disbursement of such
revenues;
B. Personnel records accurately reflecting: the name,
address, and telephone number of each person employed in any
capacity by such business, including as an independent
contractor; that person's job title or position; the date upon
uhich the person commenced work; and the date and reason for the
?ersonlstermination, if applicable;
C. Customer files containing the names, addresses, phone
numbers, dollar amounts paid, quantity of items or services
?urchased, and description of items or services purchased, to the
zxtent such information is obtained in the ordinary course of
xsiness ;
D. Complaint and refund requests (whether received
iirectly, indirectly or through any third party) and any
responses to those complaints or requests; and
Copies all sales scripts, training materials,

advertisements, or other marketing materials.
IX. CONPLIANCE REPORTING BY DEFENDANT
FURTHER ORDERED that, order that compliance with
the provisions this Order monitored:
A. For a period of five (5) years from the date of entry
of this Order,
1. Defendant shall notify the Commission of the following:
(a) Any changes in Defendant's residence, mailing
addresses, and telephone numbers, within ten (10) days
of the date of such change;
(b) Any changes in Defendant's employment status
(including self-employment) within ten (10) days of the
date of such change. Such notice shall include the
name and address of each business that Defendant is
affiliated with, employed by, or performs services for;
a statement of the nature of the business; and a
statement of Defendant's duties and responsibilities in
connection with the business;
(c) Any changes in Defendant's name or use of any
aliases or fictitious names; and
2. Defendant shall notify the Commission of any changes in
corporate structure that may affect compliance obligations
arising under this Order, including but not limited to a
dissolution, assignment, sale, merger, or other action that
would result in the emergence of a successor corporation;
the creation or dissolution of a subsidiary, parent, or

affiliate that engages in any acts or practices subject to
this Order; the filing of a bankruptcy petition; or a change
in the corporate name or address, at least thirty (30) days
prior to such change, provided that, with respect to any
proposed change in the corporation about which the Defendant
learns less than thirty (30) days prior to the date such
action is to take place, Defendant shall notify the
Commission as soon as is practicable after obtaining such
knowledge. ,
B. One hundred eighty (180) days after the date of entry of

this Order, Defendant shall provide a written report to the FTC,
sworn to under penalty of perjury, setting forth in detail the
nanner and form in which he has complied and is complying with
this Order. This report shall include, but not be limited to:
1. Any changes required to be reported pursuant to
subparagraph above ;
, 2. A copy of each acknowledgment of receipt of this Order
obtained by Defendant pursuant to Paragraph VI;
C., For the purposes of this Order, Defendant shall, unless
~therwisedirected by the Commissionls authorized
representatives, mail all written notifications to the Commission
Assistant Regional Director

Western Region - Los Angeles
10877 Wilshire Blvd., Suite 700
Los Angeles, California 90024
Re: FTC v. Innovative Svstems Technoloqv, et al.
D. For purposes of the compliance reporting required by

this Paragraph, the Commission is authorized to communicate
directly with Defendant.
X. COMPLIANCE MONITORING
IT IS FURTHER ORDERED that, for the purpose of monitoring
and investigating compliance with any provision of this Order,
A. Within ten (10) days of receipt of written notice from a
representative of the Commission, Defendant shall submit
additional written reports, sworn to under penalty of perjury;
produce documents for inspection and copying; appear for
deposition; and/or provide entry during normal business hours to
any business location in such Defendant's possession or direct or
indirect control to inspect the business operation;
B. In addition, the Commission is authorized to monitor
zompliance with this Order by all other lawful means, including
out not limited to the following:
obtaining discovery from any person, without further
leave of court, using the procedures proscribed by Fed.
R. Civ. P. 30, 31, 33, 34, 36, and 45;
2. posing as consumers and suppliers to Defendant or his
employees, or any other entity managed controlled
whole or in part by Defendant, without the necessity of
identification prior notice;
Jrovided that nothing in this Order shall limit the Commissionls
.awful use of compulsory process, pursuant to Sections 9 and 20
~f the FTC Act, 15 U.S.C. §§ 49, 57b-1, to obtain any documentary
material, tangible things, testimony, or information relevant to

unfair or deceptive acts or practices in or affecting commerce
(within the meaning of 15 U.S.C. § 45 (a)(1)).
C. Defendant shall permit representatives of the
Commission to interview any employer, consultant, independent
contractor, representative, agent, or employee who has agreed
such an interview, relating in any way to any conduct subject
this Order. The person interviewed may have counsel present.
XI. ACKNOWLEDGMENT OF RECEIPT OF ORDER BY DEFENDANT
IT IS FURTHER ORDERED that Defendant, within five (5)
msiness days of receipt of this Order as entered by the Court,
nust submit to the Commission a truthful sworn statement
3cknowledging receipt of this Order.
XI1 . COSTS AND ATTORNEYS .FEES
IT IS FURTHER ORDERED that each party to this Order shall
)ear its own costs and attorney's fees incurred in connection
~ i t hthis action.
XIII. RETENTION OF JURISDICTION
IT IS FURTHER ORDERED that this Court shall retain
urisdiction of this matter for purposes of construction,
lodification and enforcement of this Order.
XIV. INDEPENDENCE OF OBLIGATIONS
IT IS FURTHER ORDERED that the expiration of any
equirements imposed by this Order shall not affect.any other
bligation under this Order.
//
XV. WAIVER O F CLAIMS
I T I S FURTHER ORDERED that Defendant waives all claims under
the Equal Access to Justice Act, 28 U.S.C. § 2412, as amended by

Pub. L. 104-121, 110 Stat. 847, 863-64 (1996), and all rights to
seek appellate review or otherwise challenge or contest the
validity of this Order, and further waives and releases any claim
he might have against the FTC or its employees, agents or
representatives.
S O STIPULATED:
individually, I:n P ~ Per

Q
DATED : I
BARBARA Y.K. CHUN

Attorneys for Plaintiff FTC
I T I S S O ORDERED:
Dated:
~-S'JO y GAKV ALLEN FEESS
UNITED STATES DISTRICT JUDGE

CERTIFICATE OF SERVICE
I, Kenneth H. Abbe, certify as follows:
I am over the age of 18 and am employed by the Federal Trade
Commission. My business address is 10877 Wilshire Boulevard,
Suite 700, Los Angeles, California 90024. On February 4, 2004, I
caused the attached document titled "STIPULATED FINAL JUDGMENT
AND ORDER FOR PERMANENT INJUNCTION AGAINST DEFENDANT JACK BRIGGS,
AKA JOHN BRIGGS" to be served by pre-paid, first class U.S. mail

to the following:
Paracorp Incorporated AGENT FOR SERVICEOF PROCESS
640 Bercut Dr. FOR DEFENDANTINNOVATIVE SYSTEMS
Suite A TECHNOLOGY, INC.
Sacramento, CA 95814
Gary S. Brown, Esq. AGENT FOR SERVICEOF PROCESS

Law Offices of Gary Brown FOR DEFENDANTDEBTRESOLUTION
1 S. Fair Oaks Ave. #301 SPECIALISTS, INC.
Pasadena, CA 91105
Todd A. Baker
35471 Larchfork Rd.
Acton, CA 93510
John Briqqs
25763 Barnett Lane
Stevenson.Ranch,CA 91381
I declare under penalty of perjury that the foregoing is

:rue and correct.
Iated: February 4, 2004

/kedneth H. Abbe
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3/4/2019 Case 5:19-cv-01538 LegalForce
Document RAPC1-1
Worldwide Mail 03/25/19
Filed - Fwd: TM Assist payment
Page 148 of 174
Fwd: TM Assist payment

1 message
Sun, Feb 10, 2019 at 9:09 AM
From: TM Assist <tmassist@legalforcelaw.com>

To: tmassist@legalforcelaw.com, @hallie
Cc:
Bcc:
On: 2019-02-08T14:12:07.000Z
Dear,
This is to inform you that there is still an outstanding payment of $1,343.

We would appriciate it if this could be settled no later than the 11th.
I have attached the current invoice link and the password for the document is: 92052.
Best Regards,
TM Assist
O 372-147-0460 / 372-147-1813
https://mail.google.com/mail/u/0?ik=bcb515018c&view=pt&search=all&permthid=thread-f%3A1625098814660722882%7Cmsg-f%3A16250988146607… 1/3
Document RAPC1-1
Page 149 of 174
M: 372-147-3299 / 372-147-4303
E tmassist@legalforcelaw.com
LegalForce RAPC Worldwide

Professional Law Corporation
446 E. Southern Avenue
Tempe, Arizona United States
www.legalforcelaw.com
United States | Europe | South Africa | China | India
Document RAPC1-1
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About LegalForce RAPC Worldwide - LegalForce RAPC Worldwide is a leading general practice law firm specializing in
serving the diverse needs of individuals, businesses, and institutions worldwide The firm created
the Trademarkia.com website.
This electronic transmission contains information which is confidential and/or privileged. The information is intended for
use only by the individual or entity named above. If you are not the intended recipient (or the employee or agent
respons ble for delivering this information to the intended recipient), you are hereby notified that any use, dissemination,
distribution, or copying of this communication is prohibited If you have received this information in error, please notify me
by electronic mail and delete all copies of the transmission. Thank you.
03/25/19 Page 151 of 174
EXHIBIT
36
EXHIBIT
37
3/25/2019 DPMA | 1-1
Case 5:19-cv-01538 Document Misleading Requests
Filed for Payment
03/25/19 Page 163 of 174
Warning against Misleading Requests for Payment

The German Patent and Trade Mark Ofce (DPMA) warns against – partially misleading – offers, requests for
payment and invoices from private companies. These companies offer services against payment including the
publication or registration of IP rights in commercial registers. They also offer the renewal of IP rights at the
DPMA and charge a fee for this service in addition to the ofcial fees.
We explicitly point out that these companies are not associated with the DPMA.
What are misleading requests for payment?

Often, such letters cannot be identied as offers at rst sight – in many cases, this becomes only obvious by
carefully reading the small print or the terms and conditions that are sometimes printed on the back. You should
therefore always carefully read communications containing requests for payment in connection with IP rights.
Indications that it is not an ofcial letter:
Bank details of a company abroad, e.g. Poland (PL), Cyprus (CY), Tunisia (TN) or Bulgaria (BG)
pre-lled transfer slip
address other than that of an authority or ofce of the DPMA
What are the actual fees charged?

he ofcial fees are due and must be paid to the DPMA when ling an application or submitting a request for the
renewal or maintenance of an IP right or for other individual procedural steps. No additional fees are charged for
the publication of IP rights in the ofcial registers.
The DPMA does not send out any invoices or requests for payment.
All information on ofcial fees is available in the leaet Information Concerning Costs, Fees and Expenses of
the German Patent and Trade Mark Ofce and of the Federal Patent Court (form A 9510.1). There you will also
nd the terms of payment and the bank details of the DPMA.
On the fee pages we have compiled information on ofcial fees of the DPMA.
Which companies are known to the DPMA?

Letters from the following companies have recently been brought to our attention:
Copyright-Register des geistigen Eigentums

German Domain & Trademark Ofce (Internetadresse: www.gdto.de/www.gd-to.com)
Deutsche Domain-Namen und Marken (DEDM) (Internetadresse: www.de-dm.de)
EUTD – European Trademarks & Domains (Internetadresse: www.eutd.org) *NEU
https://www.dpma.de/english/services/fees/warning_against_misleading_requests/index.html 1/2
3/25/2019 DPMA | 1-1
Case 5:19-cv-01538 Document Misleading Requests
Filed for Payment
03/25/19 Page 164 of 174
IOIP – International Organisation Intellectual Property Registration International Mark
IPTR - International Patent and Trademark Register (Internetadresse: www.iptr.biz)
IPOS - Intellectual Property Organisation Service (Internetadresse: www.ip-os.org)
PMR-Service GmbH - Patent- und Markenregister (Internetadresse: www.pmr-serv.com)
Register der deutschen Marken (Internetadresse: www.schutzmarke.org)
Register des gewerblichen Eigentums (Internetadresse: www.deutsche-erndungen.org)
TMP Register - Trademark Publication (Internetadresse: www.tmp-register.com/) *NEU
WPAT- World Patents and Trademarks (Internetadresse: www.wpat-service.com)
List of the companies which have been brought to the attention of the DPMA
Have you received such a letter?

If you receive requests for payment, offers or invoices relating to your IP right pending before the DPMA from
companies where you have doubts about the legitimacy of the request for payment, you can contact our
Customer Care and Services any time. If you have not found the company in question in our list, please send an e-
mail to info@dpma.de and provide an example in the attachment.
Holders of international registrations of marks who received a communication can contact WIPO directly to nd
out if the communication received is indeed an ofcial communication by WIPO:
For this purpose, please call the International Bureau (phone: +41 22 338-9111) or send an e-mail to
intreg.mail@wipo.int
In addition, you may contact the Legal Division of the Madrid Union with respect to any query concerning
this and any other legal issue: madridlegal@wipo.int
Not only the DPMA issues warnings

Other IP ofces have also issued warnings on their websites concerning – partially misleading – offers, requests
for payment and invoices from companies unrelated to them:
World Intellectual Property Organization ( WIPO)

European Union Intellectual Property Ofce ( EUIPO)
European Patent Ofce ( EPO) and
numerous national IP ofces such as the
Swiss Federal Institute of Intellectual Property ( IPI) and the
United States Patent and Trademark Ofce ( USPTO)
The German Protective Association against Economic Crime ( Deutscher Schutzverband gegen
Wirtschaftskriminalität – DSW) as well as numerous chambers of commerce and industry provide comprehensive
information about the practice described on this page, also known as scam.
Last updated: 25/03/19
You are here: Welcome / Services / Fees / Misleading Requests for Payment
https://www.dpma.de/english/services/fees/warning_against_misleading_requests/index.html 2/2
3/25/2019 Case 5:19-cv-01538 Trademark
DocumentScams:1-1
What toFiled
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Trademark Scams: What to Expect After Filing

Your Application
Crystal T. Broughan Follow

11 2 1
Intellectual Property Attorney - S…
I recently went through the process of filing trademark applications for my law firm’s trademarks. Now I am receiving all kinds of
scam mail from companies claiming to publish international catalogues of trademarks and offering global trademark protection.
I realized that my clients receive these scam mailings every time a new trademark application is filed with the United States
Patent and Trademark Office.
So below is a list of scam mail I received. Click on the images to download a full PDF of the email.
WTMR Catalogue 2018 (World Trademark Register) from Washington, D.C.
These people claim there is a due date to pay a “registration fee of $980.” There is a warning buried in the verbiage stating, “THIS
IS NOT A BILL. THIS IS A SOLICITATION. YOU ARE UNDER NO OBLIGATION TO PAY THE AMOUNT STATED ABOVE, UNLESS YOU
ACCEPT THIS OFFER.”
https://www.linkedin.com/pulse/trademark-scams-what-expect-after-filing-your-crystal-t-broughan 1/6
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TM-Edition International Catalogue of Trademarks - 2018 from Hungary demands $2450 for registration costs, and they only
accept payment via a bank transfer. No checks accepted.
DocumentScams:1-1
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167 of 174
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GloTrade s.r.o. Global Trademarks Protection from New York. These people want $2890. This solicitation letter also states in very
small writing, “This offer is not an invoice but a solicitation without obligation to pay, unless our offer is accepted.”
DocumentScams:1-1
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Expect03/25/19
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168 of 174
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Trademark Edition International Catalogue of Trademarks 2018 from Hungary demands $2050. No checks accepted. Payment
only via bank transfer.
DocumentScams:1-1
What toFiled
Expect03/25/19
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169 of 174
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If you have received any mail from these entities, throw them away immediately. They do not provide any legitimate service that
will benefit your trademark registrations.
USPTO's Warning
The United States Patent and Trademark Office sends warnings with their Certificates of Registration that state:
"Beware of potentially misleading offers and notices
"All official correspondence about your registration will be from the "United States Patent and Trademark Office" in Alexandria,
VA, and, if by email, from the domain "@uspto.gov." Our email reminders will direct you to make the necessary filings and pay
the associated fees online through TEAS, and will not request any fees by mail.
"Private companies not associated with the USPTO often use trademark application and registration information from our
databases to mail or email trademark-related offers and notices. These offers and notices may include legal services, trademark
monitoring services, recording trademarks with U.S. Customs and Border Protection, and "registering" trademarks in a private
registry. Most companies require "fees" to be paid.
"These companies may have names similar to the USPTO. Their names may include the terms "United States," "U.S.," "Trademark,"
"Patent," "Registration," "Office," or "Agency." Some companies attempt to make their offers and notices look like official
government documents by using official government data publicly available from USPTO records."
Seek Guidance from an Experienced Trademark Lawyer
Scams are a good reason to have your trademarks applications filed and managed by an experienced trademark lawyer who can
screen out these types of fraudulent mailings for you.
Often, I receive phone calls and/or emails from clients who have received questionable mailings relating to their trademark
applications or registrations. I review the mailing and advise the client on the validity of the mailing. Usually the client claims they
thought it was a scam, but they wanted to make sure before the sent in payment.
I wonder how many trademark owners fall for these scams and send in a payment. Don’t get caught in the scam web. Be careful!
DocumentScams:1-1
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Expect03/25/19
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3/25/2019 How trademark
Case scams work: WTMR Document
5:19-cv-01538 changes name to WTRMFiled
1-1 | Erik M03/25/19
Pelton & Associates,
PagePLLCErik
171 ofM 174
Pelton & Associates, PLLC
iPelton
BL
BLOG
OG
Welcome to My Blog >
March 19, 2018

How trademark scams work: WTMR changes name to
WTRM
This scam offering (below) from WTRM, Inc. looked so familiar when a client
forwarded it to me last week. But when I searched online I couldn’t find any warnings
about WTRM.
The reason I couldn’t find any warnings was that just a few weeks ago they were
sending bogus trademark directory offers using the name WTMR, Inc. See images
below. The addresses are the same. The logos are the same. The offers are the same.
The costs are the same. Yet the name changed to help avoid unsuspecting recipients
from discovering this sham.
The new offer is so poorly done that in the fine print it still references WTMR, and so
does the logo and the top right corner.
It seems to me that this is clear evidence of an intent to mislead and defraud

consumers who own trademark filings with the USPTO. When will the USPTO,
Trademark Public Advisory Committee (TPAC), Fair Trade Commission (FTC),
Department of Justice (DoJ), and U.S. Postal Service (USPS) ramp up any investigations
and crack downs on these scams. Of course it is not easy to track the catch those
behind these offerings, but is enough being done? Not in my opinion.
WTRM, Inc. offer from last week:
https://www.erikpelton.com/how-trademark-scams-work-wtmr-changes-name-to-wtrm/ 1/4
1-1 | Erik M03/25/19
PagePLLCErik
172 ofM 174
WTMR, Inc. offer from just a few weeks ago, which I blogged about here:
1-1 | Erik M03/25/19
PagePLLCErik
173 ofM 174
Don’t be taken for this scam to the tune of $980.00 USD.
Beware of such scams. Read the fine print. Contact your attorney. Report scams to
the FTC and USPTO.
For more information, see:
How to avoid being taken by a trademark scam

WARNING: Non-USPTO Solicitations That May Resemble Official USPTO
Communications
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COMPLAINT Against Fraudulent & Misleading Trademark Mailer Entities Via USPS Impersonating The USPTO Against All Defendants

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3/25/2019 Complaint - Fraudulent

Case 5:19-cv-01538 Document 1 Filed Mailers - Google Docs

RAJ V. ABHYANKER, SBN 233284

LEGALFORCE RAPC WORLDWIDE, P.C.

Attorneys for Plaintiff,

UNITED STATES DISTRICT COURT

LEGALFORCE RAPC WORLDWIDE, Case No. 19-1538

1. LegalForce RAPC Worldwide, P.C. (“RAPC” or “Plaintiff”) alleges as follows

purported services they advertise to provide result in no value to trademark owners.

8. A printout of USPTO’s warning is attached as Exhibit 2 (including highlights of

Washington, D.C., California, and elsewhere in the United States.

principal place of business at 1321 Upland Drive, Houston, TX 77043.

protecting their trademark by either registering or publishing the registration of the

Washington, D.C. to a different address or addresses for WTMR.

service to consumers that is commensurate with the costs.

set forth herein.

set forth herein.

Respectfully submitted this 25th day of March 2019.

LegalForce RAPC Worldwide P.C.

By /s/ Raj V. Abhyanker

JURY TRIAL DEMAND

Respectfully submitted this 25th day of March 2019.

LegalForce RAPC Worldwide P.C.

By /s/ Raj V. Abhyanker

Fact Sheets Home

Unsolicited Offers for Trademark-Related Services in the United

How do I know which notices are legitimate?

Caution: misleading notices

Trademark Information Network News Video: Solicitation Alert

Trademark Information Network News Video: Solicitation Alert

TMIN News 16: Solicitation Alert

Enhanced accessibility version of the "Solicitation Alert" video

Printable transcript of video

What is a trademark-related solicitation?

What kinds of trademark-related services do private companies offer?

Are the deadlines in these offers and notices accurate?

I received a misleading trademark offer or notice. What should I do?

Do you have any examples of potentially misleading offers or notices?

Brand Registration Office (Trademark Selection Edition) (Washington, DC)

GBO, Inc., Trademark and Patent Dep. (Miami, FL)

GLOPAT Global Patents & Trademarks (Bratislava, Slovak Republic)

GLOTRADE (New York, NY)

Intellectual Property Agency Ltd. (London, U.K.)

Intellectual Property Services USA Incorporated (Alexandria, VA)

IOPR - Intellectual Office Property Register (Beaverton, OR)

IP Direct - Registration of the International Trademark (Czech Republic)

IPTA Registration of the International Trademark (Brno, Czech Republic)

IPTI - International Patent & Trademark Index (Czech Republic)

IPTO International Patent & Trademark Organization (Brno, Czech Republic)

IPTR Registration of the International Trademark (Brno, Czech Republic)

P.T.M.A. Patent and Trademark Association (New York, NY)

Patent & Trademark Agency (New York, NY)

Patent & Trademark Bureau (Philadelphia, PA)

Patent and Trademark Bureau (New York, NY)

Patent & Trademark Office (299 Park Ave., New York, NY)

Patent & Trademark Office (555 Madison Ave., New York, NY)

Patent & Trademark Office (Jersey City, NJ)

Patent & Trademark Resource Center (Seattle, Woodinville, & Bothell, WA)

Patent and Trademark Organization (New York, NY)

Patent Trademark Register

PTMI – Register of Protected Patents and Trademarks (Staten Island, NY)

Register of International Patents and Trademarks (Bratislava, Slovak Republic)

RPT Servis - Registration of the International Trademark (Czech Republic)

TM Edition (2012 version) (Szentendre, Hungary)

TM Edition (2015 version) (Szentendre, Hungary)

TM-DB Register of Protected Trademarks (Minneapolis, MN)