JFP Gulf General Trading LLCv.Evory Technologies, Inc.

Trademark Trial and Appeal Board

Feb 6, 2017

CANC (T.T.A.B. Feb. 6, 2017)

Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
ESTTA Tracking number: ESTTA799450
Filing date: 02/06/2017
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
Proceeding 92062012
Party Defendant
Evory Technologies, Inc.
Correspondence
Address
CHI LIU
EVORY TECHNOLOGIES INC
1270 N MARINE CORP DR, STE 101-397
TAMUNING, GU 96913-4331
UNITED STATES
chi_liu@evorytech.com, liuchi23@hotmail.com
Submission Reply in Support of Motion
Filer's Name Chi Liu
Filer's e-mail chi_liu@evorytech.com
Signature /LIU, CHI/
Date 02/06/2017
Attachments Registrants response to Petitioners Opp 01.pdf(450716 bytes )
Registrants response to Petitioners Opp 02.pdf(5304796 bytes )
Registrants response to Petitioners Opp 03.pdf(1798959 bytes )
Registrants response to Petitioners Opp 04.pdf(5172029 bytes )
1

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

JFP GULF GENERAL TRADING LLC,
Petitioner,
vs.
EVORY TECHNOLOGIES, INC.
Registrant.

Mark: ALISHAN
Cancellation No.: 92062012

REGISTRANT’S RESPONSE TO PETITIONER’S OPPOSITION TO
REGISTRANT’S MOTION FOR SUMMARY JUDGMENT
Evory Technologies, Inc., Registrant, hereby responds to Petitioner’s Opposition to
Registrant’s Motion for Summary Judgment dated on January 17, 2017.
I.
ARGUMENT
1-1. Petitioner used fraudulent statement to distract the Board’s attention and
mislead the truth. In Petitioner’s Declaration of Marie Richmond in support of
Petitioner’s opposition to registrant’s motion for summary judgment, Petitioner stated
that “Note that the Exhibit indicates that company was founded in 2010, but Mr. Liu has
provided at least 6 invoices purportedly to that company in 2008” on page 5 in point 11.
In fact, the above mentioned company Dainty Products Company was founded in 2003.
True and correct copies of the relevant documents of the Business Name History are
attached hereto as Exhibit AAA. Because of Ms. Marie Richmond’s continuous
2

fraudulent records in the processing, any Declaration of Ms. Marie Richmond should not
be considered.
1-2． Petitioner is an unproven foreign organization. Throughout the discovery
period, Petitioner escaped responsibilities and refused to submit any documents to prove
that Petitioner is a legal entity. Basis on Fed. R. Civ. P. 17(b), Petitioner does not have
any capacity to sue or be sued. The Petitioner’s Cancellation No. 92062012 should be
denied immediately. See In re Cambridge Digital Systems, 1 USPQ2d 1659, 1660 n.1
(TTAB 1986).
1-3. Petitioner still refused to provide who or which division authorized Mr. Mike
Rodenbaugh and Ms. Marie Richmond to be Petitioner’s counsel or representative in this
processing. Mr. Mike Rodenbaugh and Ms. Marie Richmond has not proved that they
were legally authorized by Petitioner and the range of their service. So far, Registrant has
not seen any document directly from Petitioner, JFP GULF GENERAL TRADING LLC.
In addition, Petitioner is an unproven foreign organization, the Cancellation No.
92062012 should be denied immediately.
1-4. On October 2, 2015, Petitioner received Registrant’s ALISHAN goods,
including Chocolate, Herbal tea, Tea, Rice, Oatmeal, Noodle, Coffee, Spice, Flour, Gum,
Sugar, Salt, Cappuccino, signed by M RODE, which is the abbreviation of Mr. Mike
Rodenbaugh (See Exhibit AA). Those Registrant’s ALISHAN goods were shipped from
oversea supplier (Algin Co. Ltd.) and filed custom form with USPS (See Exhibit AB).
However, Petitioner refused to concede Petitioner’s receiving of Registrant’s ALISHAN
goods (See Exhibit AC), until Registrant presented a copy of United State Postal Service
confirmation of delivery by signature. Because of Petitioner’s repetitive lying and
dishonesty, any Declaration of Petitioner should not be considered. Petitioner’s lying and
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dishonesty should be censured.
1-5. After the completion of the discovery period, Petitioner responded Registrant’s
document requests for the first time on December 1, 2016, although the responses
showed an earlier date of October 20 (See Exhibit AJ, AK). Please note that October 20,
2016 is exactly the date set for the close of discovery period. Petitioner intended to
respond on the date set for the close of discovery period, in order to avoid his obligations.
Petitioner’s delay in response violate the regulation. Petitioner should be censured.
1-6. Petitioner has been intentionally delayed proceeding by distracting the Board’s
attentions from this case to another case. In Petitioner’s Opposition to Registrant’s
Motion for Summary Judgment dated on January 17, 2017, Petitioner wasted over 10
pages on another irrelevant trademark. It is no use to discuss how many lawsuits Mr.
Mike Rodenbaugh lost or why Mr. Mike Rodenbaugh left his previous employer in the
past to support Mr. Mike Rodenbaugh’s incompetence. Petitioner’s bad behaviors and
should be censured.
1-7. Petitioner used misrepresentation to distract the Board’s attention and to
mislead the truth. In Petitioner’s Opposition to Registrant’s Motion for Summary
Judgment stated that “A cursory look at the Registrant’s Website reveals consumers
cannot purchase items directly through the site, nor does the website indicate that such
goods are available for sale. Registrant has not provided any evidence of any sales
through the website” on page 14. The truth is, everyone in the United States can easily
find the pictures, description, price and availability of ALISHAN goods as well as
shipping method and shipping fee at eBay or Registrant’s website since 2006. Registrant
reiterates that Registrant and relative parities has continuously used, promoted and
advertised ALISHAN goods from 2006 to 2017 in the United States of American (See
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Exhibit AB, AM, AP, AQ, AR, AU).
1-8. Petitioner has strong drive to lie and to cheat in the processing for profits. In
order to delay the processing and to enable Petitioner’s registration of trademark,
Petitioner claimed that Petitioner did not received Registrant’s ALISHAN sample on
October 20, 2015 (See Exhibit AC) and did not correct his statement until Registrant
presented USPS proof of delivery. On the other hand, Registrant has strong motivation to
do good faith in the processing and submits documents and supporting materials promptly.
Petitioner’s cheating should be censured.

II.
CONCLUSION
2-1. Petitioner used false statements, lying, cheating and misdirect to delay the
proceeding and misled the truth. Petitioner’s bad behaviors should be censured.

2-2. Petitioner purposely distracted the Board’s attention by ignoring Registrants
evidence and picking hole in it. In fact, Registrant provided lots of documents showing
sales invoice, sales records at websites and eBay. Petitioner intentionally ignored most of
the above documents and focused on arguing about the number of invoice that Registrant
provided to Petitioner. Petitioner attempted to delay the proceeding and misled the truth.
Petitioner’s bad behavior should be censured.

2-3. Petitioner is an unproven foreign organization. However, Petitioner refused to
submit any documents to prove that Petitioner is a legal entity (See Exhibit AJ, AK).
Because of Petitioner’s repetitive lying and dishonesty (See Exhibit AA, AC), any
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declaration of Petitioner should not be considered. Petitioner’s Petition to Cancel should
be denied.

2-4. Based on all the evidence, there is little, if any, doubt that Petitioner’s Petition
to Cancel should be denied and Registrant’s Motion for Summary Judgment granted due
to Registrant’s continuous use, advertise and promote in the United States, without
abandonment, of the mark ALISHAN.

2-5. The Petitioner’s Cancellation No. 92062012 was contrary to fact and was
absence of evidence. Registrant respectfully requests that the Trademark Trial & Appeal
Board grant Registrant’s Motion for Summary Judgment and deny the Petitioner’s
Petition to Cancel.

Respectfully submitted,
EVORY TECHNOLOGIES, INC.

Dated: February 6, 2017
By:_____________________________
CHI LIU
1270 N. Marine Corp. Dr. Ste. 101-397
Tamuning, Guam 96913-4331
General Manager
Evory Technologies, Inc.

6

CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing REGISTRANT’S RESPONSE TO
PETITIONER’S OPPOSITION TO REGISTRANT’S MOTION FOR SUMMARY
JUDGMENT was served by Post Office Mail, postage prepaid on February 6, 2017 and
E-mail on the same day, addressed as follows:

JFP GULF GENERAL TRADING LLC
548 MARKET STREET BOX NO 55819
SAN FRANCISCO, CA 94104
mike@rodenbaugh.com

_________________________________
CHI LIU
February 6, 2017
Exhibit AAA

Exhibit AA

Exhibit AB

Exhibit AC

Exhibit AD

Exhibit AE

Exhibit AF

Exhibit AG

Exhibit AH

Exhibit AI

Exhibit AJ
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE
TRADEMARK TRIAL AND APPEAL BOARD

Registration No.: 3511321
For the mark: ALISHAN
Date Registered: October 7, 2008

Registration No.: 3273480
For the mark: ALISHAN
Date Registered: August 7, 2007
_____________________________________________

JFP GULF GENERAL TRADING LLC,

Petitioner,

vs.

EVORY TECHNOLOGIES, INC.,

Registrant.
__________________________________________
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Proceeding No. 92062012

PETITIONER’S RESPONSES
TO REGISTRANT’S FIRST
SET OF
INTERROGATORIES

PETITIONER’S RESPONSES TO REGISTRANT’S FIRST SET OF
INTERROGATORIES
Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure and Rule
2.120 of the Trademark Rules of Practice, Petitioner JFP Gulf General Trading LLC
(“Petitioner”) submits the following objections and responses to Registrant’s First Set
of Interrogatories:
GENERAL OBJECTIONS
The following General Objections apply to every paragraph of Registrant’s First Set of
Interrogatories:
1. Petitioner objects to every interrogatory that calls for privileged information,
including, without limitation, information protected by the attorney-client privilege.
2. Petitioner objects to every interrogatory that calls for information prepared in
anticipation of litigation or for trial absent a showing of substantial need by Registrant.
3. Petitioner objects to every interrogatory that calls for the production of any
information containing or reflecting the mental impressions, conclusions, opinions and/or
legal theories of any attorney for Petitioner, on the grounds that such information is
protected by the attorney work product doctrine.
4. Petitioner objects to every interrogatory that is overly broad, unduly burdensome,
harassing, duplicative or which requests documents which are already in the possession of
Registrant.
5. Petitioner objects to every interrogatory that calls for information which is
neither relevant to the subject matter of the pending Opposition proceeding nor reasonably
calculated to lead to the discovery of admissible evidence in connection with the pending
Opposition proceeding.
6. Petitioner objects to every interrogatory, and to every introductory
“definition” or “instruction,” that seeks to impose obligations beyond those required
by the Federal Rules of Civil Procedure, as reasonably interpreted and supplemented
by Trademark Rules of Practice.
RESPONSES AND OBJECTIONS TO INTERROGATORIES
Subject to and without waiver of the foregoing General Objections, Petitioner
responds to Registrant’s specific Requests for Production of Documents and Things as
follows:
INTERROGATORY NO. 1:
(a) List the name and title of all Petitioner’s employee and/or shareholder who visited
Registrant’s website of http://www.superteastore.com
(b) List the dates that all Petitioner’s employee and/or shareholder who visited
Registrant’s website of http://superteastore.com.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
objects to the extent the request seeks information that is not relevant or likely to lead to the
discovery of admissible evidence.
INTERROGATORY NO. 2:
(a) List the name and title of all Petitioner’s employee and/or shareholder who had
the most acknowledge of the ALISHAN samples provided by Registrant. The ALISHAN
samples were received and signed by M. Rode on October 2, 2015.
(b) List the dates that all Petitioner’s employee and/or shareholder who had the most
acknowledge of the ALISHAN samples provided by Registrant. The ALISHAN samples
were received and signed by M. Rode on October 2, 2015.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
objects to the extent the request seeks information that is not relevant or likely to lead to the
discovery of admissible evidence.
INTERROGATORY NO. 3:
(a) List the name and title of all Petitioner’s employee and/or shareholder who
physically touched the ALISHAN samples provided by Registrant. The ALISHAN samples
were received and signed by M. Rode on October 2, 2015.
(b) List the dates that all Petitioner’s employee and/or shareholder who physically
touched the ALISHAN samples provided by Registrant. The ALISHAN samples were received
and signed by M. Rode on October 2, 2105.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request seeks
information that is protected from disclosure by the attorney-client privilege, the attorney work
product doctrine and/or the joint interest or joint defense privilege. Petitioner objects to the
extent the request seeks information that is not relevant or likely to lead to the discovery of
admissible evidence.
INTERROGATORY NO. 4:
According to Petitioner’s letter dated on May 9, 2016, Petitioner is located in
India. Explain the transportation approach that Petitioner received the ALISHAN
samples provided by Registrant.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request seeks
information that is protected from disclosure by the attorney-client privilege, the attorney work
product doctrine and/or the joint interest or joint defense privilege. Petitioner objects to the
extent the request seeks information that is not relevant or likely to lead to the discovery of
admissible evidence.
INTERROGATORY NO. 5:
According to the International Accounting Standard 37 – Provisions, Contingent
Liabilities and Contingent Assets, the contingent liability of the cancellation process
between Petitioner and Registrant must be disclosed in Petitioner’s 2015 financial report:
(a) an estimate of its financial effect;
(b) an indication of the uncertainties relating to the amount or timing of any
outflow; and
(c) the possibility of any reimbursement
Please provide the name and the contact information of the Chief Financial Officer
of Petitioner. Did the Chief Financial Officer of Petitioner acknowledge the shareholders
of the cancellation process between Petitioner and Registrant in Petitioner’s 2015 financial
report?
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner objects to the extent the request seeks
information that is not relevant or likely to lead to the discovery of admissible evidence.
INTERROGATORY NO. 6:
According to the International Accounting Standard 37 – Provisions, Contingent
Liabilities and Contingent Assets, the contingent liability of the cancellation process between
Petitioner and Registrant must be disclosed in Petitioner’s 2015 financial report
(a) an estimate of its financial effect;
(b) an indication of the uncertainties relating to the amount or timing of any outflow;
and
(c) the possibility of any reimbursement
Please provide the name and the contact information of the auditor of Petitioner. Was
the Auditor of Petitioner acknowledged the cancellation process between Petitioner and
Registrant?
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner objects to the extent the request seeks
information that is not relevant or likely to lead to the discovery of admissible evidence.

INTERROGATORY NO. 7:
According to the International Accounting Standard 37 – Provisions, Contingent
Liabilities and Contingent Assets, the contingent liability of the cancellation process between
Petitioner and Registrant must be disclosed in Petitioner’s 2015 financial report:
(a) an estimate of its financial effect;
(b) an indication of the uncertainties relating to the amount or timing of any outflow;
and
(c) the possibility of any reimbursement
Please provide the name and contact information for the Chief Executive Officer of
Petitioner. Was the Chief Executive Officer of Petitioner acknowledged the cancellation
process between Petitioner and Registrant?
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner objects to the extent the request seeks
information that is not relevant or likely to lead to the discovery of admissible evidence.
INTERROGATORY NO. 8:
According to the International Accounting Standard 37 – Provisions, Contingent
Liabilities and Contingent Assets, the contingent liability of the cancellation process between
Petitioner and Registrant must be disclosed in Petitioner’s 2015 financial report:
(a) an estimate of its financial effect;
(b) an indication of the uncertainties relating to the amount or timing of any outflow;
and
(c) the possibility of any reimbursement
Please provide the name and the contact information of all major shareholders of
Petitioner. Were all major shareholders of Petitioner acknowledged the cancellation process
between Petitioner and Registrant?
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner objects to the extent the request seeks
information that is not relevant or likely to lead to the discovery of admissible evidence.

INTERROGATORY NO. 9:
(a) List the date, location and name of trade show in the United States of America that
Petitioner participated in the latest five (5) years. The trade shows include all local, cross state,
national and/or international shows.
(b) List the name and title of all Petitioner’s employee and/or shareholder who
participated in the shows participated in the shows in the United States of America in the latest
five (5) years. The trade shows include all local, cross state, national and/or international
shows.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner objects to the extent the
request seeks information that is not relevant or likely to lead to the discovery of admissible
evidence.
INTERROGATORY NO. 10:
(a) List the number of dates that Petitioner visited the United States of America in the
latest five (5) years, including the arriving and the leaving dates.
(b) List the name and title of all Petitioner’s employee and/or shareholder by each visit
who visited the United States of America in the latest five (5) years.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner objects to the extent the
request seeks information that is not relevant or likely to lead to the discovery of admissible
evidence.
INTERROGATORY NO. 11:
Identify all trademarks searches, conducted by or for Petitioner with respect to
Registrant’s MARKS or any other name containing the term ALISHAN and/or ALISHAAN
including:
(a) all marks searched;
(b) whether a written report was rendered pursuant to these searches and investigations;
(c) the person(s) to whom the results of such searches and investigations were reported.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
objects to the extent the request seeks information that is not relevant or likely to lead to the
discovery of admissible evidence.
INTERROGATORY NO. 12:
Identify all persons who have conducted for or on behalf of Petitioner any research
relating in any manner to Registrant’s MARKS.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
objects to the extent the request seeks information that is not relevant or likely to lead to the
discovery of admissible evidence.
INTERROGATORY NO. 13:
Identify all proceedings (including but not limited to the Federal Courts, State Courts and
the Patent and Trademark Office) in which Petitioner has been or is involved which refer or
relate to products or services to be sold in connection with Registrant’s MARKS or which relate
to a trademark comprised in whole or in part of ALISHAN and/or ALISHAAN and identify all
documents related thereto.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner objects to the extent the
request seeks information that is not relevant or likely to lead to the discovery of admissible
evidence.
INTERROGATORY NO. 14:
(a) State when and how Petitioner first learned of Registrant’s use of Registrant’s
MARKS.
(b) Identify the documents in Petitioner’s possession referring to Registrant

RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
objects to the extent the request seeks information that is not relevant or likely to lead to the
discovery of admissible evidence.
INTERROGATORY NO. 15:
(a) Has Petitioner or any person acting for or on behalf of Petitioner received any
communication, oral or in writing, from any person which suggests that Petitioner may be
connected with Registrant?
(b) If so, identify each such communication, including Petitioner’s response thereto.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
objects to the extent the request seeks information that is not relevant or likely to lead to the
discovery of admissible evidence.
INTERROGATORY NO. 16:
State whether Petitioner has knowledge that third parties unrelated to Registrant or
Petitioner use or have used a trademark comprising the term ALISHAN and/or ALISHAAN in
whole or in part in connection with Registrant’s goods.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
objects to the extent the request seeks information that is not relevant or likely to lead to the
discovery of admissible evidence.

INTERROGATORY NO. 17:
Identify the witnesses Petitioner intends to call to testify on its behalf and identify all
documents upon which Petitioner intends to rely on in connection with this Cancellation
proceeding.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
objects to the extent the request seeks information that is not relevant or likely to lead to the
discovery of admissible evidence.
INTERROGATORY NO. 18:
Identify each person who participated in the preparation of Petitioner’s responses to the
foregoing interrogatories and who furnished any information in response thereto.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
objects to the extent the request seeks information that is not relevant or likely to lead to the
discovery of admissible evidence.
Respectfully submitted,

Dated: Oct. 20, 2016

By: /s/ Mike Rodenbaugh

Mike Rodenbaugh
RODENBAUGH LAW
548 Market Street
Box No. 55819
San Francisco, CA 94104
Telephone: (451) 738-8087
Email: mike@rodenbaugh.com

Attorney for Petitioner
CERTIFICATE OF
SERVICE

I hereby certify that a true and complete copy of the foregoing PETITIONER’S
RESPONSES TO REGISTRANT’S FIRST SET OF INTERROGATORIES was served by
U.S. first class mail on this 20th day of October 2016, upon the following:

Registrant’s Attorney of Record
Chi Liu
Evory Technologies, Inc.
1270 N. Marine Corp. Dr. Ste. 101-397
Tamuning, GU 96913-4331
United States

Dated: Oct. 20, 2016
Respectfully submitted,
By: /s/ Mike Rodenbaugh
Mike Rodenbaugh
Rodenbaugh Law
548 Market Street
San Francisco, CA 94104
Tel: (415) 738-8087
California Bar No. 292962

Exhibit AK
1
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE
TRADEMARK TRIAL AND APPEAL BOARD

Registration No.: 3511321
For the mark: ALISHAN
Date Registered: October 7, 2008

Registration No.: 3273480
For the mark: ALISHAN
Date Registered: August 7, 2007

___________________________________________

JFP GULF GENERAL TRADING LLC,

Petitioner,

vs.

EVORY TECHNOLOGIES, INC.,

Registrant.
__________________________________________
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Proceeding No. 92062012

PETITIONER’S RESPONSES
TO REGISTRANT’S FIRST
SET OF REQUESTS FOR
PRODUCTION OF
DOCUMENTS AND THINGS

PETITIONER’S RESPONSES TO REGISTRANT’S FIRST SET OF REQUESTS FOR
PRODUCTION OF DOCUMENTS AND THINGS
Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure and Rule 2.120
of the Trademark Rules of Practice, Petitioner JFP Gulf General Trading (“Petitioner”) submits
the following objections and responses to Registrant’s First Set of Requests for Production of
Documents and Things:
GENERAL OBJECTIONS
The following General Objections apply to every paragraph of Petitioner’s Responses
to Registrant’s First Set of Requests for Production of Documents and Things:
1. Petitioner objects to every Document Request that calls for privileged information,
including, without limitation, information protected by the attorney-client privilege.
2. Petitioner objects to every Document Request that calls for information prepared in
anticipation of litigation or for trial absent a showing of substantial need by Registrant.
2
3. Petitioner objects to every Document Request that calls for the production of any
information containing or reflecting the mental impressions, conclusions, opinions and/or legal
theories of any attorney for Petitioner, on the grounds that such information is protected by
the attorney work product doctrine.
4. Petitioner objects to every Document Request that is overly broad, unduly
burdensome, harassing, duplicative or which requests documents which are already in the
possession of Registrant.
5. Petitioner objects to every Document Request that calls for information, which is
neither relevant to the subject matter of the pending Opposition proceeding nor reasonably
calculated to lead to the discovery of admissible evidence in connection with the pending
Opposition proceeding.
6. Petitioner objects to every interrogatory, and to every introductory “definition” or
“instruction,” that seeks to impose obligations beyond those required by the Federal Rules of
Civil Procedure, as reasonably interpreted and supplemented by Trademark Rules of
Practice.
RESPONSES AND OBJECTIONS TO REQUESTS FOR PRODUCTION
Subject to and without waiver of the foregoing General Objections, Petitioner responds to
Registrant’s specific Requests for Production of Documents and Things as follows:
DOCUMENT REQUEST NO. 1:
All documents and things requested to be identified by “Registrant’s Interrogatories to
Petitioner” served concurrently herewith.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence.
DOCUMENT REQUEST NO. 2:
The Petitioner’s Financial Statements for the last six (6) years. The Petitioner’s audited
Financial Statements are preferably audited and in accordance with accounting principles
generally accepted in the United States of America.

3
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, Petitioner’s financial statements
have no bearing on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 3:
All documents showing, concerning, evidencing, relating, without limitation, any
documentation of meetings or discussions about Registrant’s ALISHAN MARK.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically,
Petitioner’s discussions and/or documents concerning Registrant’s mark, if any, have no bearing
on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 4:
All documents showing, concerning, evidencing, relating, without limitation, any
documentation of meetings or discussions about Registrant’s ALISHAN MARK after Petitioner
reads, understands, and acknowledges Registrant’s website at http://www.superteastore.com.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically,
Petitioner’s discussions and/or documents concerning Registrant’s mark and/or use or lack
thereof, if any, have no bearing on this proceeding and are therefore irrelevant.

4
DOCUMENT REQUEST NO. 5:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests all
documents showing, concerning, evidencing, relating or referring to Petitioner’s selection,
design and adoption of ALISHAAN including, without limitation, any documentation of
meetings or discussions held concerning the selection, design and adoption of ALISHAAN, any
documentation relating to the reasons for selecting ALISHAAN, and any documentation
concerning the consideration and rejection of using ALISHAAN in the United States of
America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically, the
similarity of Registrant’s and Petitioner’s marks, if any, is not at issue in this proceeding,
therefore documents concerning Petitioner’s selection of the ALISHAAN mark have no bearing
on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 6:
A sample, copy, photograph, illustration, sketch of other depiction of each different
logotype, design, font of type or style in which ALISHAN or ALISHAAN or any variation
thereof has been or now is being used by Petitioner in the United States of America
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, documents concerning Petitioner’s
depiction of the ALISHAAN mark have no bearing on this proceeding and are therefore
irrelevant.

5
DOCUMENT REQUEST NO. 7:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide documents sufficient to show the names, titles and addresses of each and
every person who participated in the Petitioner’s selection, design and adoption of ALISHAAN
including, specifically, the name(s) of the person and persons who first suggested that Petitioner
adopts and uses the subject ALISHAAN for each of Petitioner’s goods and services in the
United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically, the
similarity of Registrant’s and Petitioner’s marks is not at issue in this proceeding, therefore
documents concerning Petitioner’s selection of the ALISHAAN mark have no bearing on this
proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 8:
All documents showing, concerning, evidencing, relating, of referring to any searches,
investigations or any other inquiries, whether formal or informal, conducted by Petitioner
relating to whether or not ALISHAN and/or ALISHAAN or any mark or name incorporating the
word ALISHAN and/or ALISHAAN alone or as part thereof was available for use with respect
to any mark, trade names, corporate names or other users by others in the United States of
America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically,
documents concerning any “searches, investigations or any other inquiries” conducted by
Petitioner, if any, have no bearing on this proceeding and are therefore irrelevant.

6
DOCUMENT REQUEST NO. 9:
All documents showing, concerning, evidencing, relating, or referring to the production
of Petitioner’s goods including, without limitation, documentation identifying every place of
business where Petitioner’s goods are produced and documentation of the total volume of sales
in units and the equivalent dollar value in the United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, documents concerning the
production of Petitioner’s goods have no bearing on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 10:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide all documents and things ever used by Petitioner or used on behalf of
Petitioner to advertise or promote the goods which bear ALISHAAN, including, without
limitation, flyers, periodicals, newspapers, telephone directory listings, video tapes, television
scripts, audio discs, displays, promotional brochures, catalogs and outdoor window signs in the
United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically, the
similarity of Registrant’s and Petitioner’s marks is not at issue in this proceeding, therefore
documents concerning Petitioner’s sales and marketing efforts are irrelevant to this proceeding.
DOCUMENT REQUEST NO. 11:
All documents showing, concerning, evidencing, relating or referring to the organization
and implementation of the Petitioner’s advertising program, including without limitation,
documents identifying: (a) the date, (b) the place, (c) the monetary amount expended, (d) the
class of customers to whom the advertising or promotional materials were (or are) directed, (e)
the number of copies of such materials and (f) the names and addresses of each person,
advertising agency, public relations firm or any other business entity hired or retained in
connection with such advertisements in the United States of America.
7
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, documents concerning Petitioner’s
“advertising program” have no bearing on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 12:
All documents showing, concerning, evidencing, relating or referring to any trade show
or similar function in which Petitioner exhibited or showed its goods in the United States of
America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, documents concerning Petitioner’s
participation in trade shows or exhibitions, if any, have no bearing on this proceeding and are
therefore irrelevant.
DOCUMENT REQUEST NO. 13:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide all documents including invoices, showing, concerning, evidencing,
relating or referring to ALISHAAN appearing on each of Petitioner’s goods in the United States
of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically, the
similarity of Registrant’s and Petitioner’s marks is not at issue in this proceeding, therefor any
“invoices, showing, concerning, evidencing, relating or referring to ALISHAAN appearing on
each of Petitioner’s goods in the United States of America” have no bearing on this proceeding
and are therefore irrelevant.
8
DOCUMENT REQUEST NO. 14:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide a sampling of invoices showing that Petitioner has used of ALISHAAN on
each of Petitioner’s goods in commerce in the United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, the similarity of Registrant’s and
Petitioner’s mark is not at issue in this proceeding, therefor any “invoices showing that Petitioner
has used of ALISHAAN on each of Petitioner’s goods in commerce in the United States of
America” have no bearing on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 15:
Documents sufficient to show any principal agents, distributors and/or retailers of
Petitioner’s goods for the last six (6) years in the United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, documents “sufficient to show any
principal agents, distributors and/or retailers of Petitioner’s goods” have no bearing on this
proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 16:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide all documents showing, concerning, evidencing, relating, or referring to
Petitioner’s permission to any other company, agent or other person in the United States of
American to use ALISHAAN or a word or mark including ALISHAN and/or ALISHAAN as a
part thereof or in combination with another word, including, without limitation all
documentation identifying: (a) the name of such company, agent or person; (b) the date of such
use; and (c) the goods or services used by such company, agent or person and any such
documents which refer to any other company, agent or other person giving Petitioner permission
to use its MARKS or a word or mark including ALISHAN and/or ALISHAAN as a part thereof
or in combination with another word.

9
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically, the
similarity of Registrant’s and Petitioner’s marks is not at issue in this proceeding, therefore
documents concerning agreements between Petitioner and any third parties, if any, have no
bearing on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 17:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide all documents showing, concerning, evidencing, relating, or referring to
any assignment or license of ALISHAAN, including, without limitation, all documentation
identifying: (a) the date of such assignment or license; (b) the name and address of the assignee
and the assignor (or licensee and licensor); (c) any record of such assignment or license in the
United States Patent and Trademark Office or other public place; and the terms and conditions
of agreement.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically, the
similarity of Registrant’s and Petitioner’s marks is not at issue in this proceeding, therefor any
“documents showing, concerning, evidencing, relating, or referring to any assignment or license
of ALISHAAN” by Petitioner, if any, have no bearing on this proceeding and are therefore
irrelevant.
DOCUMENT REQUEST NO. 18:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide a sample, copy, photograph, illustration, sketch or other depiction of each
label, tag, container, stencil, package, price list and display which are or have ever been used in
connection with goods bearing ALISHAAN in the United States of America.

10
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, the similarity of Registrant’s and
Petitioner’s marks is not at issue in this proceeding, therefor any depictions of Petitioner’s
ALISHAAN mark in connection with its goods have no bearing on this proceeding and are
therefore irrelevant.
DOCUMENT REQUEST NO. 19:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide all documents showing, concerning, evidencing, relating, or referring to (a)
the date when used of each item sold under ALISHAAN commenced; (b) the type of goods on
or in connection with ALISHAAN are used; (c) the party who designed each item; (d) and the
date each item was produced in the United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, the similarity of Registrant’s and
Petitioner’s marks is not at issue in this proceeding, therefor any documents concerning sales
made under the ALISHAAN mark by Petitioner have no bearing on this proceeding and are
therefore irrelevant.
DOCUMENT REQUEST NO. 20:
As ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide all documents showing, concerning, evidencing, relating, or referring to
Petitioner’s knowledge of any third party’s part of current use or registration of and
ALISHAAN or a mark or term which includes the word ALISHAN and/or ALISHAAN or the
mark or use which Petitioner consider an alleged imitation of its MARKS on any goods or
services in the United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
11
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically, the
similarity of Registrant’s and Petitioner’s marks is not at issue in this proceeding, therefor any
documents concerning “Petitioner’s knowledge of any third party’s part of current use or
registration” of the ALISHAAN or similar mark have no bearing on this proceeding and are
therefore irrelevant.
DOCUMENT REQUEST NO. 21:
AS ALISHAAN is similar to Registrant’s ALISHAN MARK, Registrant requests
Petitioner to provide all documents showing, concerning, evidencing, relating, or referring to
any infringement action or other proceeding in the United States Patent and Trademark Office
(or any count) which has ever been brought by or against the Petitioner for the use of
ALISHAAN or what it has asserted to be a colorable imitation thereof in the United States of
America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically, the
similarity of Registrant’s and Petitioner’s marks is not at issue in this proceeding, therefor any
documents concerning “any infringement action or other proceeding” brought against Petitioner
have no bearing on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 22:
All documents showing, concerning, evidencing, relating, or referring to any discussions,
negotiations, or settlements entered into by Petitioner with any other party in regard to the
adoption, use, or registration of ALISHAN, ALISHAAN or any other mark which Petitioner has
asserted to be a colorable imitation thereof in the United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically,
12
documents concerning “any discussions, negotiations, or settlements entered into by Petitioner
with any other party” have no bearing on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 23:
Provide documents sufficient to show the name and business address of each of the
officers and directors of Petitioner for the past ten (10) years, and as to each state the office or
offices held and the period of time during which each office was held (or in lieu thereof a listing
of the same).
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, documents concerning Petitioner’s
officers and directors have no bearing on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 24:
All documents showing, concerning, evidencing, relating, or referring to Petitioner’s
acquired knowledge of Registrant’s ALISHAN MARKS and all documents surrounding the
acquisition of such knowledge.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically,
documents concerning “Petitioner’s acquired knowledge of Registrant’s” marks have no bearing
on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 25:
All documents which show that Petitioner has a bona fide intention to use ALISHAN
and /or ALISHAAN marks.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
13
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically,
documents concerning Petitioner’s intent to use the ALISHAAN or similar marks have no
bearing on this proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 26:
All documents which refer or related to or comment on Petitioner’s knowledge or
awareness of the use of the trademark ALISHAN by Registrant.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically,
documents concerning Petitioner’s knowledge of Registrant’s mark have no bearing on this
proceeding and are therefore irrelevant.
DOCUMENT REQUEST NO. 27:
All documents showing, concerning, evidencing, relating, or referring to any survey
which has ever been conducted by the Petitioner relating to whether there is or may be any
likelihood of confusion between Registrant’s MARKS and any mark or name used by Registrant.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically,
documents concerning any survey conducted by Petitioner, if any, have no bearing on this
proceeding and are therefore irrelevant.

14
DOCUMENT REQUEST NO. 28:
Provide copies of all registration and pending or lapsed applications, federal, state, and
foreign owned for the benefit or in the name of or filed on behalf of Petitioner.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, documents concerning Petitioner’s
trademarks registrations and/or applications, if any, have no bearing on this proceeding and are
therefore irrelevant.
DOCUMENT REQUEST NO. 29:
Documents sufficient to show all the goods or services which have been sold, advertised,
and/or distributed under Petitioner’s any word which includes the word ALISHAN,
ALISHAAN and/or predecessors in interest of the Petitioner and/or licensees of Petitioner
including, where available specimens of such goods and literature describing the services in the
United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, documents concerning Petitioner’s
use of the ALISHAAN, or similar, marks have no bearing on this proceeding and are therefore
irrelevant.
DOCUMENT REQUEST NO. 30:
All documents showing, concerning, evidencing, relating, or referring to any market
research conducted by Petitioner concerning Registrant’s ALISHAN MARKS or similar Marks,
including, without limitation, all documentation identifying: (a) the location and the date of such
research; (b) the person who conducted the research; and (c) the results of the research in the
United States of America.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that this
15
request fails to designate the documents to be produced with reasonable particularity. Petitioner
objects to the extent the request seeks the production of documents that are not relevant or likely
to lead to the discovery of admissible evidence. Specifically, documents concerning market
research conducted by Petitioner, if any, have no bearing on this proceeding and are therefore
irrelevant.
DOCUMENT REQUEST NO. 31:
(a) All documents showing, concerning, evidencing, relating, or referring to any and all
statements and/or opinions of any person, other than any attorney rendering legal advice to
Petitioner, regarding any of the issues involved in this cancellation procedure.
(b) All documents showing, concerning, evidencing, relating, or referring to the
statements and/or opinions referred to in (a) above
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence.
DOCUMENT REQUEST NO. 32:
Copies of all agreement, contracts or other arrangements between Petitioner and any third
party which refer or relate to or comment on Petitioner’s right to Petitioner’s MARKS or any
MARK which incorporate the word ALISHAN and/or ALISHAAN.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence. Specifically,
documents concerning arrangements between Petitioner and any third parties concerning
Petitioner’s rights in the ALISHANN or similar marks, if any, have no bearing on this
proceeding and are therefore irrelevant.

16
DOCUMENT REQUEST NO. 33:
With respect to each document or thing which is withheld from production, whether
under a claim or privilege or otherwise, and which is otherwise responsive to any of the
production requests, provide: (a) the date, identity, and general subject matter of such document
or thing; (b) the grounds asserted in support of the failure to produce such document or thing; (c)
the identity of each person (other than stenographic or clerical assistants) participating in the
preparation of such document or thing; (d) the identity of each person to whom the contents of
such document or thing were communicated by copy, distribution, reading or substantial
summarization; (e) a description of any document or thing or other material transmitted with or
attached to such document or thing; (f)the number of pages in such document; (g) the particular
request to produce to which such document or thing is responsive; and (h) whether any business
or non-legal matter is contained or discussed in such document or thing.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence.
DOCUMENT REQUEST NO. 34:
All documents, other than those produced in response to any of the forgoing requests,
upon which Petitioner intends to rely in connection with this cancellation proceeding.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague, ambiguous,
and not reasonably specific. Petitioner further objects that the request is overbroad and without
reasonable limitation in scope or time frame. Petitioner further objects that the request seeks
information that is protected from disclosure by the attorney-client privilege, the attorney work
product doctrine and/or the joint interest or joint defense privilege. Petitioner further objects that
this request fails to designate the documents to be produced with reasonable particularity.
Petitioner objects to the extent the request seeks the production of documents that are not
relevant or likely to lead to the discovery of admissible evidence. Applicant further objects to
this request on the ground that the request seeks information and documents equally available to
the propounding parties from their own records or from records which are equally available to
the propounding parties.
DOCUMENT REQUEST NO. 35:
All documents, other than those produced in response to any of the forgoing requests,
which were examined, reviewed or inspected by Petitioner or any person acting for on behalf of
17
Petitioner in connection with the preparation of Petitioner’s responses to REGISTRANT’S
INTERROGATORIES TO PETITIONER.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence.
DOCUMENT REQUEST NO. 36:
With respect to each document or thing otherwise responsive to any request to produce
which has been lost or destroyed since its preparation or receipt, identify the document or thing,
state the request to produce to which it would have been responsive, and give the full particulars
or circumstances whereby the document or thing was lost or destroyed.
RESPONSE
Petitioner objects to this request as it is overly broad, unduly burdensome, vague,
ambiguous, and not reasonably specific. Petitioner further objects that the request is overbroad
and without reasonable limitation in scope or time frame. Petitioner further objects that the
request seeks information that is protected from disclosure by the attorney-client privilege, the
attorney work product doctrine and/or the joint interest or joint defense privilege. Petitioner
further objects that this request fails to designate the documents to be produced with reasonable
particularity. Petitioner objects to the extent the request seeks the production of documents that
are not relevant or likely to lead to the discovery of admissible evidence.
Respectfully submitted,
Dated: Oct. 20, 2016

By: /s/ Mike Rodenbaugh

Mike Rodenbaugh
RODENBAUGH LAW
548 Market Street
Box No. 55819
San Francisco, CA 94104
Telephone: (451) 738-8087
Email: mike@rodenbaugh.com

Attorney for Petitioner
18
CERTIFICATE OF SERVICE

I hereby certify that a true and complete copy of the foregoing PETITIONER’S
RESPONSES TO REGISTRANT’S FIRST SET OF REQUESTS FOR PRODUCTION OF
DOCUMENTS AND THINGS was served by U.S. first class mail and email on this 20th day of
October 2016, upon the following:

Registrant’s Attorney of Record
Chi Liu
Evory Technologies, Inc.
1270 N. Marine Corp. Dr. Ste. 101-397
Tamuning, GU 96913-4331
United States

Dated: Oct. 20, 2016
Respectfully submitted,
By: /s/ Mike Rodenbaugh
Marie Richmond
Rodenbaugh Law
548 Market Street
San Francisco, CA 94104
Tel: (415) 738-8087
California Bar No. 292962

Exhibit AL

Exhibit AM
Exhibit AM was submitted to the Confidential Defendant’s Supporting Evidents/Exhibits.
Exhibit AN

Exhibit AO

Exhibit AP

Exhibit AQ

Exhibit AR

Exhibit AS
Exhibit AS was submitted to the Confidential Defendant’s Supporting Evidents/Exhibits.
Exhibit AT
eBay/PayPal Law Enforcement Guide
eBay, Inc., has established a Fraud Investigations Team (FIT) to promote safe use of our platforms and encourage
prosecution of those responsible for misconduct on them. Law enforcement agencies in North America seeking
assistance and records for investigations that relate to either the eBay or PayPal should use the Frequently Asked
Questions below as guidance in how FIT can assist in these investigations.

Q. What investigative tools are available on the public ebay.com site?

Search by seller ID for 30 days of active/completed sales: http://pages.ebay.com/search/items/search_seller.html

Search for active listings using search string or specific item number. Ability to search by nearest zip code using search
options on left hand column: http://pages.ebay.com/search/items/basicsearch.html

Feedback Profile reflects comments made by other users regarding prior transactions

Create your own Favorite Searches: http://pages.ebay.com/help/find/search_favorites.html

Create your own department/agency eBay account at eBay.com. http://pages.ebay.com/help/newtoebay/durreg_ov.html
Please do not bid or purchase unless you plan to follow through and pay for the item

Q. Can eBay help me search for a Stolen Item?
A. eBay now makes listing and member information immediately available to law enforcement via Leadsonline’s First
Responder Service. See Section A on the next page for more details.
Please note eBay/PayPal FIT is unable to perform any specialized internal searches for items - only users.

Q. How can I acquire BOTH eBay and PayPal records for the same case?
A. You may send in a single subpoena, court order, legal process for this information. This Subpoena must be
addressed to eBay AND PayPal and must include all suspect data referenced in Sections C and D on Page Two of this doc.

Q. What information must I submit to acquire records?
A. In most cases, we require a minimum of name, email address and User Name (for eBay investigations) to locate the
correct account. Please provide as much information on your subject as possible to assist us in searching for records of over
200 million users. Please reference Page Two of this document for specific guidance on releasing data.
-- In addition, we require you provide your full contact details including name, e-mail address, agency, phone/fax numbers
and physical address (no P.O. Boxes). For faster delivery of your records, please include your email address.

Q. Where do I send my formal data request?
A. Please address your data request to eBay/PayPal Fraud Investigations Team and send via Fax: 408.967.9915. Please
only mail data requests if you do NOT have access to a fax machine: 2211 North First Street, San Jose, CA 95131.

Q. How and when will the data be returned?
A. eBay and PayPal provide all records electronically, via secure website or via CD Rom via Fed Ex Ground (For faster
service please provide agency Fed Ex account number and specify delivery timeframe). Please be sure to provide your
email address in your data inquiry. Please reference Page Two for turnaround time estimates.

Q. Does eBay/PayPal supply all accounts linked/related to my subject?
A. Please inform us in your data request if linked/ related accounts are required. Due to our privacy agreement with our
users, we must use strict standards when making this determination. Our common linkage criteria includes financial
instruments and identical registration data.

Q. How long do eBay and PayPal retain records?
A. eBay keeps most account records indefinitely and most transaction records for two years. Records may not be
available for Inactive or closed accounts. PayPal currently keeps all records indefinitely

Q. Does eBay/PayPal inform the subject of my investigation of my query?
A. eBay/PayPal does not disclose inquiries to the account holder

Q. How can I follow up on a query already submitted?
A. If you do not have the FIT Analyst/Investigator’s direct line or email, please leave a message on our help line
(408.967.9919) and somebody will return your call within 24 hours.

If your specific question is not answered above, please contact FIT directly for information by phone
(408.967.9919 - automated message only). All calls are returned within ONE business day.
A. eBay User Contact Details
New From eBay --- First Responder Service via LeadsOnline eBay has
eBay/PayPal Law Enforcement Guide
partnered with L.e.a.d.s.online to make certain listings and eBay user data available to law enforcement immediately to assist in
their investigations. These services are available 24/7 to registered L.e.a.d.s.online customers. L.e.a.d.s.online offers two
separate services to assist law enforcement in eBay Investigations: eBay site search and Internet (eBay) Drop-Off Store Search. Visit
www.leadsonline.com for more information. Turnaround Time: Immediate.

B. eBay User Contact Details and limited transaction history (12 months maximum)
Please submit a signed fax (non-subpoena) on department letterhead stating specifically what you require. eBay can
provide the following information for users under investigation of illegal activity only:
• Contact Name, City, State, Zip, and Telephone Number
• All email addresses and eBay User ID’s added to account with date/time stamps
• eBay Fraud complaints (*If Requested)
• Account listing/bid history dating back one year (*If Requested)
To assist us in searching for records, the following data must be included in your data request (if available):
- All known names, aliases, street addresses, email addresses, and phone numbers
- Known eBay ID(s) and Item Numbers
- Statement relating to the illegal nature of the activities being investigated
Please fax data request to: Fax: 408.967.9915 Turnaround Time: Typically within 15 business days

C. All Records relating to an eBay user
Please submit a subpoena, court order, or other legal process stating specifically what you require. We can provide:

Full eBay Contact Details, including the billing and mailing address

eBay IP addresses: time of registration and at time of item listing

Complete Listing and/or bid history – 2 yr max (including bidder information if specifically requested)

Credit card and checking account information added to eBay account (if available)
To assist us in searching for records, the following data must be included in your data request (if available):
- Full name of the subject, and any known aliases
- All known addresses, including email addresses, and phone numbers
- Known eBay ID(s) and Item Numbers
**If you require the related PayPal records, please address your Subpoena to EBAY AND PAYPAL and include all
available PayPal details outlined in Section D below.
Please fax data request to: Fax: 408.967.9915 Turnaround Time: Typically within 10 business days

D. All Records relating to a PayPal user -- Please note all PayPal records require a subpoena.
Please submit a subpoena, court order, or other legal process stating specifically what you require. We can provide:
• All PayPal account information including, SSN*, names, addresses, phone numbers, email addresses
• PayPal IP addresses (at each login)
• Financial instruments added to PayPal account
• Complete PayPal transactional information (including complaints if requested and available)
To assist us in searching for records, the following data must be included in your data request (if available):
- Full name of the subject, and any known aliases, and known email addresses
- All known financial instruments and any transaction details linked to the relevant PayPal activity
**If you require the related eBay records, please address your Subpoena to EBAY AND PAYPAL and include all
available eBay details outlined in Section C above. * If applicable
Please fax data request to: Fax: 408.967.9915 Turnaround Time: Typically within 10 business days

Exhibit AU