estta tracking number: estta1052703 05/01/2020
TRANSCRIPT
Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
ESTTA Tracking number: ESTTA1052703
Filing date: 05/01/2020
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
Proceeding 91241107
Party DefendantColmont Restaurant Group, LLC
CorrespondenceAddress
WILLIAM E CARLSONSHAPIRO SHER GUINOT & SANDLER PA250 W PRATT STREET , SUITE 2000BALTIMORE, MD 21201UNITED [email protected], [email protected], [email protected]
Submission Testimony For Defendant
Filer's Name Eric R. Harlan
Filer's email [email protected], [email protected], [email protected]
Signature /erh/
Date 05/01/2020
Attachments Declaration of Anthony DiGangi.pdf(648578 bytes )Ex. A. DiGangi Declaration Application No. 87435377.pdf(1890217 bytes )Ex. B. DiGangi Declaration Restaurant Signage.pdf(622724 bytes )Ex. C. DiGangi Declaration Packaging Proofs.pdf(123389 bytes )Ex. D. DiGangi Declaration Promo Materials.pdf(391618 bytes )Ex. E. DiGangi Declaration Twitter Profile.pdf(53945 bytes )Ex. F. DiGangi Declaration Twitter Search.pdf(92213 bytes )Ex. G. DiGagni Declaration Instagram Profile.pdf(107734 bytes )Ex. H. DiGangi Declaration Instagram Search.pdf(82380 bytes )Ex. I. DiGangi Declaration SnapChat.pdf(37411 bytes )Ex. J. DiGangi Declaration Facebook.pdf(104966 bytes )Ex. K. DiGangi Declaration Web Page.pdf(582841 bytes )Ex. L. DiGangi Declaration App Screen.pdf(83893 bytes )Ex. M. DiGangi Declaration App Store Search.pdf(80793 bytes )Ex. N. DiGangi Declaration Social Media Examples.o.pdf(1573916 bytes )Ex. O. DiGangi Declaration Heggies Tweet.pdf(70388 bytes )Ex. P. DiGangi Declaration Koepp email.pdf(106268 bytes )Ex. Q. DiGangi Declaration Marketing Expenses May 2016 - December 2019[Redacted].pdf(242051 bytes )Ex. R. DiGangi Declaration Total Sales [Redacted].pdf(244483 bytes )
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
Bernatello’s Pizza, Inc., * Opposer, * In re the Matter of: Application Ser. No.: 87/435,377 v. * For the Mark: Lotsa Stone Fired Pizza Colmont Restaurant Group, LLC, * Opposition No.: 91241107 Applicant. * * * * * * * * * * * * *
DECLARATION OF ANTHONY DIGANGI
I, Anthony DiGangi, declare as follows:
1. I am over the age of 18 and currently reside in Baltimore, Maryland. I make this
declaration based on my personal knowledge.
2. I am the Chief Operating Officer of Applicant Colmont Restaurant Group, LLC
(“Colmont”).
3. Colmont is a Maryland limited liability company with its principal place of
business in Glenwood, Maryland.
4. Colmont owns and operates a chain of fast casual restaurants under the name
“LOTSA STONE FIRED PIZZA.”
5. Colmont operates such restaurants in eight locations: Annapolis, MD; College
Park, MD; Pittsburgh, PA (Oakland); Pittsburgh, PA (Southside); Morgantown, WV; West
Lafayette, IN; Chapel Hill, NC; and Tallahassee, FL.
6. Colmont formerly operated restaurants in Madison, Wisconsin (from September
7, 2016 to July 21, 2018); East Lansing, Michigan (from January 10, 2017 to November 21,
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2017); Athens, Ohio (from August 23, 2017 to June 28, 2019); and Towson, Maryland (from
May 12, 2016 to January 8, 2020).
7. Colmont offers a sit-down restaurant service at brick & mortar locations under the
LOTSA STONE FIRED PIZZA Mark. The restaurants are open seven days per week from 11:00
a.m. to 11:00 p.m. with extended hours Thursday through Saturday. (As of the writing of this
Declaration, Colmont’s restaurants have temporarily closed because of the COVID-19
Pandemic).
8. Each restaurant offers a selection of Signature Pizzas, options to Build-Your-Own
pizzas and salads, and drinks and deserts customarily offered in a restaurant setting.
9. The pizza that Colmont serves at its restaurant locations consists of fresh,
premium ingredients and toppings (typically hand-selected by customers), which is then baked
on a rotating pizza stone in an oven at 800 degrees Fahrenheit. The intense heat in Colmont’s
ovens cooks Colmont’s pizza in just 150 seconds, and creates a Neapolitan style crust with
charring around the edges.
10. When building their own pizzas, Colmont customers are offered to select from
among several types of dough, including traditional Neapolitan-style dough, a Detroit-style
dough, whole wheat dough, and gluten-free dough. The dough is hand-stretched in front of the
customer. Customers then choose from a variety of freshly made sauces, including: Red; Spicy
Red; Sweet Agave Red; Olive Oil; Buffalo; Barbeque; and Alfredo.
11. Customers may then choose from among the following freshly made (never
frozen) cheeses: Shredded Mozzarella; Traditional Fresh Mozzarella; Ricotta; Blue Cheese;
Cheddar Jack; Shaved Parmesan; and Vegan. Next, customers may add any of the following
proteins: Pepperoni; Italian Sausage; Bacon; Chicken; Crumbled Meatball; Italian Ham; and
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Anchovies. (Because the proteins—chicken, sausage, bacon, meatball, ham and pepperoni—are
pre-cooked, they are delivered to Colmont restaurants frozen and then thawed prior to being
offered as a topping).
12. Colmont also offers a wide variety of fresh—never frozen—vegetables and other
toppings that a customer may add to his or her pizza, including: Banana Peppers; Mushrooms;
Red Onion; Black Olives; Jalapeño Peppers; Roasted Garlic; Tomatoes; Green Peppers; Spinach;
Artichokes; Roasted Red Peppers; and Pineapple.
13. Following quick-firing in Colmont’s 800 F oven, customers are offered a
selection of finishings, including: Balsamic Glaze, Barbeque Sauce; Hot Sauce; Ranch Dressing;
Pesto; Blue Cheese Dressing; Grated Parmesan; Basil; Oregano; Crushed Red Pepper; Garlic
Powder; and Salt and Pepper. Customers may choose as few or as many of the above ingredients
whenever they visit a LOTSA STONE FIRED PIZZA restaurant, which allows each customer
always to create his or her own specialized and uniquely personal pizza.
14. Colmont also serves salads, bread sticks, and desserts. It offers its food for dine-
in and carryout. Colmont’s stone fired pizza is not offered for sale through grocery stores or any
third-party outlets; it is available only at its LOTSA STONE FIRED PIZZA restaurants.
15. Colmont does not serve or sell a frozen pizza product. Every pizza that Colmont
serves is made with generous portions of a wide variety of the ingredients described above, and
then stone-fired in intensely hot ovens.
16. Colmont owns U.S. Trademark Application No. 87/435,377 filed May 3, 2017 for
LOTSA STONE FIRED PIZZA as applied to “Restaurant services; Restaurant carry out
services; Restaurants featuring delivery services; Fast casual restaurants.” Attached as Exhibit A
is a true and correct copy of this Application.
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17. “LOTSA STONE FIRED PIZZA” is dominant in all signage, advertising, exterior
and interior restaurant fixtures, menus, cups, pizza boxes, and pizza liners at each of Colmont’s
restaurants. Attached as Exhibit B are photographs of the interior and exterior signage at
Colmont’s restaurants. Attached as Exhibit C are proofs of Colmont’s LOTSA STONE FIRED
PIZZA branded pizza boxes, liners and cups that are in use at Colmont’s restaurants.
18. Colmont’s LOTSA STONE FIRED MARK is also dominant on restaurant
promotional materials. Attached as Exhibit D are photographs of some of Colmont’s
promotional materials, including key chains, ping pong balls, T-shirts, and drink sleeves.
19. Colmont began using the mark LOTSA STONE FIRED PIZZA in commerce on
May 5, 2016 at its Morgantown, West Virginia restaurant location and has used the mark
continuously in commerce since that date.
20. Colmont’s Mark includes the words “STONE FIRED” in reference to Colmont’s
pizza being fast cooked on a flame-heated rotating pizza stone.
21. In connection with the marketing of Colmont’s Lotsa Stone Fired Pizza restaurant
services, it maintains a presence on various social media platforms such as Twitter, Instagtram,
and SnapChat. Colmont’s Twitter page shows the “Lotsa Stone Fired Pizza” logo and “LOTSA
Stone Fired Pizza” as the name of the account. In addition, each Twitter post bears the name
“LOTSA Stone Fired Pizza.” A true and accurate example of Colmont’s Twitter home page is
attached hereto as Exhibit E. In addition, a true and accurate screenshot of the results for a
search of “Lotsa” on Twitter on April 27, 2020 is attached hereto as Exhibit F.
22. Colmont’s Instrgram page bears the “Lotsa Stone Fired Pizza” logo and name
prominently. A true and accurate example of Colmont’s Instagram page is attached hereto as
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Exhibit G. In addition, a true and accurate screenshot of the results for a search of “Lotsa” on
Instagram on April 27, 2020 is attached hereto as Exhibit H.
23. Colmont’s Snapchat profile also displays the full “Lotsa Stone Fired Pizza” name.
A true and accurate copy of its Snapchat profile is attached hereto as Exhibit I.
24. Colmont maintains a Facebook page for its LOTSA STONE FIRED PIZZA
restaurants. Its Facebook page and each of its Facebook posts bear the LOTSA STONE FIRED
PIZZA logo and the name LOTSA STONE FIRED PIZZA prominently. A true an accurate
image of Colmont’s Facebook page is attached as Exhibit J.
25. Colmont also maintains a website, www.lotsa.com, for its LOTSA STONE
FIRED PIZZA restaurants. Its logo and name, LOTSA STONE FIRED PIZZA appear
prominently on the website. A true and accurate example of Colmont’s LOTSA STONE FIRED
PIZZA restaurant webpage is attached hereto as Exhibit K.
26. Colmont provides an application that restaurant customers can download on
mobile devices and through which they can have access to restaurant promotions, and may order
ahead and pay. An image of the app’s home screen, which displays Colmont’s LOTSA STONE
FIRED PIZZA mark and its logo is attached hereto as Exhibit L. An April 27, 2020 search of
“Lotsa” in the Apple mobile app store reveals multiple apps that contain the word “lotsa.” A
screen shot of said search is attached hereto as Exhibit M.
27. Additional examples of the LOTSA STONE FIRED PIZZA social media
presence across Facebook, Twitter, Instagram and app stores are attached hereto as Exhibit N.
28. In December 2016, a Twitter user, Mac Wilson, intending to poke fun at
Bernatello’s Pizza, Inc. tagged the LOTSA STONE FIRED PIZZA Twitter Account
inadvertently by misspelling Bernatello’s Mark as “LOTSA MOZZA” in his Twitter post. The
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specific tweet is referenced as https://twitter.com/cinatyte/status/805965657531699200 by Mr.
Wilson in an email exchange with me. (The e-mail was attached to Opposer’s Second Notice of
Reliance, at 16 TTABVUE 169, in a document labeled COLMONT000757). A true and
accurate copy of Mr. Wilson’s tweet from the referenced URL is attached hereto as Exhibit O.
29. “Lotsa Mozza” was a name used by Colmont’s predecessor before it rebranded as
LOTSA STONE FIRED PIZZA. The name “Lotsa Mozza” originated from the family of Victor
Corbi, which family owned a pizza business in the Baltimore area. I recall seeing a photograph
of a young Victor Corbi wearing a T-Shirt with the phrase “Lotsa Mozza” printed on it.
30. Colmont maintained the domain name www.lotsamozza.com; it is not an active
site but does redirect to Colmont’s current website, www.lotsa.com. When one enters the
www.lotzzamotzza.com domain name into an internet browser, that domain re-directs to
www.bernatellos.com, Opposer’s website.
31. On October 4, 2018, an individual, who identified herself as Jodi Koepp, sent an
email to [email protected] which is the email address that receives contact inquiries from the
“Contact Us” link on the lotsa.com webpage. A copy of that email is attached hereto as Exhibit
P. At that time, the “Contact Us” link required individuals to provide their name, e-mail address,
and telephone number, and to also select, from a drop-down menu, the particular restaurant
location about which the individual was contacting Colmont. In October of 2018, the “Contact
Us” page did not have an option to contact Colmont’s corporate office; only restaurant locations
were listed, with Colmont’s Annapolis, Maryland location appearing first in the menu. The
“Contact Us” page also contains a “How can we help you?” space for an individual to provide
comments.
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32. Ms. Koepp’s contact inquiry was directed to the Annapolis, Maryland location,
and stated “Im a customer that purchases pizza fries from lotsa motsa. I have a complaint and
was wondering who i talk to.” (See Ex. P.). I contacted Ms. Koepp via the telephone number
she provided and learned that she was from Wisconsin and was referring to a frozen pizza
product, which I concluded was a Bernatello’s product. Colmont does not make or sell “pizza
fries.”
33. Colmont has developed advertising and marketing strategies in an effort to
promote its restaurant services and fresh pizza provided under the LOTSA STONE FIRED
PIZZA mark. These include in-store and mobile app promotions, social media advertising, radio
advertising, and fundraising campaigns. Since it began offering its restaurant services under the
LOTSA STONE FIRED PIZZA mark, Colmont has expended $727,502.44 on marketing and
promoting its restaurant services. Attached as Exhibit Q is a true and correct copy of a business
record of Colmont setting forth the above marketing expenses.
34. Since it began offering its restaurant services under the LOTSA STONE FIRED
PIZZA mark, Colmont has realized sales over the years, as follows:
May 2016 - December 2016: $1,796,432.88
2017: $5,676,447.33
2018: $6,295,994.41
2019: $5,667,354.51
Attached as Exhibit R is a true and correct copy of a business record of Colmont setting forth
the above revenue.
35. At no time has Colmont ever referred to its restaurant as “LOTZZA” nor has it
used the terms “LOTZZA” or “MOTZZA,” individually or combination, in regards to its
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restaurant services in any marketing, promotional, social medial, website, or other such
materials.
I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge.
Executed this day of April, 2020.
Anthony DiGangi
30th
CERTIFICATE OF SERVICE
I hereby certify that on this this 1st day of May, 2020, a copy of Applicant Colmont
Restaurant Group, LLC’s Declaration of Anthony DiGangi in the above matter, with its attached
exhibits, was served upon Opposer, addressed as follows:
Via Electronic Delivery
Laura M. Davis, Esquire Harry E. Van Camp, Esquire DeWitt, LLP Two East Mifflin Street, Suite 110 Madison, WI 53703-2865 [email protected] [email protected] Anthony J. Bourget, Esquire Wendy Fenske, Esquire BOURGET LAW, S.C. P.O. Box 81 1119 Regis Court, Suite 110 Eau Claire, Wisconsin 54702 [email protected] [email protected] Attorneys for Opposer Bernatello’s Pizza, Inc.
/s/ Eric R. Harlan
Eric R. Harlan
Under the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless it displays a valid OMB control number. PTO Form 1478 (Rev 09/2006)
OMB No. 0651-0009 (Exp 02/28/2018)
Trademark/Service Mark Application, Principal Register
Serial Number: 87435377
Filing Date: 05/03/2017
The table below presents the data as entered.
Input Field Entered
SERIAL NUMBER 87435377
MARK INFORMATION
*MARK Lotsa Stone Fired Pizza
STANDARD CHARACTERS YES
USPTO-GENERATED IMAGE YES
LITERAL ELEMENT Lotsa Stone Fired Pizza
MARK STATEMENTThe mark consists of standard characters, without claim to any particular font
style, size, or color.
REGISTER Principal
APPLICANT INFORMATION
*OWNER OF MARK Colmont Restaurant Group, LLC
INTERNAL ADDRESS Suite 12
*STREET 2480 Rte. 97
*CITY Glenwood
*STATE
(Required for U.S. applicants)Maryland
*COUNTRY United States
*ZIP/POSTAL CODE
(Required for U.S. and certain international addresses)21738
LEGAL ENTITY INFORMATION
TYPE limited liability company
STATE/COUNTRY WHERE LEGALLY
ORGANIZEDMaryland
GOODS AND/OR SERVICES AND BASIS INFORMATION
INTERNATIONAL CLASS 043
*IDENTIFICATIONRestaurant services; Restaurant carry out services; Restaurants featuring
delivery services; Fast casual restaurants.
FILING BASIS SECTION 1(a)
FIRST USE ANYWHERE DATE At least as early as 05/05/2016
FIRST USE IN COMMERCE DATE At least as early as 05/05/2016
SPECIMEN FILE NAME(S)
ORIGINAL PDF FILE SPE0-38124154210-20170503160213266178_._1_-_menu__online_.pdf
Exhibit AApplication No. 87435377
CONVERTED PDF FILE(S)
(3 pages)\\TICRS\EXPORT17\IMAGEOUT17\874\353\87435377\xml1\RFA0003.JPG
\\TICRS\EXPORT17\IMAGEOUT17\874\353\87435377\xml1\RFA0004.JPG
\\TICRS\EXPORT17\IMAGEOUT17\874\353\87435377\xml1\RFA0005.JPG
ORIGINAL PDF FILE SPE0-38124154210-20170503160213266178_._2_-_signage.pdf
CONVERTED PDF FILE(S)
(3 pages)\\TICRS\EXPORT17\IMAGEOUT17\874\353\87435377\xml1\RFA0006.JPG
\\TICRS\EXPORT17\IMAGEOUT17\874\353\87435377\xml1\RFA0007.JPG
\\TICRS\EXPORT17\IMAGEOUT17\874\353\87435377\xml1\RFA0008.JPG
SPECIMEN DESCRIPTION digital images of menu and signs
ATTORNEY INFORMATION
NAME William E. Carlson
FIRM NAME Shapiro Sher Guinot & Sandler, P.A.
INTERNAL ADDRESS Suite 2000
STREET 250 W. Pratt Street
CITY Baltimore
STATE Maryland
COUNTRY United States
ZIP/POSTAL CODE 21201
PHONE 410-385-0202
EMAIL ADDRESS [email protected]
AUTHORIZED TO COMMUNICATE VIA EMAIL Yes
CORRESPONDENCE INFORMATION
NAME William E. Carlson
FIRM NAME Shapiro Sher Guinot & Sandler, P.A.
INTERNAL ADDRESS Suite 2000
STREET 250 W. Pratt Street
CITY Baltimore
STATE Maryland
COUNTRY United States
ZIP/POSTAL CODE 21201
PHONE 410-385-0202
*EMAIL ADDRESS [email protected]
*AUTHORIZED TO COMMUNICATE VIA EMAIL Yes
FEE INFORMATION
APPLICATION FILING OPTION TEAS RF
NUMBER OF CLASSES 1
APPLICATION FOR REGISTRATION PER CLASS 275
*TOTAL FEE DUE 275
*TOTAL FEE PAID 275
SIGNATURE INFORMATION
SIGNATURE /wec/
SIGNATORY'S NAME William E. Carlson
SIGNATORY'S POSITION Attorney of Record, Maryland bar member
SIGNATORY'S PHONE NUMBER 410-385-0202
DATE SIGNED 05/03/2017
Under the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless it displays a valid OMB control number. PTO Form 1478 (Rev 09/2006)
OMB No. 0651-0009 (Exp 02/28/2018)
Trademark/Service Mark Application, Principal Register
Serial Number: 87435377
Filing Date: 05/03/2017
To the Commissioner for Trademarks:
MARK: Lotsa Stone Fired Pizza (Standard Characters, see mark)
The literal element of the mark consists of Lotsa Stone Fired Pizza.
The mark consists of standard characters, without claim to any particular font style, size, or color.
The applicant, Colmont Restaurant Group, LLC, a limited liability company legally organized under the laws of Maryland, having an address of
Suite 12
2480 Rte. 97
Glenwood, Maryland 21738
United States
requests registration of the trademark/service mark identified above in the United States Patent and Trademark Office on the Principal Register
established by the Act of July 5, 1946 (15 U.S.C. Section 1051 et seq.), as amended, for the following:
International Class 043: Restaurant services; Restaurant carry out services; Restaurants featuring delivery services; Fast casual restaurants.
In International Class 043, the mark was first used by the applicant or the applicant's related company or licensee or predecessor in interest at
least as early as 05/05/2016, and first used in commerce at least as early as 05/05/2016, and is now in use in such commerce. The applicant is
submitting one(or more) specimen(s) showing the mark as used in commerce on or in connection with any item in the class of listed
goods/services, consisting of a(n) digital images of menu and signs.
Original PDF file:
SPE0-38124154210-20170503160213266178_._1_-_menu__online_.pdf
Converted PDF file(s) (3 pages)
Specimen File1
Specimen File2
Specimen File3
Original PDF file:
SPE0-38124154210-20170503160213266178_._2_-_signage.pdf
Converted PDF file(s) (3 pages)
Specimen File1
Specimen File2
Specimen File3
The applicant's current Attorney Information:
William E. Carlson of Shapiro Sher Guinot & Sandler, P.A.
Suite 2000
250 W. Pratt Street
Baltimore, Maryland 21201
United States
410-385-0202(phone)
[email protected] (authorized)
The applicant's current Correspondence Information:
William E. Carlson
Shapiro Sher Guinot & Sandler, P.A.
Suite 2000
250 W. Pratt Street
Baltimore, Maryland 21201
410-385-0202(phone)
[email protected] (authorized)
E-mail Authorization: I authorize the USPTO to send e-mail correspondence concerning the application to the applicant, the applicant's
attorney, or the applicant's domestic representative at the e-mail address provided in this application. I understand that a valid e-mail address
must be maintained and that the applicant or the applicant's attorney must file the relevant subsequent application-related submissions via the
Trademark Electronic Application System (TEAS). Failure to do so will result in the loss of TEAS Reduced Fee status and a requirement to
submit an additional processing fee of $125 per international class of goods/services.
A fee payment in the amount of $275 has been submitted with the application, representing payment for 1 class(es).
Declaration
Basis:
If the applicant is filing the application based on use in commerce under 15 U.S.C. § 1051(a):
The signatory believes that the applicant is the owner of the trademark/service mark sought to be registered;
The mark is in use in commerce on or in connection with the goods/services in the application;
The specimen(s) shows the mark as used on or in connection with the goods/services in the application; and
To the best of the signatory's knowledge and belief, the facts recited in the application are accurate.
And/Or
If the applicant is filing the application based on an intent to use the mark in commerce under 15 U.S.C. § 1051(b), § 1126(d),
and/or § 1126(e):
The signatory believes that the applicant is entitled to use the mark in commerce;
The applicant has a bona fide intention to use the mark in commerce on or in connection with the goods/services in the
application; and
To the best of the signatory's knowledge and belief, the facts recited in the application are accurate.
To the best of the signatory's knowledge and belief, no other persons, except, if applicable, concurrent users, have the right to use the
mark in commerce, either in the identical form or in such near resemblance as to be likely, when used on or in connection with the
goods/services of such other persons, to cause confusion or mistake, or to deceive.
To the best of the signatory's knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, the
allegations and other factual contentions made above have evidentiary support.
The signatory being warned that willful false statements and the like are punishable by fine or imprisonment, or both, under 18 U.S.C. §
1001, and that such willful false statements and the like may jeopardize the validity of the application or submission or any registration
resulting therefrom, declares that all statements made of his/her own knowledge are true and all statements made on information and
belief are believed to be true.
Declaration Signature
Signature: /wec/ Date: 05/03/2017
Signatory's Name: William E. Carlson
Signatory's Position: Attorney of Record, Maryland bar member
Payment Sale Number: 87435377
Payment Accounting Date: 05/04/2017
Serial Number: 87435377
Internet Transmission Date: Wed May 03 16:13:27 EDT 2017
TEAS Stamp: USPTO/BAS-XX.XXX.XXX.XXX-201705031613273
69394-87435377-5901425c77c05fcf9ab9438f7
5e2a2b77ed0ae422397a26e7de948faa3bb1582-
CC-2975-20170503160213266178
Exhibit BRestaurant Signage
Exhibit C
Packaging Proofs
Exhibit D
Promo Materials
Exhibit E
Twitter Profile
Exhibit FTwitter Search
Exhibit GInstagram Profile
Exhibit HInstagram Search
Exhibit I
SnapChat
Exhibit JFacebook
Exhibit K
Web Page
Exhibit LApp Screen
Exhibit MApp Store Search
Exhibit N
Social Media Examples
Exhibit OHeggies Tweet
Exhibit PKoepp email
Summary
Page 1 of 2
ATTORNEYS' EYES ONLY Exhibit Q
Jan 2018 - Dec 2019
Page 2 of 2
ATTORNEYS' EYES ONLY Exhibit Q
Sheet1
Page 1 of 1
ATTORNEYS' EYES ONLYExhibit R