`
`ESTTA1423048
`
`Filing date:
`
`03/20/2025
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding no.
`
`92086625
`
`Party
`
`Correspondence
`address
`
`Defendant
`Vanessa Alonso
`
`VANESSA ALONSO
`806 S ZARZAMORA ST
`SAN ANTONIO, TX 78207
`UNITED STATES
`Primary email: vanessa@alonsoalonsolaw.com
`No phone number provided
`
`Submission
`
`Filer's name
`
`Filer's email
`
`Signature
`
`Date
`
`Other Motions/Submissions
`
`Rodrick J. Enns
`
`renns@ennsandarcher.com
`
`/Rodrick J. Enns/
`
`03/20/2025
`
`Attachments
`
`Motion to Amend and Withdraw - LA MERA MERA - 3-20-2025.pdf(8115 bytes )
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Pastrana & Garcia
`
`Cancellation No. 92086625
`
`v.
`
`Registration No. 7350828
`
`Petitioner,
`
`Vanessa Alonso
`
`Mark: LA MERA MERA
`
`Registrant.
`
`MOTION ON CONSENT TO AMEND REGISTRATION AND,
`IF GRANTED, TO WITHDRAW PETITION WITH PREJUDICE
`
`Pursuant to Rule 2.133 of the Trademark Rules of Practice, Registrant, through its
`
`undersigned counsel, requests that Registration No. 7350828 be amended by deleting the
`
`wording “personal injury, and criminal defense” from the identification of services, as shown:
`
`legal services in the field of immigration, personal injury, and
`criminal defense.
`
`This amendment is appropriate pursuant to Lanham Act § 7(e), 15 U.S.C. § 1057(e), in
`
`that it only limits and does not add to the identification of services, and does not alter materially
`
`the character of the mark.
`
`This amendment does not require payment of a fee pursuant to 37 C.F.R. § 2.6(a)(11)
`
`because it is being requested prior to submission of an affidavit under Lanham Act § 8, 15
`
`U.S.C. § 1058.
`
`This amendment is made pursuant to an agreement between Registrant and Petitioner,
`
`who has consented to the amendment. If the amendment is approved by the Board, Petitioner,
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`with Registrant’s consent, requests that this opposition be withdrawn with prejudice.
`
`WHEREFORE, the Parties respectfully request:
`
`
`
`1.
`
`that Registration No. 7350828 be amended by deleting the wording “personal
`
`injury, and criminal defense” from the identification of services; and
`
`2.
`
`that that the Petition for Cancellation thereupon be withdrawn with prejudice.
`
`Dated: March 20, 2025
`
`Respectfully submitted,
`
`
`
`By: /s/ Rodrick J. Enns
`Rodrick J. Enns
`Enns & Archer LLP
`939 Burke Street
`Winston-Salem, NC 27101
`(336) 723-5180
`renns@ennsandarcher.com
`
`Attorney for Registrant Vanessa Alonso
`
`CONSENTED TO:
`
`By:
`
`
`
`/s/ Ryan T. Beard
`Ryan T. Beard
`PIERSON FERDINAND
`2021 Guadalupe Street, Suite 260
`Austin, Texas 78702
`512-577-2673
`ryan.beard@pierferd.com
`
`Attorney for Petitioner Pastrana & Garcia
`
`2
`
`
`
`The signatory being warned that willful false statements and the like are punishable by fine or
`imprisonment, or both, under 18 U.S.C. § 1001, and that such willful false statements and the
`like may jeopardize the validity of this submission, declares that all statements made of his/her
`own knowledge are true and all statements made on information and belief are believed to be
`true.
`
` /s/ Rodrick J. Enns
`Rodrick J. Enns
`Enns & Archer LLP
`939 Burke Street
`Winston-Salem, NC 27101
`(336) 723-5180
`renns@ennsandarcher.com
`
`Attorney for Registrant Vanessa Alonso
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this date I served a true and complete copy of the foregoing
`
`MOTION ON CONSENT TO AMEND REGISTRATION AND, IF GRANTED, TO
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`WITHDRAW PETITION WITH PREJUDICE on counsel of record for Petitioner by forwarding
`
`the same via email to:
`
`Ryan T. Beard
`ryan.beard@pierferd.com
`
`Attorney of record for Petitioner
`
`This the 20th day of March, 2025.
`
`/Rodrick J. Enns/
`Rodrick J. Enns
`ENNS & ARCHER LLP
`939 Burke Street
`Winston-Salem, NC 27101
`336-723-5180
`renns@ennsandarcher.com
`
`2
`
`
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