Threshold Enterprises Ltd.v.Renew Life Formulas, Inc.

Trademark Trial and Appeal Board

Jun 19, 2015

No. 91200928 (T.T.A.B. Jun. 19, 2015)

Mailed: June 19, 2015

UNITED STATES PATENT AND TRADEMARK OFFICE
_____

Trademark Trial and Appeal Board
_____

Threshold Enterprises Ltd.
v.
Renew Life Formulas, Inc.
_____

Opposition No. 91200928
_____

Erica Connolly and Monty Agarwal of Arnold & Porter LLP, for Threshold
Enterprises Ltd.

James B. Lake, James J. McGuire, and Mark R. Caramanica of Thomas &
Locicero PL, for Renew Life Formulas, Inc.
_____

Before Wellington, Ritchie, and Kuczma, Administrative Trademark Judges.

Opinion by Ritchie, Administrative Trademark Judge:

On January 10, 2011, Renew Life Formulas, Inc. (“Applicant”) applied to
register ARCTIC NATURALS, in standard character form, for “naturally
derived dietary and nutritional supplements,” in International Class 5.”1 On
July 28, 2011, Threshold Enterprises, Ltd. (“Opposer”), filed an opposition to
the registration of Applicant’s mark on the ground that Applicant’s mark is
1 Application Serial No. 85214143, filed under Section 1(b), and disclaiming the
exclusive right to use the term “NATURALS” apart from the mark as shown.
THIS OPINION IS NOT A
PRECEDENT OF
THE T.T.A.B.

Opposition No. 91200928
likely to cause confusion with Opposer’s marks. Opposer asserted in its
Notice of Opposition, that it owns the mark SOURCE NATURALS in typed
drawing format2 for “vitamins, herbs and nutritional supplements,” in
International Class 53 and in standard character format for “cosmetics,
namely, ointments, gels, creams, lotions, moisturizers, oils, serums, salves
and bath oils, all of which are used for the skins,” in International Class 3,4
as well as the mark ARCTICPURE, in standard character format, for
“dietary supplements,” in International Class 5.5 Opposer argues that it uses
the two marks SOURCE NATURALS and ARCTICPURE conjointly, and as
such, Applicant’s mark ARCTIC NATURALS is confusingly similar thereto,
or in the alternative that Applicant’s mark is confusingly similar to Opposer’s
ARTICPURE mark.6
In its Answer, Applicant denied the salient allegations of the Notice of
Opposition. Applicant also asserted various affirmative defenses, including:
“Numerous third parties use the term NATURALS or ARCTIC in connection
2 “Prior to November 2, 2003, ‘standard character’ drawings were known as ‘typed’
drawings. The mark on a typed drawing was required to be typed entirely in capital
letters. A typed mark is the legal equivalent of a standard character mark.” TMEP
§ 807.03(i) (January 2015).
3 Registration No. 1909705, registered August 8, 1995. Sections 8 and 15 affidavits
accepted and acknowledged. Renewed.
4 Registration No. 3930397, registered March 15, 2011, and disclaiming the exclusive
right to use the term “NATURALS” apart from the mark as shown.
5 Registration No. 3203797, registered January 30, 2007. Sections 8 and 15 affidavits
accepted and acknowledged.
6 Although the assertion of conjoint use was not expressly pleaded in the Notice of
Opposition, it was discussed in the testimony and other documents submitted during
the parties’ trial period, and it was argued in substance by both parties on brief.
Accordingly, we deem the pleadings amended to assert both bases. Fed. R. Civ. P.
15(b).
2

Opposition No. 91200928
with a wide variety of goods, including goods similar to Threshold’s and
Renew Life’s.” (Answer at Affirm. Def. No. 3; 5 TTABVUE 4).
Both parties filed briefs, and Opposer filed a reply brief.
The Record
The record consists of the pleadings; the file of the involved application;
and the following evidence submitted by the parties:
By Opposer:
1. The testimonial declaration of Barry Sugarman, consultant to
Opposer’s President, dated January 19, 2014;7

2. Opposer’s Notice of Reliance on May 22, 2013 discovery depositions for
Don Pollo, Applicant’s Chief Financial Officer; and Stan Watson,
Applicant’s Chief Executive Officer;

3. Opposer’s Notice of Reliance on April 19, 2013 discovery depositions for
Barry Sugarman, Opposer’s Consultant to the President, and Ira
Goldberg, Opposer’s Chief Executive Officer;

4. Opposer’s Notice of Reliance on written discovery responses from
Applicant;

5. Opposer’s Notice of Reliance on registration documents;

6. Opposer’s Notice of Reliance on official records (Complaint in Renew
Life v. Nordic Naturals, Inc., Case No. 12-cv-449 (M.D. Fla));

7. Opposer’s Notice of Reliance on request for judicial notice (dictionary
definitions);

7 The parties filed two stipulations regarding the submission of evidence, on
December 12, 2013, and January 21, 2014, in which they agreed that testimony may
be introduced “by sworn declaration in lieu of live deposition-subject to objection, as
well as to live cross examination” as well as that “discovery depositions of a witness
may be offered as testimony.” 38 TTABVUE 3-4. The parties further stipulated that
a “party may introduce as evidence, and rely on at trial, document or things [sic] it
produced in discovery by Notice of Reliance alone without further evidence of
authentication.” 46 TTABVUE 3.
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Opposition No. 91200928
8. Opposer’s Notice of Reliance on Internet materials; and

9. Opposer’s Notice of Reliance on Applicant’s responses to discovery.

By Applicant:
1. Applicant’s Notice of Reliance on documents produced in response to
third party subpoenas.

2. Applicant’s Notice of Reliance on discovery responses from Opposer;

3. Applicant’s Notice of Reliance on the prosecution history of the
application that issued as 3930397;

4. Applicant’s Notice of Reliance on online publications, parts 1 and 2;

5. Applicant’s Notice of Reliance on the testimony declaration of Stan
Watson, Executive Chair of Applicant, dated March 24, 2014;

6. Applicant’s Notice of Reliance on May 22, 2013 discovery depositions of
Pollo and Watson; and

7. Applicant’s Notice of Reliance on April 19, 2013 discovery depositions
of Sugarman and Goldberg.

Priority and Standing
Standing is a threshold issue that must be proven in every inter partes
case. See Lipton Industries, Inc. v. Ralston Purina Co., 670 F.2d 1024, 213
USPQ 185, 189 (CCPA 1982) (“The facts regarding standing . . . must be
affirmatively proved. Accordingly, [plaintiff] is not entitled to standing solely
because of the allegations in its [pleading].”). To establish standing in an
opposition, opposer must show both “a real interest in the proceedings as well
as a ‘reasonable’ basis for his belief of damage.” See Ritchie v. Simpson, 170
F.3d 1092, 50 USPQ2d 1023, 1025 (Fed. Cir. 1999).
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Opposition No. 91200928
Opposer’s witness Barry Sugarman, consultant to the president for
twenty years, who oversees trademark matters for Opposer, offered
testimony regarding Opposer’s continuing use of the marks SOURCE
NATURALS and ARCTICPURE. See Sugarman decl. 49 TTABVUE 3. He
further states that ARCTICPURE is used “for fish oil products,” and has been
since 2001. Id., and Ex. D (showing the label). The declaration further attests
to use of SOURCE NATURALS on dietary supplements, since at least 1987.
See Id. at Ex. C. Based on this testimony, we find that Opposer has shown a
sufficient basis for standing.8 See Cunningham v. Laser Golf Corp., 222 F.3d
943, 55 USPQ2d 1842, 1844 (Fed. Cir. 2000).
The dates of use attested to by Opposer predate any dates of use claimed
by Applicant, which states that it first used the ARCTIC NATURALS mark
in or about January 2012. See Appl’s Response to Interrogatory No. 1; See
also Watson discovery depo. 62 TTABVUE 77.
Applicant argues that Opposer does not have standing in this action,
based on a statement made by Barry Sugarman during his discovery
deposition, as follows: “And we believe Arctic Naturals isn’t a threat to our
8 Opposer also submitted copies of its pleaded registrations. However, these are not
“status and title” copies as required by Trademark Rule 2.122(d), and thus Opposer
cannot rely on them to establish its standing or remove priority as an issue with
respect to the marks and goods covered by the registrations. No witness testified as
to the status and title of the pleaded registrations.
5

Opposition No. 91200928
intellectual property and our business.”9 63 TTABVUE 21. We note, however,
that the very next sentence is:
We graded it as a higher risk to us in overall impression, in the
usage of components of two of our marks. In the way that the
style of the bottle is and the way the styles of the mark is and
based on what our – how we sell our products. All of those
things pointed to us that it would be a higher risk.
Id.

Furthermore, elsewhere in his discovery deposition, Mr. Sugarman
attested to his concerns about Applicant’s use of the ARCTIC NATURALS
mark:
Q: I guess what I would like to know having gone through these
agreements why your company has a problem with Arctic
Naturals given that you have permitted other people to use
Natural Sources, Natural Source, and and [sic] not objected to
anyone using Arctic.

A: Well, it’s the overall – the overall case as a whole. Number
one, we view the combination of your Arctic mark, Arctic
Naturals, as something that would be confusingly similar. We
think the trade dress is similar, we think Renewed life is
potential threat [sic] into our marketplace and that they would –
that there would be a substantial likelihood of confusion with
those marks.
So we graded it as a much higher risk than anything I
have seen today.. . . And the usage of the mark appears to be a
direct threat and a higher risk for us of confusion and risk in the
marketplace for us. So that’s why we have taken the position
that we have taken.
Id. at 19.

9 Opposer later filed a “Request for Leave to Correct Errors in Deposition
Transcript,”arguing that “Mr. Sugarman either misspoke or his testimony was not
properly transcribed.” 81 TTABVUE 4. Given our finding on standing, the request
for leave to correctis moot.
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Opposition No. 91200928
Notwithstanding the one statement by Mr. Sugarman in his deposition,
we find that based on the evidence and testimony of record, Opposer has
shown a reasonable belief of damage and has established its priority for “fish
oil products.”
Likelihood of Confusion
Our determination under Section 2(d) is based on an analysis of all of the
relevant, probative evidence in the record related to a likelihood of confusion.
See In re E. I. du Pont de Nemours & Co., 476 F.2d 1357, 177 USPQ 563
(CCPA 1973); see also Palm Bay Imports, Inc. v. Veuve Clicquot Ponsardin
Maison Fondee En 1772, 396 F.3d 1369, 73 USPQ2d 1689 (Fed. Cir. 2005); In
re Majestic Distilling Company, Inc., 315 F.3d 1311, 65 USPQ2d 1201 (Fed.
Cir. 2003); and In re Dixie Restaurants Inc., 105 F.3d 1405, 41 USPQ2d 1531
(Fed. Cir. 1997). In any likelihood of confusion analysis, two key
considerations are the similarities between the marks and the similarities
between the goods and services. See Federated Foods, Inc. v. Fort Howard
Co., 544 F.2d 1098, 192 USPQ 24, 29 (CCPA 1976) (“The fundamental inquiry
mandated by § 2(d) goes to the cumulative effect of differences in the
essential characteristics of the goods and differences in the marks.”). We
discuss the du Pont factors for which there is relevant argument and
evidence. The others we consider to be neutral.
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Opposition No. 91200928
Conjoint Use of the Marks
Opposer argues that in analyzing the similarity or dissimilarity of the
marks, “the Board should consider Threshold’s SOURCE NATURALS and
ARCTICPURE marks conjointly rather than separately.” 76 TTABVUE 17.
In evaluating the propriety of viewing marks conjointly, we look to two key
factors: First, whether the marks are “used together on a single product or in
marketing;” and second whether they “have been used and/or advertised
conjointly in such a manner and to such an extent in connection with a single
product that they have come to be associated together, in the minds of the
purchasing public, as indications of origin for opposer’s product.” Schering-
Plough HealthCare Products Inc. v. Ing-Jing Huang, 84 USPQ2d 1323, 1326
(TTAB 2007) (finding DR. SCHOLL’S and AIRPILLO used conjointly such
that DR. PILLO likely to cause confusion).
In Schering-Plough, the Board stated that the first element is satisfied
where opposer “routinely uses” the two marks together. Id. Opposer has used
SOURCE NATURALS since 1982 and ARCTIC PURE since 2001. See
Sugarman decl., 49 TTABVUE 3. Mr. Sugarman further attested “From the
time that the ARCTICPURE mark was first used until the present, it has
never appeared on goods without the SOURCE NATURALS mark also
present.” Id. In other testimony, Mr. Sugarman stated that SOURCE
NATURALS is the brand name for “an entire product line” while
ARCTICPURE is a subline, and also a product.” 42 TTABVUE 13. However,
8
Opposition No. 91200928
as discussed below, there is not evidence of such level of sales and marketing
that consumers have been exposed to “routine use” of them together.
Accordingly, we do not find the first element to be satisfied.
As to the second element, Schering-Plough found it to be satisfied where
opposer had undertaken “great expense in advertising the marks together,”
noting that the decision was largely based on “the fame of opposer’s marks.”
Schering-Plough Healthcare Products Inc. v. Ing-Jing Huang, 84 USPQ2d at
1327. Here, by contrast, we note that while the numbers for SOURCE
NATURALS are more significant, we do not find that there has been an
extensive amount of advertising or sales for Opposer’s ARCTICPURE.10
Without significant use together, we do not find that Opposer’s marks satisfy
the second requirement that they “have been used and/or advertised
conjointly in such a manner and to such an extent in connection with a single
product that they have come to be associated together, in the minds of the
purchasing public, as indications of origin for opposer’s product.” Id. See also
Parke, Davis & Co v. The G.F. Harvey Co., 60 USPQ 572 (CCPA 1944)
(DIGISEALS similar to opposer’s two marks KAPSEALS and DIGIFORTIS
because “opposer was using both well-known marks combined.”); H.D.
Hudson Manufacturing Co. v. Food Machinery and Chemical Corp., 230 F.2d
445. 109 USPQ 48 (CCPA 1956) (ROTOMIST not similar to opposer’s ROTO-
POWER and MISTY marks because “Here appellant has not used its marks
10 The numbers are in the confidential record. See 44 Conf TTABVUE 28, Ex 6; 50
Conf TTABVUE 2-3, and Ex. H.
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Opposition No. 91200928
‘Roto-Power’ and ‘Misty’ combined as one mark”); Sperry Rand Corp. v.
Remvac Systems Corp., 172 USPQ 415 (TTAB 1971) (REMVAC found
confusingly similar to oppposer’s conjointly used REMINGTON and
UNIVAC).
Because we find that Opposer has not satisfied the necessary elements,
we will not consider the marks conjointly in our analysis, but will proceed on
Opposer’s alternative basis, claiming likelihood of confusion as to its
ARCTICPURE mark.
Goods and Channels of Trade
There is no dispute that the goods at issue in this dispute are legally
identical, since Opposer has established rights in ARCTICPURE for “fish oil
products” and Applicant seeks to register ARCTIC NATURALS for “naturally
derived dietary and nutritional supplements,” which encompasses fish oil
supplements.
As for channels of trade, Opposer has established via testimony that it
sells its ARCTICPURE “fish oil products” via various means, including to
“Internet customers, Internet retailers” as well as “brick-and-mortar health
food stores, health food chain stores” and to “some distributors who sell to
practitioners.” 42 TTABVUE 13. Opposer also provided more particular
testimony on the confidential record regarding its distribution means.
Applicant attests to selling to only one customer, Walgreens. 40 TTABVUE
20. Although it appears that the channels of trade do not currently overlap,
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Opposition No. 91200928
Applicant’s application is not limited in the potential channels of trade, and
could overlap with those identified as being used by Opposer. Accordingly, we
find these du Pont factors to weigh strongly in favor of a finding of likelihood
of confusion.
The ARCTICPURE Mark
Initially we note that where the goods are identical or identical-in-part, as
they are here, the degree of similarity between the marks which is required
to support a finding of likelihood of confusion is less than if the goods were
not identical. In re Viterra Inc., 671 F.3d 1358, 101 USPQ2d 1905, 1912 (Fed.
Cir. 2012), citing Century 21 Real Estate Corp. v. Century Life of America,
970 F.2d 874, 23 USPQ2d 1698 (Fed. Cir. 1992).
In considering the similarity or dissimilarity of the ARCTICPURE mark
to Applicant’s ARCTIC NATURALS mark, we consider and compare the
appearance, sound, connotation and commercial impression of the marks in
their entireties. Palm Bay Imports Inc. v. Veuve Clicquot Ponsardin Maison
Fondee En 1772, 73 USPQ2d at 1692. In comparing the marks, we are
mindful that the test is not whether the marks can be distinguished when
subjected to a side-by-side comparison, but rather whether the marks are
sufficiently similar in terms of their overall commercial impression that
confusion as to the source of the goods offered under the respective marks is
likely to result. San Fernando Electric Mfg. Co. v. JFD Electronics
Components Corp., 565 F.2d 683, 196 USPQ 1, 3 (CCPA 1977);
11
Opposition No. 91200928
Restaurants Inc. v. Morrison Inc., 23 USPQ2d 1735, 1741 (TTAB 1991), aff’d
unpublished, No. 92-1086 (Fed. Cir. June 5, 1992). The proper focus is on the
recollection of the average consumer, who retains a general rather than
specific impression of the marks. Winnebago Industries, Inc. v. Oliver &
Winston, Inc., 207 USPQ 335, 344 (TTAB 1980); Sealed Air Corp. v. Scott
Paper Co., 190 USPQ 106, 108 (TTAB 1975).
Opposer’s mark is ARCTICPURE and Applicant’s mark is ARCTIC
NATURALS. Opposer submitted dictionary definitions of the terms “pure”
and “natural” as follows:
Pure: not mixed with anything else; clean and not harmful in
any way.
Merriam-Webster; merriam-webster.com

Natural: existing in nature and not made or caused by people:
coming from nature; not having any extra substances or
chemicals added: not containing anything artificial.
Merriam-Webster; merriam-webster.com

As explained by Opposer’s Chief Executive Officer, regarding the choice of
the name ARCTICPURE, “We—the material we were buying we were told,
you know, one of the factories we worked with was in Norway. And the
material we were buying was near the Arctic Circle. The fact they told us
that they used fish primarily from the Arctic Sea or – Arctic Sea I guess.”
Goldberg discovery deposition; 65 TTABVUE 7. Applicant’s Executive Chair
similarly stated regarding ARCTIC NATURALS, “those words convey that
our product is natural and comes from fish that inhabit cold-water areas,
such as the Arctic Ocean.” Decl. Stan Watson 61 TTABVUE 4. As such, we
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Opposition No. 91200928
find that the marks have similar connotations and commercial impressions of
pure or natural fish oil from the Arctic Sea.
Applicant argues that the term “ARCTIC” is weak, which we later discuss
in the sixth du Pont factor. We find, however, that the similarities in
commercial impression clearly outweigh any differences in sight and sound,
and this first du Pont factor also weighs in favor of finding a likelihood of
confusion.
Number and Nature of Third Party Use of Shared Term
Applicant argues that consumers will recognize the subtle differences
between the marks since there are a number of third-party marks containing
the term “ARCTIC” for fish oil products. Applicant’s Executive Chair attested
that “The words ARCTIC and NATURALS are commonly used to identify
dietary supplements, particularly products that contain fish oil.” 61
TTABVUE 4. Applicant further subpoenaed third parties in this proceeding,
and submitted evidence of eight uses of the term “ARCTIC” by third parties
for fish oil products.11 These uses include Arctic Essentials from Urban
Nutrition, LLC; Arctic Fresh and Arctic Fresh Omega 3 from Mr. David
Ruggieri; Arctic Ocean Krill Oil from Natural Biology, Inc.; Arctic Sea and
Forever Arctic Sea from Aloe Vera; and Arctic Select Krill Oil from Pro-
Health; and Arctic Oils from Xymogen.
11 The parties stipulated that documents obtained in discovery “from a third party in
response to a subpoena” may be made of record “by Notice of Reliance alone without
further evidence of Authentication.” 38 TTABVUE 3. Although Opposer objected to
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Opposition No. 91200928
Opposer argues that the submitted uses “do not support that the relevant
consuming public has been conditioned to distinguish between close marks.”
76 TTABVUE 31. Notably, Opposer asserts that several of the third parties
either don’t sell their products in the same channels of trade or don’t have
significant sales. We note, however, that with the possible exception of Arctic
Ocean Krill Oil, the uses are not de minimus, and some indicate significant
market exposure. Urban Essentials stated that Arctic Essentials has been
sold since 2007, in all U.S. states, and that it has a registration for ARCTIC
ESSENTIALS, Registration No. 3,360,277. 61 TTABVUE 206-207; 217. Mr.
David Ruggieri stated that Arctic Fresh Omega 3 and Arctic Fresh have been
used since 2007 in all fifty states, with sales including through the Internet.
Id. at 225. Natural Biology stated that Arctic Ocean Krill Oil has been sold
under the mark since 2010. Although sales were less than $20,000 for 2011,
they were marketed through the Internet. Id. at 242-243. Aloe Vera of
America produced documents related to its Arctic Sea and Forever Arctic Sea
products. These reflect sales to numerous states around the country,
reflecting millions of dollars in sales. Id. at 344-352. The documents also
include a registration for ARCTIC-SEA, Registration No. 1,908,108. Id. at
303. Pro-Health stated that it has promoted its Arctic Select Krill Oil since
2010 in twenty-two direct mail catalogs and via amazon.com as well as via
search engine optimization and Google pay-per-click advertising in addition
the probative weight of the third party evidence, it did not object to their submission
into the record.
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Opposition No. 91200928
to direct consumer emails. Id. at 369. The eighth use, discussed only in the
confidential record, notes significant sales of Arctic Oil by Xymogen.
While these eight uses demonstrate some weakness of the term “ARCTIC”
for fish oil products, there is insufficient evidence of the extent of market
exposure of several of the individual products for us to find that the term is
widely used for such goods. Furthermore, it remains unclear what share of
the fish oil market is possessed by the third-party use. Cf. In re Broadway
Chicken Inc., 38 USPQ2d 1559 (TTAB 1996) (finding BROADWAY PIZZA not
confusingly similar to BROADWAY BAR & PIZZA where hundreds of third-
party uses of shared term). Overall, we find that this sixth du Pont factor
weighs slightly against finding a likelihood of confusion.
Conditions of Sale
Applicant urges us to consider the level of purchasing care likely to be
exercised by consumers of dietary supplements and fish oil products. There is
conflicting evidence in the record in this regard, with Applicant’s Chief
Financial Officer testifying that “Supplement consumers are very discerning
consumers” 40 TTABVUE 77, and Opposer’s consultant to the president
testifying to a gamut of customers including all levels. (41 Conf TTABVUE
27). Applicant noted in a response to interrogatory that its suggested retail
price is as low as $14.99 for its product. Appl’s Response to Interrogatory No.
3. Moreover, it is well-established that even sophisticated consumers are not
immune from source confusion. Cunningham v. Laser Golf Corp., 55 USPQ2d
15
Opposition No. 91200928
at 1846. With identical goods and similar marks, even a careful, sophisticated
consumer of these goods is not likely to note the differences in the marks.
Stone Lion Capital partners, LP v. Lion Capital LLP, 746 F.3d 1317, 110
USPQ2d 1157, 1163 (Fed. Cir. 2014).
Accordingly, we find this fourth du Pont factor to be neutral.
Actual Confusion and Potential for Confusion
The parties discussed the lack of actual confusion and the extent of
potential confusion. Applicant argues that there have been no instances of
actual confusion. We note, however, that while the presence of confusion may
be very useful to our analysis, the lack of evidence of actual confusion carries
little weight. J.C. Hall Co. v. Hallmark Cards, Inc., 340 F.2d 960, 144 USPQ
435, 438 (CCPA 1965). This is especially true where, as here, the record is
unclear as to the amount of meaningful opportunities for confusion to have
occurred among purchasers. Nike Inc. v. WNBA Enters. LLC, 85 USPQ2d
1187, 1202 (TTAB 2007). The parties do not appear to be currently selling to
the same consumers. Accordingly, we find these du Pont factors to be neutral.
Conclusion
We do not analyze Opposer’s SOURCE NATURALS and ARCTICPURE
marks conjointly as the requisite elements were not satisfied.
In comparing Opposer’s mark ARCTICPURE to applicant’s ARCTIC
NATURALS mark, and taking into account all of the arguments and evidence
of record as they pertain to the relevant du Pont factors, we conclude that the
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Opposition No. 91200928
goods are legally identical, and may travel through the same or similar
channels of trade. Although the shared term “ARCTIC” is somewhat weak for
the goods involved, the marks nonetheless have the same connotation and
commercial impression with the similarity of the terms “PURE” and
“NATURALS,” that, when considered in their entireties, the marks are
similar. In conclusion, we find that there is a likelihood of confusion between
the marks.
DECISION: The opposition is sustained on the ground of likelihood of
confusion with Opposer’s mark ARCTICPURE.
17