Amicus Curiae Brief — United States Patent and Trademark Office, et al., Petitioners v. Booking.com B.V.

NO. 19-46

In the Supreme Court of the United States

________________

UNITED STATES PATENT AND TRADEMARK OFFICE ET AL.,

PETITIONERS,

v.

BOOKING.COM B.V.,

RESPONDENT.

________________

ON WRIT OF CERTIORARI TO THE

UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

________________

BRIEF OF THE INTELLECTUAL PROPERTY LAW

ASSOCIATION OF CHICAGO AS AMICUS CURIAE IN

SUPPORT OF RESPONDENT BOOKING.COM B.V.

__________________________________

OF COUNSEL

Counsel

MARC V. RICHARDS

PRESIDENT-ELECT

THE INTELLECTUAL PROPERTY

LAW ASSOCIATION OF

CHICAGO

P.O. Box 472

Chicago, IL 60690

(312) 321-4200

JUDY K. HE

Haynes and Boone, LLP

180 North LaSalle Street,

Suite 2215

Chicago, IL 60601

judy.he@haynesboone.com

(312) 216-1620

February 19, 2020

MARGARET M. DUNCAN

Counsel of Record

Loyola University

Chicago School of Law

25 East Pearson Street

Chicago, IL 60611

mduncan@luc.edu

(312) 915-7120

i

TABLE OF CONTENTS

Page

INTEREST OF AMICUS CURIAE.............................1

SUMMARY OF FACTS ...............................................2

ISSUES PRESENTED ................................................4

SUMMARY OF ARGUMENT .....................................5

ARGUMENT ...............................................................6

I. Whether A Term Is Generic Should Be

Determined By The Fact-Specific “Primary

Significance” Test. ...................................................6

II. The USPTO’s Concerns Regarding Monopoly

Power Are Misplaced. ..............................................9

CONCLUSION .......................................................... 13

ii

TABLE OF AUTHORITIES

Cases

Advertise.com, Inc. v. AOL Advert., Inc.,

616 F.3d 974 (9th Cir. 2010) ...................................8

Booking.com B.V. v. Matal,

278 F. Supp. 3d 891 (E.D. Va. 2017). ........... passim

Booking.com B.V. v. United States Patent &

Trademark Office,

915 F.3d 171 (4th Cir. 2019) ......................... passim

CES Publ’g Corp. v. St. Regis Publ’ns, Inc.,

531 F.2d 11 (2d Cir. 1975) .................................... 10

Door Sys., Inc. v. Pro-Line Door Sys., Inc.,

83 F.3d 169 (7th Cir. 1996) .....................................8

Goodyear’s India Rubber Glove Mfg. v. Goodyear

Rubber Co.,

128 U.S. 598 (1888) .................................................7

Henri’s Food Prods. Co. v. Tasty Snacks, Inc.,

817 F.2d 1303 (7th Cir. 1987) ............................... 12

In re 1800Mattress.com IP, LLC,

586 F.3d 1359 (Fed. Cir. 2009) ...............................6

In re Hotels.com, L.P.,

573 F.3d 1300 (Fed. Cir. 2009) ...............................8

In re Hunke & Jochheim,

185 U.S.P.Q. 188 (T.T.A.B. 1975) ......................... 12

In re Reed Elsevier Props.,

482 F.3d 1376 (Fed. Cir. 2007) ...............................6

In re Steelbuilding.com,

415 F.3d 1293 (Fed. Cir. 2005) ........................... 7, 8

iii

Juice Generation, Inc. v. GS Enters. LLC,

794 F.3d 1334 (Fed. Cir. 2015) ............................. 12

Kellogg Co. v. National Biscuit Co.,

305 U.S. 111 (1938) .................................................7

Liquid Controls Corp. v. Liquid Control Corp.,

802 F.2d 934 (7th Cir. 1986) ...................................8

Princeton Vanguard, LLC v. Frito-Lay North

America, Inc.,

786 F.3d 960 (Fed. Cir. 2015) .................................8

Swatch AG v. Beehive Wholesale, LLC,

739 F.3d 150 (4th Cir. 2014) ...................................9

Te-Ta-Ma Truth Found.—Family of URI, Inc. v.

World Church of the Creator,

297 F.3d 662 (7th Cir. 2002) ................................. 10

Ty Inc. v. Softbelly’s Inc.,

353 F.3d 528 (7th Cir. 2003) ............................... 7, 8

Statutes

15 U.S.C. § 1064(3) ............................................ 5, 6, 13

15 U.S.C. § 1125(d) .................................................... 11

Other Authorities

106 CONG. REC. S10,513 (daily ed. Aug. 5, 1999) ..... 11

S. REP. NO. 106-140 (1999). ....................................... 11

U.S. PAT. AND TRADEMARK OFF., TRADEMARK

ELECTRONIC SEARCH SYSTEM,

http://tmsearch.uspto.gov/bin/gate.exe?f=

tess&state=4802:j6niem.1.1 (last visited Feb.

18, 2020) ..................................................................3

U.S. Trademark Application Serial No.

79/114,998 (filed June 5, 2012) ...............................3

iv

U.S. Trademark Application Serial No.

79/122,365 (filed Nov. 7, 2012) ...............................3

U.S. Trademark Application Serial No.

79/122,366 (filed Nov. 7, 2012) ...............................3

U.S. Trademark Application Serial No.

85/485,097 (filed Dec. 1, 2011) ................................3

Rules

TMEP § 1215.05 (Oct. 2018). ......................................7

Treatises

2 J. THOMAS MCCARTHY, MCCARTHY ON

TRADEMARKS AND UNFAIR COMPETITION (5th

ed. 2019) .................................................. 6, 9, 12, 13

INTEREST OF AMICUS CURIAE1

The Intellectual Property Law Association of

Chicago (“IPLAC”) respectfully requests that this

Court affirm the Fourth Circuit’s decision in

Booking.com B.V. v. United States Patent &

Trademark Office, 915 F.3d 171 (4th Cir. 2019).2

Founded in 1884 in Chicago, Illinois, a principal

forum for U.S. technological innovation and

intellectual property litigation, IPLAC is the country’s

oldest bar association devoted exclusively to

intellectual property matters. IPLAC has as its

governing objects, inter alia, to aid in the development

of intellectual property laws, the administration of

them, and the procedures of the U.S. Patent and

Trademark Office, the U.S. Copyright Office, and the

U.S. courts and other officers and tribunals charged

with administration. IPLAC’s about 1,000 voluntary

members include attorneys in private and corporate

practices in the areas of copyrights, patents,

trademarks, trade secrets, and the legal issues they

present before federal courts throughout the United

States, as well as before the U.S. Patent and

1

Pursuant to Supreme Court Rule 37.6, no counsel for a

party authored this brief in whole or in part and no such counsel,

or party made a monetary contribution intended to fund the

preparation or submission of this brief. No person or entity, other

than Amicus, its members or its counsel, has made a monetary

contribution to the preparation or submission of this brief.

2

Pursuant to Supreme Court Rule 37.3(a), both Petitioners

and Respondent have provided written consents to IPLAC’s filing

of this brief.

2

Trademark Office and the U.S. Copyright Office.3

IPLAC’s members represent innovators and accused

infringers in roughly equal measure and are split

roughly equally between plaintiffs and defendants in

litigation.

As part of its central objectives, IPLAC is

dedicated to aiding in developing intellectual property

law, especially in the federal courts.4

SUMMARY OF FACTS

5

Booking.com B.V. (“Booking.com”)6 filed four

trademark applications in 2011 and 2012 involving

the mark “BOOKING.COM” for, inter alia, services

directed generally to providing information about, and

3

In addition to the statement of footnote 1, after reasonable

investigation, IPLAC believes that (a) no member of its Board or

Amicus Committee who voted to prepare this brief, or any

attorney in the law firm or corporation of such a member,

represents a party to this litigation in this matter; (b) no

representative of any party to this litigation participated in the

authorship of this brief; and (c) no one other than IPLAC, or its

members who authored this brief and their law firms or

employers, made a monetary contribution to the preparation or

submission of this brief.

4

Although over 30 federal judges are honorary members of

IPLAC, none were consulted on, or participated in, this brief.

5

See generally Booking.com B.V. v. United States Patent and

Trademark Office, 915 F.3d 171 (4th Cir. 2019).

6

For purposes of this brief, “Booking.com” refers to

Respondent and “BOOKING.COM” refers to the proposed mark.

3

assisting with hotel, resort,

accommodation reservations.7

and

temporary

The United States Patent and Trademark Office

(“USPTO”) denied the applications, finding that

BOOKING.COM was generic for the services offered

or, in the alternative, that the mark was descriptive

and that Booking.com had failed to show the mark

had acquired distinctiveness.

The Trademark Trial and Appeal Board (“TTAB”)

of the USPTO affirmed, finding that BOOKING.COM

comprises a generic second-level domain (“SLD”) and

“.com,” a top-level domain (“TLD”) that means a

commercial website. In effect, the TTAB concluded

that BOOKING.COM is generic because customers

would understand the mark to “primarily [] refer to an

online reservation service for travel, tours, and

lodging, which is consistent with the services

proposed in the applications.” Booking.com B.V. v.

Matal, 278 F. Supp. 3d 891, 898 (E.D. Va. 2017)

(internal citations omitted). In the alternative, the

TTAB also found that BOOKING.COM was

descriptive but lacked a showing of acquired

distinctiveness.

7

See, e.g., U.S. Trademark Application Serial Nos.

85/485,097 (filed Dec. 1, 2011); 79/114,998 (filed June 5, 2012);

and 79/122,365 and 79/122,366 (both filed Nov. 7, 2012).

According to the USPTO’s Trademark Electronic Search System,

the ’097 and ’998 applications have been abandoned. U.S. PAT.

AND TRADEMARK OFF., TRADEMARK ELECTRONIC SEARCH SYSTEM,

http://tmsearch.uspto.gov/bin/gate.exe?f=tess&state=4809:9e70

qe.1.1 (last visited Feb. 18, 2020).

4

On April 15, 2016, Booking.com sued the USPTO

under 15 U.S.C. § 1071(b) in the U.S. District Court

for the Eastern District of Virginia. Both sides moved

for summary judgment, and in 2017, the district court

found that BOOKING.COM was descriptive. The

district court further found that the record evidence,

including a consumer survey “reveal[ing] that 74.8

percent

of

[survey]

respondents

identified

BOOKING.COM as a brand name,” showed that the

mark had acquired distinctiveness for the relevant

services. Id. at 915. The district court then ordered the

USPTO to register BOOKING.COM for two of the four

applications and remanded for further administrative

proceedings on the other two.

The USPTO appealed to the U.S. Court of Appeals

for the Fourth Circuit, challenging whether

BOOKING.COM can be protected as a mark. The

Fourth Circuit applied the fact-specific “primary

significance” test and affirmed the district court’s

holding, finding that “when ‘.com’ is combined with an

SLD, even a generic SLD, the resulting composite may

be non-generic where evidence demonstrates that the

mark’s primary significance to the public as a whole is

the source, not the product.” Booking.com B.V., 915

F.3d at 186.

Petitioners appeal.

ISSUES PRESENTED

Under the Lanham Act, 15 U.S.C. § 1051 et seq.,

generic terms may not be registered as trademarks.

This case questions whether the addition by an online

business of a generic top-level domain (“.com”) to an

5

otherwise generic term can create a protectable

trademark.

IPLAC respectfully submits that the answer to this

question depends on the proper test for determining

whether a proposed trademark or service mark,

including a domain name comprising a TLD (e.g.,

“.com” or hundreds of other possible choices) and a

generic SLD, when taken as a whole, is generic and

can never serve as a source identifier for particular

goods or services.

SUMMARY OF ARGUMENT

The Court should affirm the Fourth Circuit’s

decision and find that the test for determining

whether a proposed trademark or service mark,

including a domain name, is generic and can never be

protected as a source identifier for particular goods or

services is the fact-specific “primary significance” test

set forth in 15 U.S.C. § 1064(3), which can involve

source-identifying evidence such as consumer

surveys.

The USPTO’s concerns regarding monopoly power

are misplaced. First, a domain name such as

BOOKING.COM does not provide monopoly power,

but rather is simply a unique online address for a user

to locate information (e.g., regarding a particular

company’s goods or services) on the Internet. Second,

courts have addressed monopoly concerns regarding

descriptive marks for decades by granting them a

narrower scope of protection than stronger marks,

such as fanciful, arbitrary or suggestive marks.

6

ARGUMENT

I.

WHETHER A TERM IS GENERIC

SHOULD BE DETERMINED BY THE

FACT-SPECIFIC “PRIMARY

SIGNIFICANCE” TEST.

The Court should affirm the Fourth Circuit’s

decision and hold that the test for whether a

trademark or service mark, including a domain name,

is generic is the fact-specific “primary-significance”

test set forth in 15 U.S.C. § 1064(3). It should reject a

rule that a domain name comprising a generic term or

terms, when taken as a whole, for particular goods or

services, is per se generic and therefore cannot be

registered as a trademark or service mark.

Both the Fourth and Federal Circuits have

adopted the “primary significance” test to determine

if a mark is generic in registration proceedings.8 See,

e.g., Booking.com B.V., 915 F.3d at 180 n.6; In re

1800Mattress.com IP, LLC, 586 F.3d 1359, 1362-63

(Fed. Cir. 2009); In re Reed Elsevier Props., 482 F.3d

1376, 1378 (Fed. Cir. 2007). Indeed, the Seventh

8

Other circuits have also adopted the fact-specific “primary

significance” test to determine if a mark is generic. 2 J. THOMAS

MCCARTHY, MCCARTHY ON TRADEMARKS AND UNFAIR

COMPETITION § 12:6, at 12-27, n.2 (5th ed. 2019) (collecting

cases). As Respondent’s brief observes, “[c]ourts and the

[US]PTO consistently interpret section 1064(3) as mandating

application of the primary-significance test in the registration

context.” Resp’t Br. at 20, 20 n.4. For the sake of conciseness and

for the convenience of the Court, this brief incorporates by

reference those cites.

7

Circuit has also recognized that “the legal test of

genericness is ‘primary significance.’” Ty Inc. v.

Softbelly’s Inc., 353 F.3d 528, 530-31 (7th Cir. 2003)

(quoting Kellogg Co. v. National Biscuit Co., 305 U.S.

111, 118-19 (1938)). This test is flexible and requires

evidence showing that “the primary significance of the

term in the minds of the consuming public is not the

product but the producer.” Kellogg, 305 U.S. at 118.

The USPTO contends that, under Goodyear’s India

Rubber Glove Mfg. v. Goodyear Rubber Co., 128 U.S.

598 (1888), a generic SLD plus a TLD necessarily

results in a generic composite as a matter of law. But

as the Fourth Circuit found, “[n]o circuit has adopted

the bright line rule for which the USPTO advocates.”

Booking.com B.V., 915 F.3d at 184. Other amici also

have highlighted that the USPTO’s own Trademark

Manual of Examining Procedure (“TMEP”) states that

“there is no per se rule that the addition of a nonsource-identifying [generic TLD] to an otherwise

generic term can never under any circumstances

operate to create a registrable mark.” TMEP § 1215.05

(Oct. 2018).

There is no reason to adopt a bright line rule for

domain names. As the Federal Circuit has recognized,

in rare instances, “the addition of a TLD indicator to

a descriptive term operate[s] to create a distinctive

mark” that may be eligible for trademark protection.

In re Steelbuilding.com, 415 F.3d 1293, 1297 (Fed.

Cir. 2005). Adopting a bright line rule would condemn

those marks to genericness as a matter of law and

deprive them forever of any trademark or service

mark protection regardless of any evidence concerning

their source-identifying significance.

8

In addition, “[c]ertain terms may connote more

than the sum of their parts,” and courts should “take

care to decide the genericness of these terms by

looking to the whole.” Liquid Controls Corp. v. Liquid

Control Corp., 802 F.2d 934, 938 (7th Cir. 1986). That

applies equally to domain names. “Because the

evaluation of a mark proposed for registration

requires consideration of the mark as a whole, the

distinctiveness derived from a connection to the

Internet, as indicated by the TLD indicator, is a part

of

the

calculus

for

registration.”

In re

Steelbuilding.com, 415 F.3d at 1297. A flexible test

best permits those considerations and should be

adopted by this Court.

The USPTO also challenges the relevance of

Booking.com’s consumer survey evidence, arguing

that the survey conflates the distinction between

generic and descriptive marks. But genericness is a

question of fact. See, e.g., Booking.com B.V., 915 F.3d

at 181; Advertise.com, Inc. v. AOL Advert., Inc., 616

F.3d 974, 977 (9th Cir. 2010); In re Hotels.com, L.P.,

573 F.3d 1300, 1301 (Fed. Cir. 2009); Door Sys., Inc.

v. Pro-Line Door Sys., Inc., 83 F.3d 169, 171 (7th Cir.

1996).

“More precisely, the question of genericness is one

of linguistic usage, and can be approached by a variety

of routes.” Door Sys., 83 F.3d at 171. One commonly

accepted route is consumer surveys. See, e.g.,

Princeton Vanguard, LLC v. Frito-Lay North

America, Inc., 786 F.3d 960, 965 (Fed. Cir. 2015)

(involving two surveys finding that 41% and 55% of

respondents thought that PRETZEL CRISPS was a

brand name); Ty Inc., 353 F.3d at 530-31 (involving a

9

survey finding that 60% of respondents thought that

“Beanies” was a brand name); see also MCCARTHY,

supra, § 12:14, at 12-58 (“Consumer surveys have

become almost de rigueur in litigation over

genericness.”).

Fourth Circuit precedent provides that “the

district court, as the trier of fact, is accorded great

deference” on factual findings. Booking.com B.V., 915

F.3d at 181 (citing Swatch AG v. Beehive Wholesale,

LLC, 739 F.3d 150, 155 (4th Cir. 2014)). The district

court’s factual finding that BOOKING.COM is

descriptive based on the record evidence should thus

be accorded great deference. Although “there is no

need for a survey if other evidence overwhelmingly

proves that the disputed designation is a generic

name,” several judges are “used to survey evidence

and often expect to receive evidentiary assistance by

surveys in resolving generic disputes.” MCCARTHY,

supra, § 12:14, at 12-58 to 12-59.

Against this backdrop, there is no reason to fault

the district court’s consideration of Booking.com’s

survey “reveal[ing] that 74.8 percent of [survey]

respondents identified BOOKING.COM as a brand

name.” Booking.com B.V., 278 F. Supp. 3d at 915.

II.

THE USPTO’S CONCERNS REGARDING

MONOPOLY POWER ARE MISPLACED.

The USPTO also raises concerns that registration

of BOOKING.COM as a protectable mark will give

Booking.com an “effective monopoly on language, to

the detriment of competition and consumers.” Pets.

Br. at 15. Where trademark or service mark protection

10

has been sought for a generic term, the concern is that

“a competitor could not describe his goods [or services]

as what they are.” Id. at 34 (quoting CES Publ’g Corp.

v. St. Regis Publ’ns, Inc., 531 F.2d 11, 13 (2d Cir.

1975)). But that concern has no application here.

“When the line between generic and descriptive

terms is indistinct . . . it is helpful to ask whether one

firm’s exclusive use of the phrase will prevent a rival

from naming itself and describing its product.” Te-Ta-

Ma Truth Found.—Family of URI, Inc. v. World

Church of the Creator, 297 F.3d 662, 666-67 (7th Cir.

2002). Here, the services Booking.com offers include,

inter alia, providing hotel, resort and temporary

accommodation reservation services and information.

Competitors offering the same services might describe

themselves as offering bookings, or even more likely

as hotel reservation services, but they would not

describe themselves as a “booking.com.” The

combination of these two terms (“booking” and “.com”)

does not per se yield a generic composite.

The district court therefore rightly characterized

the USPTO’s “suggest[ion] that [Booking.com’s]

competitors need to be able to describe themselves as

‘booking.coms’” to compete effectively as illogical.

Booking.com B.V., 278 F. Supp. 3d at 912.

“[C]ompetitors, such as Expedia and Travelocity, have

no incentive to describe themselves as ‘booking.coms’

because this risks diverting customers to the website

of their competitor.” Id. at 913.

Nor does the uniqueness of online addresses create

a concern over monopolization of language. Indeed, in

the online environment, Congress has adopted the

11

Anti-Cybersquatting Consumer Protection Act, 15

U.S.C. § 1125(d), to address concerns that customers

seeking information online about a brand they

recognize will be taken to the wrong website.

For example, “when a trademarked name is used

as a company’s address in cyberspace, customers

know where to go online to conduct business with that

company,”

benefitting

both

consumers

and

merchants. 106 CONG. REC. S10,513, S10,516-17

(daily ed. Aug. 5, 1999) (statement of Sen. Leahy).

Because “consumers have come to rely heavily on

familiar brand names when engaging in online

commerce,” if a competitor “operat[es] a web site

under another brand owner’s trademark . . .

consumers bear a significant risk of being deceived

and defrauded, or at a minimum, confused,” which

may result in “the erosion of consumer confidence in

brand name identifiers and in electronic commerce

generally.” S. REP. NO. 106-140, at 5 (1999).

Nothing in the Anti-Cybersquatting Consumer

Protection Act suggests that Congress intended to

withhold its remedies from a domain name that serves

as a source identifier and has become recognized as a

brand, even if the domain name comprises a generic

SLD and a TLD.

The district court properly recognized these policy

considerations: “granting trademarks to producers

who primarily offer goods and services online and

brand themselves based on their domain name favors

the interest of consumers by limiting the prospect of

deception and confusion” and “protects the good will

generated by producers, often at great effort and

12

expense,

and

thereby

incentivizes

brand

development.” Booking.com B.V., 278 F. Supp. 3d at

913.

But this does not mean that a domain name that is

descriptive necessarily would receive the same scope

of protection as a fanciful, arbitrary or suggestive

mark. “Not all marks are equal.” MCCARTHY, supra, §

11:73, at 11-239. “Some trademarks are very ‘strong,’

in the sense they are widely known and recognized.”9

Id. Other “relatively weak marks are given a

relatively narrow range of protection both as to

products and format variations.” Id. at 11-242.

Courts have addressed monopoly concerns

regarding descriptive marks for decades by granting

them a narrower scope of protection than fanciful,

arbitrary or suggestive. See, e.g., Juice Generation,

Inc. v. GS Enters. LLC, 794 F.3d 1334, 1339 (Fed. Cir.

2015) (“Marks that are descriptive . . . are entitled to

a narrower scope of protection, i.e., are less likely to

generate confusion over source identification, than

their more fanciful counterparts.”); Henri’s Food

Prods. Co. v. Tasty Snacks, Inc., 817 F.2d 1303, 1305

(7th Cir. 1987) (“Trademarks run the gamut from the

fanciful or arbitrary (which are fully protected), to the

suggestive, to the ‘merely descriptive’ (which require

for protection a showing of secondary meaning).”); In

re Hunke & Jochheim, 185 U.S.P.Q. 188, 189

(T.T.A.B. 1975) (“[I]t is well established that the scope

9

For example, these marks include “APPLE for computers

and mobile phones, GOOGLE for a search engine, COCA-COLA

for beverages and TOYOTA for vehicles.” Id.

13

of protection afforded a merely descriptive . . . term is

less than that accorded an arbitrary or coined mark.”).

As recognized during the early years of the

Lanham Act, “the merchant who chooses as a mark a

term that is descriptive and has not achieved a strong

presence in the marketplace cannot be surprised that

the mark has only a limited scope of protection.”

MCCARTHY, supra, § 11:76, at 11-253. The same

principle applies here. Accordingly, even if

BOOKING.COM is found descriptive and protectable,

that does not mean that Booking.com would

necessarily receive the same scope of protection as a

fanciful, arbitrary or suggestive mark, let alone a

monopoly.

For these reasons,

concerns are misplaced.

the

USPTO’s

monopoly

CONCLUSION

Because the fact-specific “primary significance”

test provides both the TTAB and courts with

flexibility for all situations and the USPTO’s

monopoly concerns are unfounded, the Court should

affirm the Fourth Circuit’s decision and hold that the

test for whether a proposed trademark or service

mark, including a domain name, is generic is the

“primary-significance” test as set forth in 15 U.S.C. §

1064(3).

14

Respectfully submitted,

OF COUNSEL

MARC V. RICHARDS

PRESIDENT-ELECT

THE INTELLECTUAL PROPERTY

LAW ASSOCIATION OF CHICAGO

P.O. Box 472

Chicago, IL 60690

(312) 321-4200

MARGARET M. DUNCAN

Counsel of Record

Loyola University

Chicago School of Law

25 East Pearson Street

Chicago, IL 60611

mduncan@luc.edu

(312) 915-7120

JUDY K. HE

Haynes and Boone, LLP

180 North LaSalle Street,

Suite 2215

Chicago, IL 60601

judy.he@haynesboone.com

(312) 216-1620

Counsel for The Intellectual Property Law

Association of Chicago

February 19, 2020