`
`ESTTA Tracking number:
`Filing date:
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Petition for Cancellation
`
`Petitioner information
`
`tion
`
`Name Rival Boxing Gear Inc.
`Entity Corporation Incorporated or CA
`registered in
`Address 9810 ST-URBAIN
`MONTREAL, QC H3L 2T2
`CANADA
`Attorney informa- | BRADLEY STOHRY
`
`6151 CENTRAL AVE
`
`INDIANAPOLIS, IN 46220
`
`UNITED STATES
`
`Primary email: brad@rsindy.com
`Secondary email(s): docket@rsindy.com
`3175012891
`
`Docket no.
`
`Registration subject to cancellation
`
`Registration no. 7128404 | Registration date | 08/01/2023
`Register Principal
`Registrant Tradehome Shoe Stores, Inc.
`
`8300 97TH ST SOUTH
`COTTAGE GROVE, MN 55016
`UNITED STATES OF AMERICA
`
`Goods/services subject to cancellation
`
`Class 025. First Use: Jul 13, 2022 First Use In Commerce: Jul 13, 2022
`All goods and services in the class are subject to cancellation, namely: footwear
`
`Grounds for cancellation
`
`| Priority and likelihood of confusion
`
`| Trademark Act Sections 14(1) and 2(d)
`
`Registration subject to cancellation
`
`Registration no. 7919839 | Registration date | 08/26/2025
`Register Principal
`Registrant Tradehome Shoe Stores, Inc.
`
`8300 97TH ST. SOUTH
`COTTAGE GROVE, MN 55016
`United States
`
`ESTTA1492614
`01/26/2026
`
`
`
`
`
`
`
`
`
`Goods/services subject to cancellation
`
`Class 025. First Use: Jul 13, 2022 First Use In Commerce: Jul 13, 2022
`All goods and services in the class are subject to cancellation, namely: Footwear
`
`Grounds for cancellation
`
`| Priority and likelihood of confusion | Trademark Act Sections 14(1) and 2(d)
`
`Mark cited by petitioner as basis for cancellation
`
`U.S. registration 4134385 Application date 06/06/2011
`
`no.
`
`Register Principal
`
`Registration date | 05/01/2012 Foreign priority NONE
`date
`
`Word mark RIVAL
`
`Design mark
`
`-
`e ™
`i .
`
`Description of
`mark
`
`The mark consists of the stylized term "RIVAL" positioned on the bottom of a
`horns design.
`
`Goods/services
`
`Class 009. First use: First Use: None First Use In Commerce: None
`Sports helmets
`
`Class 010. First use: First Use: None First Use In Commerce: None
`Support bandages for boxing training
`
`Class 025. First use: First Use: None First Use In Commerce: None
`Clothing, namely, boxing shorts, bathrobes, corner jackets, boxing shoes
`Class 028. First use: First Use: None First Use In Commerce: None
`
`Boxing equipment and accessories, namely, boxing gloves, punching bags, box-
`
`ing swivels for speed bags, abdominal pads, training bandages, namely, hand-
`wraps, and trainer's mitts
`
`Attachments 85338478#TMSN.jpg( bytes )
`Petition to Cancel RIVAL Registrations.pdf(2112646 bytes )
`Signature /bms/
`Name Bradley M. Stohry
`Date 01/26/2026
`
`
`
`
`
`
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of Trademark Reg. Nos. 7128404 and 7919839
`For the mark RIVAL (Stylized) and RIVAL
`Registered on August 1, 2023 and August 26, 2025
`
`Rival Boxing Gear Inc., )
`Petitioner, ;
`V. ; Cancellation No.:
`Tradehome Shoe Stores, Inc., ;
`Registrant. ;
`PETITION TO CANCEL
`
`Rival Boxing Gear Inc. (“Petitioner”) hereby seeks to cancel U.S. Trademark Reg. Nos.
`7128404 and 7919839 (the “Registrations’), which are owned by Tradehome Shoe Stores, Inc.
`(“Registrant”). The grounds for cancellation are as follows:
`
`The Parties
`
`1. Petitioner is a corporation organized under the laws of Quebec (Canada) with a
`place of business at 9810 St-Urbain, Montreal, QC H3L 2T2, Canada.
`
`2. Registrant is a corporation under the laws of the Minnesota (U.S.A.) with a place
`of business at 8300 97th St South, Cottage Grove, MN 55016, U.S.A.
`
`Petitioner and Its Use of the RIVAL Mark
`
`3. Petitioner uses the RIVAL mark to promote its boxing gear, which includes shoes
`and other clothing items.
`
`4. Petitioner began using the RIVAL mark in connection with its provision of goods
`to U.S. consumers in December 2014. Since that time, Petitioner has actively used the RIVAL
`
`mark in connection with its shoes and other boxing gear throughout the U.S.
`
`
`
`
`
`
`
`
`5. As a result of this use of the RIVAL mark, Petitioner has established valuable
`trademark rights and goodwill in the RIVAL mark.
`
`6. To further solidify its rights in the RIVAL mark, Petitioner obtained U.S. Reg. No.
`4134385 for a logo version of the RIVAL mark. Copies of the Certificate of Registration for U.S.
`Reg. No. 4134385 and the related TSDR record are submitted herewith as Exhibit A.
`
`Grounds for Cancellation
`
`7. Trademark App. Ser. No. 97162918 and was filed by Registrant for a logo version
`of the RIVAL mark on December 8, 2021. That application proceeded to registration as Reg. No.
`7128404 on August 1, 2023.
`
`8. Trademark App. Ser. No. 98906707 and was filed by Registrant for the RIVAL
`mark on December 17, 2024. That application proceeded to registration as Reg. No. 7919839 on
`August 26, 2025.
`
`0. According to the Registrations, Registrant uses the RIVAL mark in connection with
`“footwear.”
`
`10. In each Registration, Registrant claimed a date of first use of July 13, 2022.
`
`11. Petitioner’s actual, continuous, and continuing use of the RIVAL mark in
`commerce began before Registrant filed the applications for the RIVAL mark and/or began using
`the RIVAL mark in commerce.
`
`12. Registrant’s use and registration of the RIVAL mark for the goods listed in its
`Registrations is likely to cause confusion, mistake, and/or lead to deception as to the origin of
`Registrant’s goods.
`
`13. The likelihood of confusion is apparent in this instance because the parties are both
`
`using the same RIVAL mark in connection with footwear.
`
`Page 2
`
`
`
`
`
`
`
`
`14. Registrant’s use and registration of the RIVAL mark is likely to result in confusion
`and substantial damage and injury to Petitioner. Persons familiar with the RIVAL mark are likely
`to believe that Registrant’s goods originate with, or are licensed, sponsored or approved by
`Petitioner. Any such confusion would inevitably result in loss of sales to Petitioner, and/or damage
`the goodwill and reputation that Petitioner has established in the RIVAL mark.
`
`WHEREFORE, Petitioner prays that the Registrations be cancelled on the grounds of
`likelihood of confusion.
`
`Dated this 26th day of January, 2026.
`
`Respectfully submitted,
`
`By: _ /Bradley M. Stohry/
`Bradley M. Stohry
`REICHEL STOHRY DEAN LLP
`6151 Central Ave.
`Indianapolis, Indiana 46220
`(317) 501-2891
`
`Attorney for Rival Boxing Gear Inc.
`
`Page 3
`
`
`
`
`
`
`
`
`Exhibit A
`
`
`
`
`
`
`
`
`Generated on: This page was generated by TSDR on 2026-01-26 15:50:40 EST
`Mark: RIVAL
`
`Y2
`RINA\L.
`
`Application Filing Jun. 06, 2011
`Date:
`
`US Serial Number: 85338478
`
`US Registration 4134385 Registration Date: May 01, 2012
`
`Number:
`Register: Principal
`Mark Type: Trademark
`
`TM5 Common Status LIVE/REGISTRATION/Issued and Active
`
`Descriptor:
`The trademark application has been registered with the Office.
`
`Status: The registration has been renewed.
`Status Date: Nov. 02, 2022
`Publication Date:Feb. 14, 2012
`
`Mark Information
`
`Mark Literal RIVAL
`
`Elements:
`
`Standard Character No
`
`Claim:
`
`Mark Drawing 3 - AN ILLUSTRATION DRAWING WHICH INCLUDES WORD(S)/ LETTER(S) /NUMBER(S)
`
`Type:
`
`Description of
`Mark:
`
`The mark consists of the stylized term "RIVAL" positioned on the bottom of a horns design.
`
`Color(s) Claimed:
`
`Design Search
`
`Color is not claimed as a feature of the mark.
`03.13.03 - Antlers shown alone or as part of something other than associated animal; Horns shown alone or as part of something other
`
`Code(s): than associated animal
`Foreign Information
`Foreign TMA661,230 Foreign Mar. 23, 2006
`Registration Registration Date:
`Number:
`
`Foreign Expiration Mar. 23, 2021
`
`Foreign CANADA
`Date:
`
`Application/Registration
`Country:
`
`Goods and Services
`
`Note:
`
`The following symbols indicate that the registrant/owner has amended the goods/services:
`e Brackets [..] indicate deleted goods/services;
`e Double parenthesis ((..)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and
`e Asterisks *..* identify additional (new) wording in the goods/services.
`
`For: Sports helmets
`International 009 - Primary Class U.S Class(es): 021, 023, 026, 036, 038
`
`Class(es):
`Class Status: ACTIVE
`
`For: Support bandages for boxing training
`
`International 010 - Primary Class U.S Class(es): 026, 039, 044
`
`Class(es):
`
`
`
`
`
`
`
`
`Class Status:
`
`For:
`
`International
`Class(es):
`
`Class Status:
`
`For:
`
`International
`
`ACTIVE
`
`Clothing, namely, boxing shorts, bathrobes, corner jackets, boxing shoes
`
`025 - Primary Class U.S Class(es): 022, 039
`
`ACTIVE
`Boxing equipment and accessories, namely, boxing gloves, punching bags, boxing swivels for speed bags, abdominal pads, training
`bandages, namely, handwraps, and trainer's mitts
`
`028 - Primary Class U.S Class(es): 022, 023, 038, 050
`
`Class(es):
`Class Status: ACTIVE
`Basis Information (Case Level)
`
`Filed Use: No Currently Use: No
`Filed ITU: Yes Currently ITU: No
`Filed 44D: No Currently 44D: No
`Filed 44E: Yes Currently 44E: Yes
`Filed 66A: No Currently 66A: No
`
`Filed No Basis: No Currently No Basis: No
`
`Current Owner(s) Information
`
`Owner Name:
`
`Owner Address:
`
`Legal Entity Type:
`
`RIVAL BOXING GEAR INC.
`
`9810 St-Urbain
`Montreal, Quebec CANADA H3L2T2
`
`CORPORATION State or Country CANADA
`
`Where Organized:
`
`Attorney/Correspondence Information
`
`Attorney Name:
`
`Attorney Primary
`Email Address:
`
`Correspondent
`Name/Address:
`
`Phone:
`
`Correspondent e-
`
`Attorney of Record
`Bradley M. Stohry
`
`Attorney Email Yes
`Authorized:
`
`docket@gomintbox.ca
`
`Correspondent
`
`Bradley M. Stohry
`Reichel Stohry Dean LLP
`525 S. Meridian St, Suite 1A2
`
`Indianapolis, INDIANA UNITED STATES 46225
`317.501.2891 Fax: 317.454.1349
`
`docket@gomintbox.ca brad@rsindy.com docket@ Correspondent e- Yes
`
`May 02, 2022
`
`mail: rsindy.com mail Authorized:
`Domestic Representative - Not Found
`Prosecution History
`Date Description nmfigg‘rfing
`
`Nov. 02, 2022 NOTICE OF ACCEPTANCE OF SEC. 8 & 9 - E-MAILED
`
`Nov. 02, 2022 REGISTERED AND RENEWED (FIRST RENEWAL - 10 YRS)
`
`Nov. 02, 2022 REGISTERED - SEC. 8 (10-YR) ACCEPTED/SEC. 9 GRANTED
`
`Nov. 02, 2022 CASE ASSIGNED TO POST REGISTRATION PARALEGAL
`
`May 02, 2022 TEAS SECTION 8 & 9 RECEIVED
`
`May 02, 2022 APPLICANT/CORRESPONDENCE CHANGES (NON-RESPONSIVE) ENTERED
`
`May 02, 2022 TEAS CHANGE OF CORRESPONDENCE RECEIVED
`
`May 02, 2022 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED
`
`May 02, 2022 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED
`
`TEAS CHANGE OF OWNER ADDRESS RECEIVED
`
`
`
`
`
`
`
`
`May 01, 2021 COURTESY REMINDER - SEC. 8 (10-YR)/SEC. 9 E-MAILED
`
`Nov. 19, 2018 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED
`
`Nov. 19, 2018 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED
`May 09, 2018 NOTICE OF ACCEPTANCE OF SEC. 8 & 15 - E-MAILED
`
`May 09, 2018 REGISTERED - SEC. 8 (6-YR) ACCEPTED & SEC. 15 ACK.
`
`May 09, 2018 CASE ASSIGNED TO POST REGISTRATION PARALEGAL
`
`Apr. 27,2018 TEAS SECTION 8 & 15 RECEIVED
`
`Dec. 18, 2017 REVIEW OF CORRESPONDENCE COMPLETE - POWER OF ATTORNEY ENTERED
`Dec. 18, 2017 TEAS WITHDRAWAL OF ATTORNEY RECEIVED-FIRM RETAINS
`Dec. 15,2017 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED
`
`Dec. 15,2017 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED
`May 01, 2017 COURTESY REMINDER - SEC. 8 (6-YR) E-MAILED
`
`Apr. 29, 2015 TEAS CHANGE OF CORRESPONDENCE RECEIVED
`
`Jul. 14, 2014 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED
`
`Jul. 14, 2014 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED
`May 01, 2012 REGISTERED-PRINCIPAL REGISTER
`
`Feb. 14,2012 OFFICIAL GAZETTE PUBLICATION CONFIRMATION E-MAILED
`
`Feb. 14,2012 PUBLISHED FOR OPPOSITION
`
`Jan. 25,2012 NOTIFICATION OF NOTICE OF PUBLICATION E-MAILED
`
`Jan. 09, 2012 LAW OFFICE PUBLICATION REVIEW COMPLETED
`
`Jan. 09, 2012 APPROVED FOR PUB - PRINCIPAL REGISTER
`
`Dec. 22, 2011 AMENDMENT FROM APPLICANT ENTERED
`
`Dec. 22, 2011 CORRESPONDENCE RECEIVED IN LAW OFFICE
`
`Dec. 20, 2011 ASSIGNED TO LIE
`
`Dec. 16, 2011 PAPER RECEIVED
`
`Sep. 26, 2011 NOTIFICATION OF NON-FINAL ACTION E-MAILED
`
`Sep. 26, 2011 NON-FINAL ACTION E-MAILED
`
`Sep. 26, 2011 NON-FINAL ACTION WRITTEN
`
`Sep. 20, 2011 ASSIGNED TO EXAMINER
`
`Jun. 10, 2011 NOTICE OF DESIGN SEARCH CODE MAILED
`
`Jun. 09, 2011 NEW APPLICATION OFFICE SUPPLIED DATA ENTERED
`
`Jun. 09, 2011 NEW APPLICATION ENTERED
`
`TM Staff and Location Information
`
`TM Staff Information - None
`File Location
`Current Location: GENERIC WEB UPDATE Date in Location: Nov. 02, 2022
`
`
`
`
`
`
`
`
`B nited
`
`States of Ampy,,
`
`WAnited States Patent and Trademark Office (?
`
`Reg. No. 4,134,385
`Registered May 1, 2012
`
`Int. Cls.: 9, 10, 25 and 28
`
`TRADEMARK
`PRINCIPAL REGISTER
`
`Director of the United States Patent and Trademark Office
`
`IN/A\ L
`
`RIVAL BOXING GEAR INC. (CANADA CORPORATION)
`
`9810 ST-URBAIN
`
`MONTREAL, QUEBEC, CANADA H3L2T2
`
`FOR: SPORTS HELMETS, IN CLASS 9 (U.S. CLS. 21, 23, 26, 36 AND 38).
`
`FOR: SUPPORT BANDAGES FOR BOXING TRAINING, IN CLASS 10 (U.S. CLS. 26,39 AND
`44),
`
`FOR: CLOTHING,NAMELY, BOXING SHORTS, BATHROBES, CORNER JACKETS, BOXING
`SHOES. IN CLASS 25 (U.S. CLS. 22 AND 39).
`
`FOR: BOXING EQUIPMENT AND ACCESSORIES, NAMELY, BOXING GLOVES, PUNCHING
`BAGS, BOXING SWIVELS FOR SPEED BAGS, ABDOMINAL PADS, TRAINING BANDAGES,
`NAMELY, HANDWRAPS, AND TRAINER'S MITTS, IN CLASS 28 (U.S. CLS. 22, 23, 38 AND
`50).
`
`OWNER OF CANADA REG. NO. TMAG661,230, DATED 3-23-2006, EXPIRES 3-23-2021.
`
`THE MARK CONSISTS OF THE STYLIZED TERM "RIVAL" POSITIONED ON THE BOTTOM
`OF A HORNS DESIGN.
`
`SER. NO. 85-338.478, FILED 6-6-2011.
`
`CAROLINE WOOD, EXAMINING ATTORNEY
`
`
`
`
`
`
`
`
`REQUIREMENTS TO MAINTAIN YOUR FEDERAL
`TRADEMARK REGISTRATION
`
`WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
`DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.
`
`Requirements in the First Ten Years*
`What and When to File:
`
`First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the
`5th and 6th years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is
`accepted, the registration will continue in force for the remainder of the ten-year period, calculated
`from the registration date, unless cancelled by an order of the Commissioner for Trademarks or a
`federal court.
`
`Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an
`Application for Renewal between the 9th and 10th years after the registration date.*
`See 15 U.S.C. §1059.
`
`Requirements in Successive Ten-Year Periods*
`What and When to File:
`
`You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between
`every 9th and 10th-year period, calculated from the registration date. *
`
`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 United States Patent and Trademark Office (USPTO) will NOT send you any future notice or
`reminder of these filing requirements.
`
`*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with
`an extension of protection to the United States under the Madrid Protocol must timely file the Declarations
`of Use (or Excusable Nonuse) referenced above directly with the USPTO. The time periods for filing are
`based on the U.S. registration date (not the international registration date). The deadlines and grace periods
`for the Declarations of Use (or Excusable Nonuse) are identical to those for nationally issued registrations.
`See 15U.8.C. §§1058, 1141k. However, owners of international registrations do not file renewal applications
`at the USPTO. Instead, the holder must file a renewal of the underlying international registration at the
`International Bureau of the World Intellectual Property Organization, under Article 7 of the Madrid Protocol,
`before the expiration of each ten-year term of protection, calculated from the date of the international
`registration. See 15 U.S.C. §1141j. For more information and renewal forms for the international registration,
`see http://www.wipo.int/madrid/en/.
`
`NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
`USPTO website for further information. With the exception of renewal applications for registered
`extensions of protection, you can file the registration maintenance documents referenced above online
`at http://www.uspto.gov.
`
`Page: 2 /RN # 4,134,385
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