Académique Documents
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EXHIBIT AA
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 2 of 113 PageID# 157
Exhibit AA
- . zzL:
To: ^'""^uipTb.SOV; atiud.8W
Oate: Wednesday. June 24.201S lOfll AM
Mail: P.O. Box 1450. Mail SO^ - OtHce oftte Solicitor. USPTO, Alexandria, VA 22313-1450
Hand-Deliveiy: Madison West- BgWhRoor, D39,600 Dulaiy Street, Alexandria. VA 22314
Based on the below^hed email from USPTOOED, it appears it is the ALJ that tampered wrth my ExhibjB
TO-TS
Tfl-is'lnRespondeni
the USPTOhereby
recordrequests the ALJ to Immediately
ofPTOD2014-31,based correctfiled
on the exhibits the fcUlfled Respondent
by Respondent sMhltals
totheAU.
also requests the AU to clarify the AU's tampering with Respondent's exhibits inmdlately
before a Is I"> fi> ofCongressional Inquiry to HUD regarding the tampered
exhibits.
To avoid further missing files orlalsified exhibits, an extra copy ofthe genuine exhibits ofT0-T5 will be
filed along with the reply briefadditionally to the Dept ofCommerce- USPTO, in the form of
Congressional Inquiry. The email communication between OED and respondent regarding the matte RESPONDENTS BQfiBIT
/ir?
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 4 of 113 PageID# 159
Print
evidence tojustify Respondent's Congressional
as'
Inquiiy.
WithReg^
Respondent
Bang-crShia
. ... jjaLBEEOflS^.* .
,ausaafi2S>;A.j.A.j<...,i8W*<>
^SromU^wld.id.flU,p.ExT.T5^
DearDr.Shia,
Tlus IS. m
. ,.,wiiltodavteeaKlingthe
i record.
appears in theWeteceivedfiBmtheAUabmdw
certified record. Ifyou believe an
Youis Truly,
Liz Mendel
11 CXHBir I
\\M I
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 5 of 113 PageID# 160
WithRegans,
Banger Shia
. Forwarded
1. Youranswertotiorquestionisiiotcomplyingith37CJA U.55(a),
n.55 Appeal to the ^ y^nofthe hearingoflicer under 1125or either
(a) Withinthttty|^y appeal shall include the appellant's brief. Ifmore tto ok
party may appeal to the Wwc^j" ofthis rule. Ifappeals ate fW oi
appeal isfiled, the pat^r who filM the ppe ,-| jjgied, then the OED Director shall tiansmitthe
the same day, the responfent isthe P^.,,^ f j^i fourteen days after the date of
entire reconl tothe USPTO ofthe initial decisL ofthe hearing
cross-appellee brief.
myreplybriei;shouldan appeiiee or
reply briefis htodly given by the OED Director.
i-..iiwiUfilevrillalsoincludefactsaboutaparticuIarOEDdatestampappear^on
Washington, DC.
iv.inll also include 6cts about the more than one subpoena filed by Melinda
LM^"^Kf^KX^^itetioaallyfalsifdbyiemovig^^^^^^
provided thereon.
.A 4n7ni4.:)l swellsasinOED208l,OED2341,andOED2505,
resolved byUSPTO.
Regards,
BangprShia
t>oiii;'^endd.Eli>>My>^.^- TiisPTn.fiO>!'
r -^ismoov^
DearDr.Shia,
towsponse to yourenuuls. your apped^as timely filedmth the
i,nn.prtofthenord before the ATJ so is not mdudedmtto
Director's ^pelleebriefin response is due m30 days. See 37 C.F.R. 11.55(a).
YoursTruly,
LizMoidel
HiabelhUIInKr Mendel |Associate SoUciM United Trademarlt Office |Office ofthe Solicitor
Main; (S7l)2'>2-fli||! Direct: (571)272-( IFax: (S7I)273-^H
S!^P.O.BoximMafsttSTs'-OffiM of"Solief"-"SPTO,
Zd-Delivev:Madison West- Eightl. Floor. 8D39,600 Dulany Street.Alexandra, VA 22314
Dear Sir/Mam,
Ihave filed on May 22,2015 an Appeal to the InttialDecision by USpostal service Certified Mail(7013 2250
0001 55061734). Istill kept the certified mail receipt with me.
However. Idonot see my Ap^l inthe documentyousent. Please explainwhy my appeal filed onIW 1 RESPONDENTS
2015 was not part ofthe official record. 1 EXHtBlT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 7 of 113 PageID# 162
.. J
You have
Uie the received
lecuic 1secure
Wc below^ ffle from
dowrfoad.
743.53 MB
Seemedby
RESPONDENTS
EXHIBIT
https;//us-iTig6.mail.yahoo.conVnco/launch?.rand-e48nrasuniuo6#583.
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 8 of 113 PageID# 163
Print
Attachments
^SpcRdeSts
EXHiBrr
/?
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 9 of 113 PageID# 164
EXHIBIT T: Tq-Tj
^SoBSBfre
EXHIBtT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 10 of 113 PageID# 165
RtCEWEO
Cotnmi8slonef.for'
PX>.Sox 1451
AIe)(andila.VA 22313-1461
www.uspU>.gov
January 23,2012
Mr.BangShia
102Xindencrest Court
SugarLand, TX 77479-5201
DearMr.Sbia: , *
4^;wmivcmihaLfarther^otJS.sctfoithbclow,tlieXJnitedStatcsPatentand
^!S^Offie(USm)isoiuided.eddingwfi^
otdomeslio lepieseotefivoin w iradnnad?"^
The USm*siecMdsiiuJistf8 8iatyottlwyeIieea involved vrithnuwthm23^
Slicattonsortegisttafioos. S?e<cdly.a>ejBcationsMaregisWtKB.Tto^^
vS&tiaSinaividuab.oftetlhw.yo5df.iayottalte
ZLmtafive. In addition, an Mn^address contammgyourname jslypicanypio^
SatioMandiegistMttonstopposesofconep^^ InsTOinstooyoutri|Da^
SBintheapp&ontecoid. A.Ustofwlevantappbrahoasenalmuntotta^
^^mtolteniber2011. Pleasenotettoaay^ relevantappUcatoonsffled
<a othetvfise notincluded onUie attached lot, are abo sulaect to the acaons
described below.
VUsuo TOtfr -Jir. -TMEP" Idcodfiei ibe Tradtmark Manual tfTExamtntngrrceedure (8th ed). aviCabte adIIim ct
hprfAsi2.t>s?to.govAmdWtinei/.
iTSpSSSIr?
' EXKSir
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 11 of 113 PageID# 166
f fitckmo
DEC Si <012
ABonn* John C. Brederick OFFICE OF ENROUMlt
M.ilrt)p:OED ANOOISC.PC.W
VjSPTO,POBox 14S0
AtaBiiidria.VA22J3-WS piUNfl.mOV
Sto c)
t. toiSt<wCaaseisonconstituUonaUyserd.violalmgduepi<soflB^^^
2^ to Show Cause Ms to >ake aclaim for lackofjurisdictionover en enUty "Bang
SUa';
5. that Show Cause is constitutionally and statutorUy defective, violating the stttwoiy
minimum reply period of1month;
6. to Show Cause fills the statuteofBmitation;
7. jjiattheRequest Ms the statuteofBmitation;
8. toShowCauseUuncon8tilutional,lminn^gon6fthamendment;
9. totheRe<jueslisnconsatutlonal,impingingonfifthamendment;
EXWBIT
V - >
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 12 of 113 PageID# 167
^ce/vg0
''fS 01 2013
I^'^p'So.uspTO.POBox 1450 >wooi|^^^Mavr
yVtaandfl^VA22313-1450 pU>lii.O20i
oB<inEDTOMaon.im
OTOHAL!,MmAL-^-MSOHOFDOMKtKMMEMmAT^
the Office Action issued 08/3/2011.
FoltowingpgraphQ.)tatheRFIdledDec.5.20n.appC8tlo791011M
showkethattheOffice'satU.n^yh.vetoowinglyaJd^Jim-represemedf^^
WBuU,ori2edpnUceofTdenttklawby presumablyknowingtotte
toftea,orothewiseserviceswererendeted.bysomeone notauthorizedtodo soin
eontravendonoftheUSTrademarklaw,andbyenteringthe appUcatlonv^ihaUS serialnumber
uponreceivingfeeapaidp^somablyftoma-fo^ignlocalagency"shownontheofficial.ecori
Other than the applicant
^IgllSSSrihascanJInnedthathe/shelsm^^^
II EXHIBIT I '
ll^l
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 13 of 113 PageID# 168
. . . ;* *'
rECEWEO
. MAR 26
OEOMDW-8C43B ftmCE0F6MR0liMENT
Attorney Emu j.All ANOOISClM.#
PO Box 1450Alexandria, VligWa 22313-WS1 Or. Banger Shia
Patent Office of Bang Stiia
102Lhdencre$tCt.
Sugar Land. TX 77479-5201
I.
RECeWEO
MtomeyBaJ.An(OEDraeG2081)
S^VA2233-145 ^01SCa^
Evidence 1): Many applications listedin Exhibit Aattached to the letterfrom attorney John
Broderick 12/5/2012 ate not associated vrilhDr.Shia in aiqr ways, including, butate not
limitedto. US serial No. 762S7209.76257214.7636738. and 76280138, ete. in the firstcolumn
ofsdExMbit Kpresenting evidence ofawrongM accusationvilh an unverified automatic
coDiputcr-gencratcd output.
'S
EXHIBIT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 15 of 113 PageID# 170
RECEIVED
AttorneyJeSferA.Halviek(OEDHleG20) HW 03 2013
PO Box 1450 OFFICE OF ENROLIMENI
Alexandria VA 22313-1450 ANOOISCiPUNfi
Respectfully submitted,
msisff?
EXHWT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 16 of 113 PageID# 171
BANG-ER SHIA
HEARING - VOLUME IH
i ourt Reporting
asamo \s s erencing
Page 405
Page 403
2 sheet. Jtist the pink sheet. Hold that up. 2 Q. At my request, did you, in fact,
3 Okayi can you tell the tell us what that 3 download print the documents from the ODUS
4 document is? 4 system this morning so we could coopare them?
5 A. This is an OED intake form. 5 A. Yes, I did.
6 Q. And where did you get that document? 6 Q. Did you bring those documents? I'm
7 A. This came out of the original file 7 sorry.
17 brought today s^teeu: to be the same as the 17 DR. SHIA (inteipreter): nhen did
18 document that's marked 61470? 18 you punch the holes here?
19 A. Yes. 19 JUDGE FERNANDEZ: When were the
20 Q. On the original document, what does 20 holes punched?
21 it show with respect to the OED date stamp? 21 THE WITNESS: They would have been
22 A. It is dated November 8, 2012. 22 punched when they were processed and put
Page 404 Page 406
1 Q. Can you eaqplain -- maybe if you could 1 into the original file.
2 pull up Respondent's Dl, do you have that? 2 DR. SHIA (interpreter): Usually,
3 A. Yes. 3 when you process it
4 Q. And can you ea^lain why Respondent's 4 JUDGE FERNANDEZ: You can ask her
5 Dl appears not to have that same date stanp as 5 questions when it's your turn, okay?
6 is on the other document we looked at a second 6 MS. MENDEL: Your Honor, I would
7 ago in Joint 6? 7 move the admission of the original two
8 A. From my understanding, OED's scanner 8 documents as Government 603 and the copy
9 is a black-and-white scanner so it does not 9 as Government 604.
10 scan color, and depending on the quality of the 10 JUDGE FERNANDEZ: So you'd like to
11 scan, if things are in color, it may appear 11 move the original in as 603 and the copy
12 Jiqht or not at all in the scanned copy. 12 in as Government 604?
13 JUDGE FERNANDEZ: May I see the 13 MS. MENDEL: Yes, Your Honor.
14 original, please? And it's light blue. 14 JUDGE FERNANDEZ: Dr. Shia, any
15 I just want the record to reflect that 15 objection?
16 it's light blue, which I know from 16 DR. SHIA {interpreter): No.
17 own experisnce is a notoriously 17 JUDGE FERNANDEZ: So ordered.
9 18 difficult solor to copy. In fact, I'll 18 (Government Exhibit Nos, 603 - 604 were
19 take judicial notics of the fact that a 19 received and admitted into evidence.)
20 lot of the editing Euid proofing gallies 20 BY MS. MENDEL:
21 are in light blue because the color does 21 Q. Now I want to ask you about the
22 not reproduce easily. 22 different date stamps.
I RESPONDENTS
Toll Free (877) 837-0077 EXHIBIT
T: (703) 837-0076
http://www.casamo.com Casamo and Associates
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 18 of 113 PageID# 173
HEARING - VOLUME III
BAN6-ER SHIA
Page 409
Page 407
Can you e^qplain wby the date staop on 1 THE INTERPRETER: I'm sorry.
1
2 what was just adsdtted as govezxment 2 A. It says "OED front desk," which I
3 Exhibit 603 is different fron the date stanp on 3 wrote this morning.
other documoits received by OED, such as Joint 4 MS. MENDEL: Give that to the
4
5 Exhibit 11? 5 judge. Your Honor, may we admit that as
6 Government 606?
6 A. OED has more than one date stait^r
7 it depends cn which contractor processes 7 JUDGE FERNANDEZ: Any objection.
that document. 8 Dr. Shia?
8
9 Q. And did you bring an OED date stamp 9 DR. SHIA (interpreter): No.
10 with you today? 10 JUDGE FERNANDEZ: So ordered.
Psge 433
Page 425
11 submitted it, well, Dr. Shia, that's 11 JUDGE FERNANDEZ: You've got two
12 something conpletely different. 12 more questions on this and then we're
13 But if what you're telling me is 13 done.
20 for TO014-04 case iust to prolong, to 20 Q. So you allow the contractors to have
21 delay, ip to find more 21 different stands; right?
22 infnmwi-inn. Then after fhpy qrt mnrp 22 A. There's two date stamps that I'm
9 IG's office and report them for doing 9 Q. You mentioned on your direct about
10 it. But that's outside of my 10 the ODUS system, and that's an electronic
11 jurisdiction because they've dismissed 11 document repository?
12 the case. 12 A. Yes, and case management.
13 THE INTERPRETED; I'm sorry, which 13 Q. And are documents uploaded into that
14 office? 14 system, then hole punched and put in the file?
15 JUDGE FERNANDEZ: IG, Inspector 15 A. Yes.
16 General. What I can tell you is that in 16 MS. MENDEL: Thank you. Nothing
17 terms of being in front of me, that's no 17 further.
18 longer in front of ne. You're not hurt 18 JUDGE FERNANDEZ: Any last thoughts
19 by that statute of limitations. Those 19 on this. Dr. Shia?
20 charges are gone. 20 DR. SHIA (interpreter): No.
21 BY DR. SHIA (interpreter); 21 MS. MENDEL: That's all for this
22 Q. So your policy is for external nails, 22 witness. Your Honor. Thanl^^
I RESPONDENTS
T; (703) 837-0076 Toll Free (877) 837-0077 P; EXHIBIT ,
http://www.casamo.com Casamo and Associates transc
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 20 of 113 PageID# 175
EXHIBIT AB
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 21 of 113 PageID# 176
EiMbit AB
iU) In the letter ot July 23, 2015, the USFTO General Counsel Sarah Harris
,a^ t. pat ediibiB A-R back t. the tdder / "RespondenfsPr.ped
Exhibits", as she cUmed the whole set ottaitti exhibits A-Z we,, all mthe
folder D"Exhibits Introduced During Hearing".
iv) USPTO also removed the Joint Exhibit 3from the folder "Exhibits
Introduced During Hearing". Joint Exhibit 3 was a copy of the former
Commissioner's Show Cause Letter, coercing for Dr. Shia's submission of
documents in defense of an alleged violation in practice of law in trademark
matters.
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 22 of 113 PageID# 177
Please find a total of 6 files; thank you. (file "Exhibits A-R" was already filed previously).
Attachments
Exhibits-A-R.pdf(2.58MB) ^
Exha)it-S.pdf(l.llMB)
EXHIBIT-T-Y.pdf(1.58MB)
EXHIBIT-Z.pdf(260.54KB)
EXHIBlT-LIST-8-13.pdf(12.59KB)
Witness-List-8-13.pdf (110.25KB)
BCHIBIT
M4-
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 23 of 113 PageID# 178
BANG-ER SHIA
HEARING - VOLUME V
Court Reporting
asamo Vidcography
Videoconferencing
3
EXHIBIT
Print ht^s://us-nig5.niail.yahoo.com/neo/launch?.raiid=648nrasuniuo6#683.
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 25 of 113 PageID# 180
Ms. Seifert,
We are resubmitting and recertifying the administrative recordinD2014-31. Certain eidiibits were inadvertently left
out of ourprevious filing and we believe that tNs iqsdated administrative record contains the entirerecord as
transmitted by the AU.
Please downtoad and replacethe previously forwarded record from the Department of Commerce RIeShare
website.
Should you have any difficiities downloading and/or retrieving the record, please let me know.
Kindest regards,
Paralegal Spedalist
Office of the Solicitor
U.S. Patent and Trademark Office
Phone:(571)272-5169
Email: i@uspto.gov
Youhavereceived secure links within this emailsent via Commerce - OCtO Secure FileSharing.To retrieve the files, please clickon the
Snks above. Toteam howyourcompan/ can tsenefit from Acc^on Secure RIeSharing, pleasevisit http://www.acceiSon.com
Secured tw AcceKon
RESPONDENTS
EXHIBIT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 26 of 113 PageID# 181
F) Hearing Transcripts
J) ProposedJoint Exhibits
CTSpSndeBts
JTc
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 27 of 113 PageID# 182
Folders
11 items
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 28 of 113 PageID# 183
Folders
9 items
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RESPONDENTS
EXHIBIT
Is
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RESPONDENTS
EXHIBIT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 31 of 113 PageID# 186
Favorite Links
Name Size Type Date modified Location
Files Cjrrently on the Disc (14)
P) Documents
00 Index - Joint Exhibits JNT#l.pdf JNT#2.pdf
^ Pictures Introduced DuringHearing.. Adobe Acrobat Document Adobe Acrobat I
IP' Music Adobe Acrobat Dccument 6.01 MB 7.82 MB
JNT#21.pdf I JNT#116.pdf
Adobe Acrobat Document I Adobe Acrobat Document
2.73 MB jg 1.49 MB
Folders A
14 items
pSSpSmEH??
EtoaBIT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 32 of 113 PageID# 187
Respondent
OnJune 27,2014, the inthis mattCT was received and assigned to the
undersigned for hearing pursuant to 35 U.S.C. 32 as implemented by 37 CJ'.R. Part 11.
The paities are encouraged to discuss setdement in this matter. Ifsuch discussions have
not yet commenced or ifsuch discussions have stalled, each party b reminded that pursuing diis
matter throu^ hearing and possible appeals will require the expendituie ofsignificant time and
financial resources. The parties should realistically consider the risk ofnot prevailing in the
proceedings despite such expenditures.
Asettlement allows the parties tocontrol the outcome ofthe case rather than have a
decision made for them. Accordingly, the parties are strongly encouraged toengage in
settlement discussions and attempt toresolve this matter. Ifatany time the parties seek the
assistance ofa settlement judge inthis matter, please advise the Court ofthat fact, witfiout
elaboration.
' Pursuant toanInteragency Agreement ineffect beginning Marcli 27,2013, AdministraUve Law Judges ofthe U.S.
Department ofHousing and Urban Development are authonzed to hear casej for the U.S. Patent and Trademark
Office.
*This proceeding is separate from another matter before the Court that is docketed as Proceeding No. D2014^
and scheduled for hearing on July 28,2014.
EXHIBIT
At't!
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 33 of 113 PageID# 188
Complaint and set forth any affirmative defenses and any mitigating factors or
extenuatuig circumstances. The Answer must be receiv^ by the Docket Clexk on or
before July 28.2014:
3. Discovery. Discovery is not authorized absent anorder oftheCourt after the Answer
has beenfiled. 37 C.F.R. 11.52. A partymoving for discovery shallfile a motion as
specifiedby 37 C.F.R. 11.43 and 11.52 demonstrating that discovery is reasonable and
relevant onorbefore Aupist28.2014. The non-moving party may file anopposition to
the discovery motion onorbefore September 8.2014.
4. AffirmativeDefenses. Counsel for theOED Director shallfile Motion to Strike
Affirmative Defenses, if any, to bereceived by theDocket Cleric onor before August 19.
2014: die Respondent(s) shall file a response toa Motion toStrike Affirmative
Defensesif any--to bereceived bythe Docket Clerk onorbefore Au^t28.2014:
5. Witnesses. Onor before August 13.2014. theparties shall exchange lists of witnesses
expected to be called atthe hearing, except for impeaduncnt orrebuttal, togethw with a
brief statement following each name describing the substance of the testimony tobe
given; \
'y 6. nnniMBNTR. On orliefore Au^t 13.2014. the parties will exchange documents and
otheritems to be ofifeied as exhibits at thehearing. Eachdocument and exhibit shallbe
numbered foridentification (with die prefix "GOV #."fortheGovernment's exhibits and
"RES #." forRespondent's exhibits);
8. Format And Submission OFExhibits. For receipt by the Dodcet Clerk onorbefoie
September 23.2014. each party will submit Binders containing the party's exhibits:
[Note: copies ofexhibits in scanned electronic format may also be filed, but the complete
exhibitbindersmust be received on or beforethe abovedate.]
b. Toavoid duplication ofexhibits, the parties will coordinate and submit JOINT
EXHIBITS. Theseexhibits willbe designated "JNT#." The Government
counsel will cooidinatethis effort The other party(s) is expectedto cooperate
fully with the Government's efforts in this regard. The Joint exhibits wiU be in
separate bindei(s), orinasegregated part ofthe binder containing die
Government exhibits;
9. Objections. Any party objecting toany known exhibit and/or witness tobepresented
atthe hearing must file a written objection, stating the legal reasons for the objection, to
bereceived bythe Docket Clerk no later than September 26.2014. The party attempting
to introduce the exhibitand/orwitness mustfile its response, to be receivedby the
Docket Clerk, no laterthanSeptember 30.2014. Theparties must fax(oremail) these
objections and responses to such objections [to each other] immediately upon filing;
10. Pre-hearing Statements. Each party shall filea pre-hearing statement, to be
received bythe nncket Clerk on orbefore September 30.2014. briefiv setting forth the
following:
a. Dispositive Motions. Any motion, the granting ofwhich could result inthe
disposition ofsoyS ^ portion ofthereof) ofthe Counts contained inthe
Complaint, oralleviate the need for a hearing, should befiled assoon as
practicable, but must be received by the Docket Clerk no lat^ than September 5>
2014;
b. Motions in Limine. Motions directly affecting the conductof the hearing (other
thanthoseabady specified herein) should be filed as soonas practicable, but
must be received by the Docket Cleri: no laterthanOctober 2.2014:
14. ServiceAND filing* Copies of all documents filedshallbe servedon all parties of
recordat the same time as the originals are filedwith the Docket Clerk:
Service to all parties of record must be made in the same form filing is made to the
Docket Clerk or to theCourtin general (e.g. if a party emails a document to theJudge,
Clerk, Docket Clerk, etc., that partymustservethe remainingparties by email as well).
All filings with the DocketCleik or withtheCourt in general must be madeby 6:00 p.m.
EST for the filing to be docketed on that specific date. Documents received by facsimile
or email after 6:00 p.m. EST will be docketed on the following business date;
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 36 of 113 PageID# 191
16. Other Matters. Issues including accessibility for the disabled, the need for
interpreters, courtroom equipment, etc., must bebrought to theattention of theDocket
Clerkat least four (4) weeks priorto thestartof the hearing; and,
So ORDERED,
Alexander Fenitodez
Administrative Law Judge
Enclosures
Appearance of Counsel Form
Pro Se Appearance Form (Respondent only)
lit^s://us-mg6.inail.yahoo.conVneo/launch?.raiid=ejarbmirht0sp#7824.
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 37 of 113 PageID# 192
Subject: D2014-31 OED Director's Response to Respondenfs Motion to Correct Record 07-08-2015
From: DeAtley, Melinda "* V@USPTO.GOV)
To: t@USPTO.GOV:
_ .a@yahoo.confi. 'j^hud.gov.' y@USPTO.GOV;
Cc: . @USPTO.GOV ' - ^n@USPTO.GOV;
Date: Wednesday.July8,20151:25 PM
On July 7,2015, Respondent filed a Motion to correct the certified record. Respondent requested that
the ALJ "re-transfer thecorrect and complete Respondent's exhibits A-Z." Respondent first did so via
anemail. Ina second filing. Respondent requested the correction via a formal motion. Please find that
motion attached.
Also, please find attached, the OED Director's Response to Respondent's Motion to Correct the
Record.
Thank you,
MelindaM. DeAtley
Associate Solicitor
Direct: 571-272-a0
Main: 571-272-Si
Fax:571-273-HB
Email: i y@uspto.gov
RESPONDENTS
EXHIBIT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 38 of 113 PageID# 193
Print Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 39 of 113 PageID# 194
https://us-mg0.inail.yahoo.com/iieo/launch?.raiid=ejarbmirhtOsp#7824.
USPTO
Alexandria, VA 22313-1450
Alexandria, VA 22314
CONFIDENTIALITY NOTICE: This e-mail message is intended only for the addressee and may
contain confidential and/orprivileged material Any unauthorized review, use, disclosure, or
distribution isprohibited. If you are notthe intended recipient, please contact the sender byreply
e-mail and destroy allcopies of the original message. If you are the intended recipient butdonotwish
to receivecommunications through this medium, please advisethe sender immediately.
Attachments
July 9,2015
We are in receipt ofyour e-mails sent on June 23,2015, July 7,2015, and today,
regarding the record ofthe proceeding referenced above. As you Icnow, Proceeding No. D2014-
31 was as ofthe issuance ofthe Initial Decision and Order, dated April 22.2015. In
accorfance with its usual practice, after the issuance ofthe Initial Decision this office transferred
all related documents in its possession (to include both originals and copies) to the OED. The
OED keeps the record and transmits it to the USPTO Director ifan appeal is filed.
USPTO regulation 37 C.F.R. 11.55(3) states, "[i]fan appeal is filed, then the OED
Director shall transmit the entire record to the USPTO Director." Pursuant to the regulation it is
the OED Director, not the Office ofHearings and Appeals, which is responsible for transmitting
the record to the USPTO Director.
Ifyou believe there is an issue with the record as transmitted to the USPTO Director by
the OED Director, you may consider raising ihe issue, in writing, with the USPTO Director.
And, because the documents you claim are missing are your own exhibits, you should be able to
provide them to the USPTO Director should the Director need them during her du mvo review of
the record. Moreover, once aparty appeals amatter to the USPTO Director and the files are
transferred out ofthe Office ofHearings and Appeals, our involvement in the matter concludes
as the USPTO Director is tasked with making the final agency decision.
Sincerely,
Hnthia Matos
Docket Clerk
Cc: Melinda M. DeAtley
Elizabetii Uilmer Mendel
s@usDto.gov
RESPONDENTS
EXHIBIT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 41 of 113 PageID# 196
In the Matter of )
ORDER
On June 23,2015, Dr. Bang-er Shia, aprose Respondent in the above-captioned matter,
filed arequest toask that the hearing record becorrected. Respondent asserted that certain
exhibits, identified as"T0-T5" in therecord ofthe hearing proceedings, hadbeen omitted fix)m
the official record.
Thereafter, on July 7,2015, Respondent filed her Reply Brief as well as anotherrequest
to correctthe record. In this second request.Respondent no longer makes any requestwith
regard to the'T' exhibits. However, she alleges that hearing exhibitsA-R, whichwereadmitted
bytheAdministrative LawJudge during thehearing proceedings, arcomitted firom the record.
OnJuly 8,2015, the OED Director responded to the July7 request, notingthatexhibits A-Rare
in Folder "D" of the corrected record. A review ofthe corrected record shows that all of
Reqjondent's exhibits A-Rareincluded in Folder *T)" ofthe corrected record.
7/Z3//S'
Date Sadn Harris
General Counsel for General Law
United States Patent and Trademark Office
RESPONDENTS
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 42 of 113 PageID# 197
on behalf of
IfoteSenaryofConunetcefor InteUectualPtopei^and
Director offl>e United States Patent and TrademarkOffice
cc:
Dr.Banger-Shia
Patent OjQSice of BangShia
102 Lindencrest Court
Sugar Land, TX 77479
.!;4a@yahooxota
Respondent
OED Director
'' 'V'@uspto.gov
C' ..n@usDto.gov
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 43 of 113 PageID# 198
EXfflBIT AC
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 44 of 113 PageID# 199
Exhibit AC
ii) In an informal "courtesy" email, Dr. Shia's Reply Brief was first
acknowledged by USPTO with a timely "receipt" date of July 6,2015,
contradict with the U.S. postal service date and the certificate of
service date of July 3,2015.
iii) Dr. Shia's Reply Briefwas stamped with the "receipt" date of "July
6,2015".
Pcta>] ; $
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RESPONDENTS
=4
Case 1:16-cv-01051-AJT-MSN Document 1-2 https://iis-nig6.inail.yahoo.coin/neo/laiinch?.ra!id-e48nrasuniuo6#346.
Filed 08/17/16 Page 46 of 113 PageID# 201
?rint
D2014-31 Baig^r Shia Reply Brief to the OED Directors Appellee Brief
From: (Qflaie3lfiteafir@USPTO.GOV)
To:
l@USPTO.GOV;
Cc: .teiiiittfi@yatioo.com; ft^aWafiBfittBy@USPTO.GOV;
Date: Tuesday, July 7,201512:19 PM
Ms. Seifert:
Please find attached, an electronic copy of"Respondent's Reply Briefto the OED Director's Appellee
Brief received timely in the Solicitor's Office on July 6,2015. The hard copy will be delivered today,
July 7,2015. ^
A
Kindest regards.
GtamMoBa
Paralegal Specialist
Phone: (571)272-5169
Email: <MMkJdMMac@usDto.gov
Attachments
^SpSiS^T?
- 1IT
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 47 of 113 PageID# 202
PROCEBDINONO. D2014-31
SOLICITOR
IN THE MATTER OF:
JUL 06 209
O&RaBir&IRMIQIAflKOinS
respondent.
Dt.Bang-erSWa
My 3.2015
102 Ijndfflicrest'Coiirt
fi...rT^tX 77479
ioo.com
EXHIBtr
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 48 of 113 PageID# 203
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 49 of 113 PageID# 204
TABl.R OF CONTENTS
TABLE OF AUTHORITIES
STATEMENT OF THE ISSUES 1
DISPUTED FACTS ^
DISPUTED POINTS OF LAW 1
SUMMARY OF ARGUMENT -2
ARGUMENT SUPPORING DISPUTED FACTS 2
A. Evidence existed to dispute the valicBty ofthe Show Cause letter. 2
B. Evidence existed to dispute the validity ofthe Exclusion Order 2
C. No evidence existed tojustify the TEAS's erasing ane-signature 3
D. No evidence racisted ofviolations of rules in 37 C.F.R. 2 andTMEP...4
E. 37 CJ-R. part 10 was replaced by part 11 after May 3,2013 .4
F. Noevidence existed offorging a written signature wth a keyboard 5
G. No evidence existed ofUPL, including assisting another's UPL 5
H. No evidence existedofthe alleged misrepresentation or deceit 6
L No evidence existed ofthe OED's compliance with 37 C.F.R. 11.32....7
CONCLUSION 15
CERTIFICATE OF SERVICE 16
u
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 51 of 113 PageID# 206
TABLE OF AUTHORITIES
Cases
Armstrong v. Manzo^
380U.S. 545,552(1965) 11
Boddie v. Connecticut,
Fuentes v. Shevin,
Le^witzv. Tvrley,
414U.S. 70,77(1973) 11
Tafas V. DolU
559 F.3d. 1345,1349-50 (Fed. Cir. 2009) 14
Wyeth V. Kappos,
No. 2009-1120 (Fed. Cir. Jan. 7,2010) 14
111
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 52 of 113 PageID# 207
35 U.S.C. 32 1,12
37CJ.R.2.17 4
37 C.F.R. 2.193 2,3,4,6,7
37 CJf.R. 10.23 .4
37 CJJl. 10.77 .4
37C.F.R. 11.19 7
37CJfJl.11.23 7
37CJF.R.11.34 7
37 CJJR. 11.49 1
37 CJJL11.303 13
37 CJF.R.11.804 13
37 C.F.R.11.901 5
iv
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 53 of 113 PageID# 208
TMEP601
TMEP 608.01
TMEP 611.04
TMEP611.06(dHe)
USPTO Code ofProfessional Responsibility
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 54 of 113 PageID# 209
Whether the Show Cause letter and the Exclusion Order issued by the
DISPUTED FACTS
System ("TEAS"), to justify the alleged violations ofrules in 37 C.F.R. part2, part
35 U.S.C. 32. Dr. Shia's hearing testimony of the legal authority to bind the
applicants, and her admitted supporting documents, both admitted mto evidence
Dr. Shiatestified to have the legal authority to bind the applicants. Neither
case lawnor notices of violations existed to justify the alleged violations. Also, no
evidence existed that the PTO's interpretation can be more than "procedural" by
SUMMARY OF ARUGMENT
Absent a file No., the Show Cause letter was not published at Trademaric
and Document Retrieval ('TSDR") for public review. TVS 627:17- 628:7.
The Show Cause letter coerced Dr. Shia for evidence in proofof herinnocence ina
charge ofUPL. R. Ex. Ci-C->. The Show Cause letter was misrepresented with a
peculiar OED date stamp. TV3 404:4-22. R. Ex. T(f-T^: Gov. Ex.520. G18783.
2
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 56 of 113 PageID# 211
Lade of a file No, Exclusion Order was not published. IVS 627:17- 628:7.
No evidence was presented in the Exclusion Order to support the alleged charge.
The mere statement that"... it may be presumed that you are completing, signing,
and thesc filings yourself..." isinsufficient to sustain the allegation of
UPL. R. Ex. G2. Exclusion Older was also misrepresented with the citation of37
C.F.R. 2.193(cXl) without the presence ofits counterpart (cX2). And, the blue-
ink signature was not believed to be personally signed by the Commissioner.
The ALJ alleged that Dr. Shia's typing in e-signatures at the TEAS violated
37 CJJL 2.17(0X1X2), and 2.193(a), (eXl). and TMEP 601, 608.01, and
611.06(d)-(e). Initial Decision, at 9-16. These rules are contained in 37 C.F.R. 2
and TMEP and are made under 35 U.S.C. 2(b)(2)(A) to govern the conduct ofthe
proceedings in registering a trademark. No notice of violation was issued as to e-
signatures entered. TW2 222:6-21, TJ^ 251:4-19; G. Ex. 506-5IS The evidence
The TEAS is posted online by the PTO. TV2 224:6-7. Dr. Shia could not
sign an applicant's pen-and-ink signature from online ^th a keyboard. Gov. Ex.
attorneys. TVl 53:6-17; R. Ex. S. The fillable paper application, PTO Form 148;
0MB No.0615-0009 is promulgated to tlie public at httD://www.pdffiHerrnm/
189271-1478a-PTO-Form-1478a-Various-Fillable-Forms. R. Ex. 85/689.678. No
evidence of unauthorized practice of law ("UPL") existed showing that Dr. Shia's
entering online e-signatures identical to the pen-and-ink signatures on paper forms
waspracticing law in violation ofthe lawofTexas, whereshe resided in.
complete and sign these electronic filings, it may be presumed that you are
completing, signing, and submitting these filings yourself..." R P.v no
In addition, the Ryu204 enuul was identified wifli Dr. Shia at the instant
when the online submission was made. Gov. Ex. 507. at G17862; flnv Rv sift at
G18117; Gov. Ex. 512. at G182SS: Gov. Ex. 508. at G17939, G17964. Gov. Ex.
512, at G18333. The ALJ even disputed, without basis, in footnotes Dr. Shia's
testimony, for fects that he believed to be unmaterial. Initial r>ip.ifiinn at 20, fii 12.
37 C.FJI. 2.193 (c) contains (c)(1) and (cX2) connected by the Boolean
connector "or". TV2 181:5-182:2. R. Ex. X. There is no information currently
7
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 61 of 113 PageID# 216
provided for tiie TEAS users to foUow under 37 C.F.R. 2.193(cX2). IV2201:9-
10, m 385:19-386:9. 386:19-21, m 623:12-16. No violation can be alleged
for noncompliance vdth an "unspecified" 37 C.F.R. 2.193(c)(2), and thus no
violation of37 C.F.R. 2.193 (c) can ever be sustained. Initial Decision, at 10.
K. Dr. Shia's testimony ofthe legal authority was missing from facts.
Persons who have legal authority to bind the appUcants are not exhaustively
listed in TMEP 611.04. liS 350:1-20. Foreign q)plicants authorized Dr. Shiato
submit trademark documents to the USPTO. TVl. 473:15-16, TY2 221:1-6, TY4
470:12-14; w F-v- 8S/SltS.031: 85/595.869. 85/689.678. 85/712.340, 85/719,310,
S/747.741.85/756.529. Attorney Catherine Cm testified that if Dr.
Shia fstflWwbfid that she had legal authority to bmd her clients, this case would fall
apaiL TV2 192:17-22; 193:1-5. Dr. Shia testified she had the legal authority to
bind the applicants. TVl 473:15-16. JVl 221:1-6; Order For Documents, at 1. Dr.
Shia's testimony, nevertheless, was not included in the ALJ's Findings ofFact
November 20, 2014, Hie AU denied the OED Director's objection and admitted
into evidence Dr. SWa's autiiorization documents supporting her hearing testimony
ofIfae oitrusted legal authority. Order Denvine The OED Director's Motion to
gfriiTA s Post-hearine Exhibits And Respondent's Motion To Strike
Catherine Cwn, a staff attorney and an editor ofthe TMEP, T\Q 325:16-18,
"[wle do not require an E signature. If you submit as part of the
applirati"" adocument such as aPDF file with ahandwritten signature, there is no
requirement for an additional signature." TN^ 395:12-16. However, Dr. Shia's
sutoiitted on October 20,2014 containing the applicant's pen-and-ink
signature on die trademark forms submitted to the PTO, admitted by the AU, were
not included in die AU's FindingsofFact
Hie ALT alleged that Dr. Shia "signed" and "changed" the address on a
rhanga of Correspondence Address form ofthe 77/836,647 (*647) application on
Febiuaiy 7,2013. Initial Decision, at9. In &ct, Dr. Shia electronically entered her
own nattif! as domestic representative when she amended "TW" as 'Taiwan" on
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 63 of 113 PageID# 218
nie AU's allegations ofDr. Shia's pleading the Fifth Amendment did not
occur in this proceeding; it occurred at the proceeding of D2014-04. ^
at 27; 619:18-620:4; R.Ex,E-F. For 85/756,529, the AU's Finding
ofFact Med to include the applicant's Response to OA and the Statement ofUse
(SOU) submitted on March 24. 2013 and August 17, 2013, respectively, even
thou^ both the OA and the SOU were admitted into evidence. G. Ex. 514, at
G18425 and G18448-18450. Also, the IP addresses traced by tiie Windstream
Inc. showed that the submission of documents in 85/595,869,
85/748,531 and 85/719,310 was not identified with Dr. Shia. G. Ex. 517, at
G18578-18580. This undisputed feet, well cited in Dr. Shia's post-hearing brief,
not fevorable to the AU's Initial Decision, was missing in his Finding ofFact Id.
ARGUMENT SUPPORTING DISPUTED POINTS OF LAW
10
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 64 of 113 PageID# 219
January 23, 2012, Med to be issued at ameaiui^l time after the e-agnatures
were entered online and submitted to the PTO since 2006; it also failed to be issued
in a manner for Ming to inform the ^plicants of aviolatirai ofPTO
rules, if any, as to the e-signatures. Absent a meaningfid notice issued at a
time, the Exclusion Order violated the Fifth Amendment Due Process
by depriving Dr. Shia's right ofadomestic representative or correspondent.
admimstrative activities of the PTO to include the exclusion of any person fiom
the scope of its own authority is not entitled to Chevron deference. Borlem S.A.
Empreedimentos Industriais v. UnitedStates, 913 F.2d 933,937 (Fed. Cir. 1990).
12
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 66 of 113 PageID# 221
practitioner, let alone his work constitutes "practice of law" in that state, and "in
violation ofthe law ofthat State". The name ofthe state is not identified.
2(bX2). Pub. L. 106-113. But this authority does NOT grant the PTO the authority
to issue "substantive" rules. Merck & Co. Inc., v. Kessler, 80 F.3d 1543, 1549-50
(Fed. Cir. 1996). "Arule is 'substantive' when it 'effect a change inexistmg law or
13
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 67 of 113 PageID# 222
poUcy' which 'affect[s] individual ri^ts and obUgfttions." Animal Legal D^.
Fund, 932 F.2d 927. To comply with 35 U.S.C. 2(bX2XA), aPTO rule must be
procedural", meaning it must "govern the conduct of proceedings in the Office."
Cooper Technology Co. v. Dudas, 536 F.3d 1330,1335-1337 (Fed. Cir. 2008).
The Federal Circuit limited Chevron deference to the PTO intwo different
ways, each relating to its prior hol<fing that the PTO has no "substance rulemaking
power". Id. Wyeth v. Kappos, No. 2009-1120 (Fed. Cir. Jan. 7,2010). Mcrfc &Co.
V. Kessler, 80 F.3d 1543,1550 (Fed. Cir. 1996). ("Because Congress has not vested
the [PTO] Commissioner with any general substantive rulemaking power, the
[rule] at issue ... cannot possibly have the 'force and effect oflaw."). PTO rules
accorded deference must be procedural", related to the "proceedings" of the PTO
ra&w than substantive law. y. The Federal Circuit's precedent was clear that
U.S.C 2(bXaXA) and section 132(b) of the Patent Act Tafas v. Doll, 559 F.3d.
1345, 1349-50 (Fed. Cir. 2009). Absent evidence of violation of the PTO
14
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 68 of 113 PageID# 223
roNCLUSiON
Dr. Shia respectfiiUy reque^ tiiat tills disciplinary action and tiie Irutial
Decitionbe <fismissed.
Respectfully Submitted,
. Di^ang-erShia
IS
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 69 of 113 PageID# 224
fRPTIgi^ATR OF SERVICE
I hereby certify that the origiiial and three true and correct copies of the
-Respondent's Reply Brief were served viapostal certified mail onthe 3rfday of
July, 2015,on:
USFTO Director
Mail Stop 8
Officeofthe Solicitor,
United States Patent and Trademark OfSce
P.O. Box 1450, Alexandria, Virginia 22313-1450.
A trae and conect copy of "Respondent's Reply Brief was served via postal
certified mail ontiie 3td day ofMy, 2015, on:
T
/ MelindaDeAtley
/ Elizabeth Ullmer Mendel
/ Associate Solicitors
Mail Stop 8
OfiSce ofthe Solicitor
P.O. Box 1450
Alexandria, VA 22313-1450
Respectfully Submitted,
A
/.^v>
Dr.'Bang-erShia
16
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 70 of 113 PageID# 225
In the Matter of
Respondent
ORDER
On June 23,2015, Dr. Bang-er Shia, apro se Respondent in the above-c^tioned matter,
filed arequest to ask that the hearing record be corrected. Respondent asserted that certain
exhibits, identified as "T0-T5" in the record ofthe hearing proceedings, had been omitted fix>m
the official record.
On June 24,2015, the OED Director responded to Respondent's request, noting that
Respondent filed two sets ofexhibits withthe prefix during the hearing proceedmgs for
D2014-31 (exhibits T1-T3 were filed on January 15,2014 and exhibits T0-T5 were filed on
September 22,2014). The OED Director acknowledged the possibility ofconfusion due to the
feet that Respondent filed two different set ofexhibits labeled witli the prefix "T." However, in
advance ofaruling on Respondent's request, the OED Director submitted asecond, corrected
record. The corrected record included both sets of"T* exhibits.
^ Thereafter, on July 7,2015, Respondent filed her Reply Briefas well as another request
toconectlherecoid.
- ... j
finEs^cSScl request. Respondent no longer makes any requestwith
nf\ Irtna^r malrAC flfiv rftnilPJst witli
regard to tlw "T" exhibits. However, she alleges that hearing exhibits A-R, wWch were admitted
bytheAdministrative Law Judge during thehearing proceedings, are omitted from the record.
On July 8,2015, the OED Director responded to ttie July 7request, noting that exhibits A-R are
inFolder "D" ofthe corrected record. Areview ofthe corrected record diows that all of
Respondent's exhibits A-R are included in Folder "D" ofthe corrected record.
Respondent's request is DENIED
7/23//r
Date Sar^ Harris
Genera] Counsel for General Law
United States Patent and Trademark Office
PrSpondSts
EXHIBIT
40^
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 71 of 113 PageID# 226
on behalf of
Michelle Lee
UnderSecretary ofCommercefor Intellectual Property and
Director of the United States Patent and Trademark Office
cc:
Dr. Bang^-Shia
Patent Office ofBang Shia
102 Lindenciest Court
SugarLand,TX 77479
toiiiiiMB@vahoo;Com
Respondent
OED Director
Hh^ifey@"sptQ,Rov
).gOV
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 72 of 113 PageID# 227
EXHIBIT AD
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 73 of 113 PageID# 228
Exhibit AD
i) On October 9, 2015, Dr. Shia testified at the trial she had the legal
authority to bind the applicants and also electronicaUy entered the
foreign applicants' names as they were removed by the TEAS.
ii) In the General Counsel Saf^ Harris' Final Order, Dr. Shia's
testimony was tampered as "Dr. Shia testified she signed and filed
trademark dociraients with the Office."
iii) In the Final Order, Dr. Shia's testimony of the legal authority to
bind the applicants was completely leftout.
BANG-ER SHIA
HEARING - VOLUME IV
October 09,2014
('ourt Reporting
asamo \s erencing
1 earth do you want? I don't understand. 1 client and they were treated differently
2 JUDGE FERNANDEZ: I mean, that's 2 than you were?
3 PTO's position. I get to irake the 3 DR. SHIA (interpreter): Yes. I'm
4 determination as to whether or not it 4 pretty clear. Can I go on?
5 can be used. Maybe it can be used, 5 JUDGE FERNANDEZ: Well, you can
6 maybe it can't be used. You can send 6 certainly submit that exhibit and you
7 all those documents to me by October 31. 7 can make that argument, and I will
8 Do you understand? 8 consider it along with all the evidence
9 DR. SHIA (interpreter): I'm still 9 in the case.
Page 571
Pa^e 569
1 forward slashes as an electr<mic signature on
1 president.
2 Q. Please look at 618342. 2 page 618366, didn't you?
3 A. Okay,
3 A. Yes, I did type in "TimWu." I
4 Q. This is a Response to Office Action. 4 should not have typed two slash, though.
5 A. Can I just answ2r your question 5 However, PTO accepted it.
6 directly? The personal signature of Mr. Wu is 6 MS. MENDEL: Move the admission of
7 right there under the section of Miscellaneous. 7 Government 513.
19 typed in the words "Tim Wu" because the 19 A. Yes. It " because it has a
20 original E signature was taken away by yqu. 20 different class number, this is Class 9.
21 And also, we attach the original signature of ^ 21 Q. And this is serial number 85756529?
22 Mr. Wu under the section of Miscellaneous. You 22 A. Yes. Can we not waste this time and
1 can see it in 618345. 1 if the answer would be the same, can we just
2 Q. Please look at 618365. 2 have a general answer to those questions?
3 A. Okay. 3 Q. Sure.
4 Q. This Is a Statement of Use? 4 Hill you agree that on every
5 A. Yes. 5 application that you submitted in this
6 Q. And you filed this on August 17, 6 Complaint that you signed the electronic
7 2013? 7 signature of your client?
8 A. Yes, I should be I should. 8 A. The " okay, are all these cases from
9 Q. And again, this has the electronic 9 D2014-31?
14 no need to have two slash; however, PTO 14 A. If it's E signature, it was because
15 accepted it. We must type in "Tim Wu" because 15 the original E signature from the downloaded
16 he is the real applicant. He his real 16 portable file were taken away by you.
17 signature is in the Signature part attached 17 When we - when I uploaded those
18 file. His personal signature is also shovm in 18 files, your system eliminated those E
19 G18378. So we have --we have to type in T-I-M 19 signatures and you said it says to create
20 W-U, because that's what it shov;s in 618378 in 20 new. In the program, in coniputer program, if y
21 his personal handwritten signature. 21 it says create new, it means to eliminate all u
22 Q. But you typed in "Tim Wu" between 22 Uie previous versions. Using the program \
Page 575
Pa<ge 573 1
1 language, it says reset to zero, so it will 1 Q. And you filed you personally filed
2 these, documents?
/ 2 wash out all previous data.
I couldn't sign ray name because the 3 A. Yes.
3
4 applicant and the person with firsthand 4 MS. MENDEL: All right, I would
5 knowledge was sonebody else. And that name of 5 move the admission of Government
6 that person was there, only you took it away. 6 Exhibit 14.
10 record that you signed the electronic signature 10 JUDGE FERNANDEZ: Any objection.
11 of every client that appears in the 11 Dr. Shia?
12 applications that are in that are in the 12 DR. SHIA (interpreter): No.
13 second case? And if not, I'll just go ahead 13 JUDGE FERNANDEZ: So ordered. Is
14 ani< we'll finish. I'm on the last one* Let's 14 608 in? Yes, it's just not marked on ray
15 keep going. 15 sheet.
16 A. This is only the second case? How 16 (Government Exhibit No. 514 was received
17 many cases do we have? 17 and admitted into evidence.)
18 Q. Let's just go to page 618410. Does 18 JUDGE FERNANDEZ: No, I never ruled
19 this indicate that you filed this application 19 on that, did I?
20 on October 17, 2012? 20 MS. MENDEL: I'm sorry, I I have
21 A. This 2012 expire? 21 no idea what 608 is.
22 Q. Pardon ste? 22 JUDGE FERNANDEZ: It's the
Respondent.
Respondent, through her hearing testimony, has indicated that her clients impart^ on her
ttie legal authority to bind chem in matters before the USPTO. Respondent further explained that
she may be in possession of such documents demonstrating this fact, but she would have to
check her records to confirm.
Accordingly, itis hereby ORDERED that Respondent shall file any such documents by
3;00 p.m. ETon October 31,2014.
So ORDERED,
lexandel^pemiSndez
Administrative Law Judge
HESPONDENrjs
mm
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 79 of 113 PageID# 234
pro,
Proceeding No. D2014-31
V.
Bang-er Shia,
Respondent testified at the hearing that Applicants imparted on her the legal authority
to bmd them in matters before USPTO. Counsel bears the burden to prove otherwise. The
documents attached hereto are evidence for the authorization from Applicants ofApplications
85/585,031,85/595,869,85/689,678,85/712,340,85/747,741,85/719,310,85/748,531, and
85/756,529,' compliant with the version ofTMEP 611 as ofthe filing dates ofthese eight
' The Amended Complaint ofD2014-31 alleges violations ofthe disciplinary rules related to ei^t
trademark applications not cited in. the Show Cause letter:
1) Paragraphs 1-303 were rebutted by Respondent's testimony;
2) Paragraphs 304 -340 were linked with Opposition No. 91195188, acontinued prosecution of
Application No. '647 first cited in D2014-04, dismissed by Counsel; and
3) Paragraphs 341 -347 refers to the e-signature/bang er shia/ above the signatory's name "bangcr
shia "ofApplication No. '647, compliant with 37 C.F.R. 2.193(c)(1).
Upon reporting to Applicants the filing ofthe documents to clear offthe alleged charges,
Applicants' attorneys would like Respondent to ask Commissioner and the OED why there had never
been a notice sent to Applicants ofadeficiency under 37 C.F.R. 2.193(c)(l), and ''Why wouldDr,
Shia be so dumb topay Commissioner to benefit iheApplicants, had Dr, Shia not had the legal
authority to bind theApplicants?" Submissions to the Court will be sent to Applicants' attomeys for
reference. On behalfofthe Applicants ofthese 8Applications, Respondent reserves the right to file a
complaint against Commissioner for violation of afair due process in the application of37 C.F.R.
2.193(c), for unauthorized tampering with Applicant's e-signatures inTSDR online documents, and
for discriminating the Applicants in the application of37 C.F.R. 2.193(c). Respondent also reserves
the right to seek ajudicial relieffiom Commissioner for asanction imposed by the OED in the matters
of tliis proceeding.
fl RESPONUbNI'S
1 ^ EXHlBfT ^
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 80 of 113 PageID# 235
Respectfully submitted,
Oct 20,2014
Dr. Bang-erShia
-li|W|piiihin@yahoo.com
Int'l PatentOffice ofBang Shia
102 LINDENCREST CT. SUGAR LAND TX 77479
^Paragraph wofResp. Ex. Es, namely the RFI (Request for Information) letter ofOED File
No.G2081 datedDecember 5,2012, stated "In accordance with 37 C.F.R.2.193 andTMEP
611.01(c), the use ofExhibit Gisnot permitted in defiance ofthose requirements, and to do so
may be aviolation ofUSPTO Disciplinary Rules and statutes." Exhibit Gis the authorization
ofelectronic signature for Statement ofUse of Application No. 77/691,338, which was
compelled to be submitted in proofofinnocence by Commissioner's Show Cause letter dated
January23,2012.
2
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 81 of 113 PageID# 236
Ihereby certify that aPDF version is filed with theAdministrative Uw Judge via
email to: a1j.al|@hud.gov.
Qct20.2014 tL
Dr.Bang-erShia
b8^nfeia@yahoo.com
Inf1Patent Office of Bang Shia
102LINDENCREST CT. SUGAR LANDTX 77479
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 82 of 113 PageID# 237
1.
Dr.BangerSHIA
International Patent Office of Bang Shia, INC.
102LINDENCRESTCT.
SUGAR LAND. TX 77479, U.S.A.
0^
Exwerr
85/585,031: p.1
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 84 of 113 PageID# 239
POWER OF ATTORNEY
WITH LEGAL AUTHORITY TOBIND THE APPLICANT
OtfaSgoe^af M.
C<k'' 4*^
dnu> CM-CMnOrWcng
<ttAf> DMor
<COOTACriNFORMA'nOW>
^aNtaM> 579-9966
<MiaMttwi> bitpat-banyhiaiBWi
PQPIT.
185/586,031; P.2
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 85 of 113 PageID# 240
2.
DearDnShia:
Mark; (logoonly)
Classification: 9
Appltcanl/Natlonalliy/Address
Eng Ku Optleal Industrial Co., Ud. (President:Terry Chou)
Taiwan, R.O.C
No.12, XInhebeng Rd., South DIst., Tainan Oty 702,Taiwan (R^.C)
DocMMnts Enclosed
(X; Executed
(X) Power of Attorney/Declaration
ResMMoiHf
aaSL-
85f58J69; p.1
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 87 of 113 PageID# 242
Dedaration
" Chou
President
Datat March 22.2012
contact INFORMATION:
int'l Patent Office of Bang Shia, ICQ LINDENCREST CT, SUGAR LAND
TX-77479
HkU^
BUBir .
88695.869: p.2
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 88 of 113 PageID# 243
3.
on
The
piiftnffpiHfliigMid Road. Lujia Tnwn. Kunahan City. JianiBU Provmce 21S33LChm8 for
tiademaik mattots before Ae USPTO including electronic signing for documents filed to the
USPTO fw applying die Trademark nf^fi^WR ADesign, in International CIssb 25'
exhibit
{188/689.6781 p.l
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 90 of 113 PageID# 245
<APPUCANT INPORMATIOrO
<Hm>KUNSHAN PEPWINGTEXTILECX)..LTD
<SttBel>N0.I9 Huangpujiang Mid Road,Lujia Town,Kunshan City,
<City>Jiangsu Province 215331,
<Countiy>China
'^A^auit requats r^ttnaUm cfthe (Aove4dait\fidcf^eetivemorft bithe UnludStatee PatentandVrodmark Office oti the
PrtndpdlRegltterestabttskedbyAetqfJufySt J946 QS U,S.C S i05I etieq,)/ortheJ6Uawiiiggoo(b/servfeet:''
rSondeSi?
EXHIOT.
85/689,678: P.2 i|
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 91 of 113 PageID# 246
Pcfft 2
<rrotalFi FeePaid>325
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wilhBlikfionidBBVfnItltfblBty
ffiir:h!l?Sfiiiiiinf nrt^ nVSJC.ImhuA^iAmA^Vm
'^patmr^
OiteSigned July T
George YANCAJ
" BANGDtflBIA
mCAMYON GREEK
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Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 93 of 113 PageID# 248
4.
Oflte ot sw.. WC
DearDr. Shia:
Documents:
(X) Power ofAttorney by mail later
BOgBIT
^2,340: P.I
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 95 of 113 PageID# 250
POWER OF ATTORNEY
<
This is to authorize Dr. Baneer Shia. at Infl Patent Office ofBane Shia.
DecUnitlon
Address of Applicant: No. 88. Yuwun Road. East District. Tainan qtv TW
Signature ofapplican^
NameofSignatory: Wang,
EXHtBIT
i^12^D:P.2
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 96 of 113 PageID# 251
5.
Applicant/Addtess
MIN HSIANG CORPORATION
No.99. Zhongshan 1stSt., fiuifen Dist,Tainan City 711, Taiwan (R.O.C.)
(X)PowerofAttorney (X)Execule^
i EXHBIT
1*88/747.741; P.I
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 98 of 113 PageID# 253
Bfdtritlon
The
le
y?!^ISl^iiMalc'tf^y*'^{ff!3i>^tiobeeBt8aedtoeBdiM*fa
AwltaaK ^
tUmn Wi4
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Dftitt >"'*
CONTACI WFOBMATION:
Nanr.Banter Shi
TEt!(MmM-; <3l)S-9lW
FAX: (3611 579-9966
! EXHIBIT
47,741: I
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 99 of 113 PageID# 254
6 .
Ur. ttngerSlilA
Intemsfional Patent Office ofBang Shia, INC.
102LINDENCRESTCT.
SUGAR LAND, TX 77479, U.S.A.
DearDr.SHU:
^ibiD
Title: '
i^licanu SHUANGFEl DAILY CHEMICALS USA INC
DiiectoR Zhenhui,LI
Addiess: Unit 24.212 NMain Street, North Wales, Montgomery Country, Pennsylvania
19454
Nationality: United State ofAmerica
Documents:
(X) Signed Power ofAttorney
Tssssssrr
BWOTl.
8S/713.310: P,1
POWER OF ATTORNEY
WITH LEGAL AUTHORtTY TO BIND THE APPLICANT
<SIGWATDB)BAND OTTORIKFORMATIGIO
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Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 101 of 113 PageID# 256
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 102 of 113 PageID# 257
7.
Goods/Oassification: 11
Applicant/Address
MIN HSIAN6 CORPORATtON
No.99, Zhongshan 1stSt.,Guiren Dist,Tainan Qty 711^alwan (R.O.C)
RESKNOBfTS
EXWBtr
1 8S748,5S1:P.1 i
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 104 of 113 PageID# 259
^iS!SR?SS251S!SAuc.
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Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 105 of 113 PageID# 260
8.
Documents Enclosed
iXl Power of Attfilliey.. (X)ExetMwu
RESPONDENTS
EXHIBIT .
88nr86,529: P.I
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 107 of 113 PageID# 262
Peclaration
JiraucoipotaUon*
SigBBtore: "
Names TIMW
TOe. PRESIDENT
Date:
CONTACT INFORMATION:
Name;Baneei $l>ia
Addrtn; Infl Patent Office of Bang Shia. 102 LINDENCREST CT. SUCSffi liAHD
TX 77479
The OED Director's bases for the Motion to Strike Respondent's Post-HearingExhibits
speaks to theweight the Court should afford thedocuments and notto their admissibility.
Therefore, the Courtfinds that such documents are admissible and may be considered by the
Court in reaching its decision regarding theallegations in theAmended Complaint, However, the
Court willconsiderthe parties* positions regarding these exhibits in determining how much
wei^t, ifany,to affordthem. Accordingly, the OED Director's Motion to Strike Respondent *s
Post-HearingExhibitsis DENIED.
*Respondent was afforded tho opportunity torespond tothe Motion to Strike, She did so on November 10,2014.
^kponmBt^
- EXHIBIT
A t>-
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 109 of 113 PageID# 264
wilh, ifnot contradictory to, including wthout limitations, the witness* hearing testimony, the
rules oflaw, and exhibits admitted into evidence.**
TheAmended Complaint was enteied into evidence upon motion ofthe Court Upon the
commencement ofthe hearing. Respondent appeared to be very emotional. She stated that the
procee(ting was causing her severe stress, which was resulting mconfusion and memory loss.
To assess whether Respondent was sufiBciently competent to present her case, the Court refened
to the Amended Complaint in this proceeding and asked Respondent aseries ofquestions. The
allegations contamed within, and whether she understood that the allegations contained in the
Amended Complaint formed the basis for the proceeding. After determining Respondent
recognized and understood the allegations in the Amended Complaint, the Court concluded that
Respondent had sufficient ciq)acity to proceed with the hearingpro se. The Court then, sua
sponte, admitted diei^wemferfCowp/a/nrasatrialexhibi^^use it was us^during that
particular line ofquestioning. Its admission as atrial exhibit does not establish that the
contained tfierein have been proven.
With regard to Respondent's claim that portions ofthe hearing testimony and trial
exhibits are contradictory, the Court finds that such argument relates to the wei^t the Court
should assess suchevidence and notto admissibility. Asnoted in the OrderDenying
Respondent's Motion to Sanction Counselfor the OED Director^ dated October 2,2014, "the
parties will draw different mfermces and reach different conclusions fiom the same piece of
evidence... Such disagreements are brought to the Court and resolved by the Judge.**
Therefore, indetermining whether Respondent violated the disciplinary rules, the Court may
consider allthe evidence ^propriately admitted into the record ofthis proceeding. However, as
with Respondent's post-hearing exhibits, the Court vnll consider the parties* positions, and
determine the weight afforded to the testimony and exhibits offered atthe hearing. Accordingly,
Respondent's Motion to Strike Trial Exhibit AofAmended Complaint andHearing Testimony is
DENIED.
So ORDERED,
Alexander Fem^dez ^
Administrative Law Judge
CERTIFICATE OF SERVICE
I hereby certify that copiesof this ORDER DENYING THE OED DIRECTOR*SMOTION TO
STRIKE RESPONDENT'S POST-HEARING EXHIBITS. AND RESPOIWENT'S MOTION TO
STRIKE EXHIBIT A OF AMENDED COMPLAINT AND HEARING TESTIMONY, Issued by
Alexander Fernandez,Administrative Law Judge in D2014-31, were sent to the following partieson this
20* day ofNovember, 2014, in the manner indicated: /
[y Johnson, StaffAssistant
m E-MAIL:
Dr. Bang-erShia
PatentOfficeof Bang Shia
102 Lindencrest Court
Sugar Land,TX 77479
)vahoo.com
Melinda DeAtley
Elizabeth Ullmer Mendel
Associate Solicitors
Mail Stop8
Office of the Solicitor
P.O. Box 1450
Alexandria, VA 22313-1450
^USptO.gQV
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 111 of 113 PageID# 266
Favorite Links
Name Size Type
FilesCurrently on the Disc (10)
pi Documents
1. Respondent's Exhibit 2. Respondent's Exhibit 3. Respondent's Exhibit
Pictures 85585031.pdf 85595869.pdf 85689678.pdf
Adobe Acrobat Document Adobe Acrobat Document Adobe Acrobat Document
Music
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n Adobe Acrobat Document Adobe Acrobat Document i .jd
khSSIKB
1 Respondent's Documents for
I Authorization fromApplica...
Adobe Acrobat Document
Folders
10 items
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 112 of 113 PageID# 267
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27
Case 1:16-cv-01051-AJT-MSN Document 1-2 Filed 08/17/16 Page 113 of 113 PageID# 268
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