Opposition Brief — Brunswick Corp. v. British Seagull Ltd.

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No. 94-1075 Py

in rooted

SUPREME COURT OF THE UNITED

STATES

October Term, 1994

BRUNSWICK CORPORATION, __

Petitioner,

v.

BRITISH SEAGULL LIMITED

and OUTBOARD MARINE CORPORATION,

Respondents.

On Petition For Writ of Certiorari

To The United States Court of Appeals

For the Federal Circuit

’ BRIEF IN OPPOSITION

Robert E. Clemency, Esq.*

Lee J. Geronime, Esq.

R. Warren Comstock, Esq.**

Michael, Best & Friedrich

100 East Wisconsin Avenue

Milwaukee, Wisconsin 53202-4108

(414) 271-6560

Attorneys for

British Seagull Limited and

Outboard Marine Corporation

*Attorney of Record

**Of Counsel

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QUESTION PRESENTED

The question presented by the

Petition erroneously assumes that the

Trademark Trial and Appeal Board applied a

more expansive "functionality" test to

Petitioner's application for a color

trademark than is applied to other types

of federal trademark applications. As

appears hereafter, respondent submits that

the functionality test(s) applied by the

Trademark Trial and Appeal Board, as

affirmed by the Federal Circuit, is in

accord with Inwood Laboratories v. Ives

Laboratories, 456 U.S. 844 (1982).

In addition, the question

presented by the Petition also raises

(Rule 14.1(a)) the subsidiary question of

the admissibility of the evidence which

has been objected to by Respondents and

which has been offered by Petitioner

atte

through Mr. DuCoty with respect to market

share and with respect to Respondent OMC's

unit volume over 75 years, and through Mr.

Piper with respect to sales unit volume

and advertising expense. This subsidiary

issue would be moot in the event of the

denial of the Petition.

Respondents' only other comment

with respect to the question presented by

the Petition is that Respondents believe

the Petition is frivolous in view of

Petitioner's reliance on Inwood v. Ives,

(supra) .

-1iii-

STATEMENT PURSUANT TO RULE 29.1

Neither British Seagull

Corporation, nor Outboard Marine

Corporation, has parent or _ subsidiary

companies, defining "subsidiary" as

greater than 50% ownership (and excluding

wholly owned subsidiaries) .

iv

TABLE OF AUTHORITIES

CASES Page(s)

TABLE OF CONTENTS

cage Inc., 671 F.2d 1332, 1341

QUESTION PRESENTED ......... jj (CCPA 1982)... eo Cone

STATEMENT PURSUANT TO RULE 29.1... iii Laboratories, 456 U.S. 644,

. ‘ ° . . . . ia 11, /

TABLE OF CONTENTS ........... iv 855 (1982) 20-27, 31, 33

TABLE OF AUTHORITIES v )

601 F.2d 631, 643

OPINIONS BELOW 2 ES A ce ee ey ee

JURISDICTION 2 )

Sept. 26,

STATUTORY PROVISIONS INVOLVED . 2 a ee

STATEMENT OF THE CASE . 2 )

Re ee an ae

REASONS FOR DENYING THE WRIT .... 16 S76 U.S. Sa5, (008)

UNITED STATES CODE

I. NON-COMPLIANCE WITH

WO MOA se wes 8 0.60: Be sk ee OD

tte ee ee eee ee ARE | RULES OF THE SUPREME COURT

NOT IN CONFLICT WITH

Mune NS Be 6 4 BE ie te ee earn ee

III. THE DECISIONS BELOW ARE : pincer

NOT CLEARLY ERRONEOUS... 28 : Rule 14.1(a) .- =...

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IV. CONSOLIDATION WITH Rule 15.1

QUALITEX ... te we ee Se aa ee keri eee

COUSIN in 6 o.oo See ee

CERTIFICATE OF SERVICE ....... 35

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IN THE

. SUPREME COURT OF THE UNITED

STATES

October Term, 1994

BRUNSWICK CORPORATION,

Petitioner,

Vv.

BRITISH SEAGULL LIMITED

and OUTBOARD MARINE CORPORATION,

Respondents.

On Petition For Writ of Certiorari

To The United States Court of Appeals

For the Federal Circuit

BRIEF IN OPPOSITION

Respondents have no comment on

the above three sections of the Petition.

STATEMENT OF THE CASE

The Statement of the Case in the

Petition is noteworthy for two reasons:

1) The absence of a fair

characterization of the record,

pain staan toa See

i.e. misstatements of facts

(Rule 15.1) and

2) Petitioner's reliance on

evidence as factual matters in

the record, which evidence is

the subject of objections which

were made and which were not

patna Mea eSi

-3-

ruled upon because consideration

of such evidence was. not

prejudicial to Respondents

(A000048) .

With respect to the absence of a

fair characterization of the record, and

contrary to the narrow assertion

(referring to the absence of testing and

survey evidence) at the bottom of page 13

of the Petition, Respondents (Opposers)

have presented substantial evidence which

supports the findings of the Trademark

Trial and Appeal Board (hereinafter TTAB)

that (a) color compatibility and perceived

size reduction are functional features of

the color black, and that (b) the non-

availability to competitors (incident to

registration) of the color. black,

including the inherently functional

features thereof, would hirer effective ampetitic.

a

The TTAB noted that there was

considerable evidence supporting

Respondents' position (A000035)*. "The

facts supporting our reasoning are not

seriously disputed" (A000034). The

Federal Circuit "..discern(ed) no error

in the Board's legal reasoning and no

clear error in its factual findings"

(A000013; AO00023).

Specifically, as to the color

compatibility of black as an ingredient of

a successful marketing program,

Respondents offered unrefuted testimony

from industry executives and color experts

that black outboard moto:rs can be attached

to (matched with) boats of any color

without risk of clashing with the boat

* Numbers in parenthesis (A000000)

refer herein and hereafter to

the Appendix filed with the

Petition.

-5-

color because black never clashes with any

other color (A000035).

Respondents offered unrefuted

evidence as to perceived size reduction by

an industry executive (Feurig p. 95

[A002474]*) and by a color expert (Welker

p. 82 [A002944]). Furthermore, unrefuted

evidence was also offered that boat

manufacturers want outboard motors to look

smaller so as to be less obtrusive on

their boats (A000036). Petitioner's

predecessor's former Vice President

testified that the reason that the color

black was selected by Petitioner's

predecessor was the tendency of black to

make objects appear to be smaller.

(Strang deposition, p. 5 - 6 [A002344 -

002345]).

* Numbers in brackets’ [A00000]

refer herein and hereafter to

the dix filed with the

Federal Circuit.

alli

Furthermore, the Petition is

Silent as two the revolution which is

taking place in the marketing of outboard

motors. In the past, outboard motors were

sold to a wide array of dealers. However,

during the late 80's and early 90's, the

market was and is moving to large sales of

outboard motors to a relatively small

number of boat manufacturers and a major

retailer who package boats and motors (and

trailers) for sale to dealers and to the

public (Opp. Confidential Ex. 356, Bates

p. 700575, 700646 [A00691i - 006950];

Feurig p. 7 - 8 [A002377 - 002378]). Such

boat manufacturers and the major retailer

desire black outboard motors to ensure

color compatibility with their boats and

to reduce the perceived size of the

outboard motor so as thereby to maximize

emphasis on the boat as a necessary

=

ingredient to the success of their

marketing plans (A000035).

Specifically, Tracker, one of

the largest boat manufacturers in the

country, demanded black outboard motors

for use in its packaged sales of boat and

motor combinations (Feurig Ex. 1, p. 28

[A011503 - 011538); Feurig p. 44 - 45

[A002414 - 002415)]). Sears, one of

America's major retailers, sells

GAMEFISHER brand outboard motors which are

black (and which are, at least in part,

manufactured by Petitioner) to obtain

color compatibility with the colors of its

various boats (Burkhardt 11/20/91, p. 196

- 198 and 250 {[A002686 - 002688 and

A002471)).

As a consequence, Respondents

clearly established that, in the unfolding

90's, in order to effectively compete, it

is necessary that all outboard motor

-g-

manufacturers be able to offer for sale

black outboard motors that utilize the

dual functional features of color

compatibility and perceived size reduction

which are being demanded by boat

manufacturers and the major retailer. To

create, incident to registration of the

color black, a monopoly in perpetuity with

respect to the color black, and the

functional attributes thereof, will impair

the ability of all others in the industry

to effectively compete.

Further in regard to competitive

need, the record also establishes that

there are at least fifteen (15) brands of

outboard motors, sold by at least eleven

(11) manufacturers, most of which outboard

motors are painted black or dark colors.

Black is one of only five basic colors,

and the testimony below is that the

"extreme" colors, i.e., pink, red, orange,

~%.

etc., are not in use (Hoover p. 17, 21

[A004647, A004651])). Such painting of

outboard motors by their manufacturers

Clearly also indicates that there is

competitive need for black outboard motors

in the marketplace.

Specifically, the following

manufacturers produce black, or primarily

black, or darkly colored outboard motors

under the indicated brand names:

Manufacturer Brand Name

Eska GAMEF ISHER

Tanaka GAMEFISHER

Brunswick MERCURY*

FORCE*

GAMEF ISHER*

Seagull SEAGULL

Outboard Marine JOHNSON TRACKER*

EVINRUDE TRACKER

EVINRUDE*

JOHNSON GT

(Representative physical samples

of the outboard motors identified above by

-10-

asterisks were marked as exhibits and

displayed before both the TTAB and Federal

Circuit during oral argument.)

The GAMEFISHER, MERCURY, JOHNSON

TRACKER, and EVINRUDE TRACKER outboard

motors are black. The FORCE outboard motor

is not readily distinguishable from black.

(The use of the color black by the FORCE

and GAMEFISHER brands, in competition with

the MERCURY brand, is in direct conflict

with and in derogation of Petitioner's

claim to exclusive use (distinctiveness)

of the color black as ae trademark

(A000057)). The SEAGULL outboard motor is

primarily black. The EVINRUDE outboard

motor is a very dark blue which is nearly

indistinguishable from black. Petitioner

was unable, during the trial period, to

determine whether the color of the JOHNSON

GT outboard motor was within the scope of

=Z2~

the black sought to be registered [A003426

- 003438].

Thus, the use by various

competing brands of black, primarily

black, and dark colors barely

distinguishable from black, constitutes

additional ample evidence in the record to

Support the TTAB's finding of competitive

need.

The proceedings before the TTAB

were fact driven and the TTAB specifically

noted that "The facts supporting our

reasoning are not seriously disputed"

(A000034) .

Thus, while Petitioner is

correct in the assertion, at the bottom of

page 13 of the Petition, that the record

does not include evidence with respect to

a test or survey with respect to

competitive need, there is, as indicated

above, ample other persuasive evidence in

«~42-

the record. The TTAB rejected

Petitioner's contention, and noted that

Respondents (Opposers) were under no

obligation to conduct tests or surveys

(A000051).

The statement (at the end of the

last full paragraph on page 11 of the

Petition) asserting the indisputability of

the focus of Mercury's advertisements on

"all black" color is incomprehensible in

view of the TTAB's specific finding that

Petitioner did not effectively image

advertise the color black so as to create

secondary meaning for black as a trademark

(AO000055 - 000056) .

Contrary to the allegation (at

the top of page 13 of the Petition) that

the color black "had acquired secondary

meaning", the TTAB specifically held,

after consideration of at least five

factors, that Petitioner had failed to

-13-

establish secondary meaning (A000056 -

000061) . With respect to the comment

on page 13 of the Petition concerning the

failure of the Federal Circuit decision to

substantially address the issue of

secondary meaning (which issue was

extensively addressed by the TTAB), no

consideration was necessary as the Federal

Circuit decision with respect to

competitive need rendered moot the issue

of secondary meaning, i.e., competitive

need precludes registration regardless of

the presence or absence of secondary

meaning (A000026 - 000027).

The reference (at the bottom of

page 12 of the Petition) to two surveys is

without merit. One survey is of "record",

1.e., part of the ex parte application

proceeding, but was never offered or

entered into evidence during the inter

partes opposition proceeding. As _ such,

~14-

its contents are irrelevant (AO000056 -

000061). The other survey is among the

evidence to which objections were made.

The TTAB concluded that this survey did

not establish secondary meaning in the

color black, without specifically ruling

on the objections made by Respondents

(Opposers) (A000052) . Most importantly,

these surveys are irrelevant to the

question of competitive need and solely

relate to the issue of secondary meaning,

which issue is not before this Court.

The statement beginning at the

bottom of page 11 of the Petition is

misleading as Petitioner did not initially

consider itself entitled to registration

of the color black alone. Specifically,

Petitioner initially applied for

registration of the color black in

combination with four specific outboard

motor configurations. It was the Examiner

-38~

who suggested that the application should

be amended to refer solely to the color

black.

The Petitioner relies on

evidence as to which objection has been

made. In the event this Court favorably

considers Respondents ' (Opposers ' )

objections, the statements (p. 11 and 12

of the Petition) as to the volume of both

advertising and sales and the allegations

as to Respondent OMC's market share and

unit volume over 75 years are without

support in the record. Both at the trial

level (A000048) and at the appellate level

(A000027 - 000028), the decisions did not

rule on Respondents' objections only

because, on the merits, the decisions were

not prejudicial to Respondents.

Furthermore, the TTAB stated

that in arriving at its findings, it had

=

carefully considered all of the offered

evidence (A000033 - 000034, AO00048).

I. NON-COMPLIANCE WITH RULE 10.1

The Petition does not

demonstrate that this case involves

"Special and important reasons" and that

"an important question of federal law" is

involved.

Supreme Court Rule 10.1 states,

in part, that:

"A review on writ of

certiorari is not a matter of

right, but of judicial

discretion. A petition for a

writ of certiorari will be

granted only when there are

cial and important reasons

therefore...."

heeeeemeneeneneneenentenieiel

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"(c) When a state court or

a United States court of

appeals has decided an

important question of

federal law which has not

been, but should be,

settled by this Court..."

The Petition has not alleged any

"special and important reasons" for

exercise of this Court's discretion to

grant certiorari and has not qualified the

Petition as involving "an _ important

question of federal law". Specifically,

Petitioner's concern for an erroneously

perceived "second class" status with

“respect to color marks (page 17 of the

Petition) does not constitute either a

"special and important reason" or "an

important question of federal law".

The Petition attempts, in

reality, to overturn findings of fact

which are clearly supported by evidence in

el

-18-

the trial record, i.e., findings of de

jure functionality and competitive need.

These findings turn on the_ specific

evidence in this case, to which findings

the Federal Circuit deferred (A000009).

It is particularly noteworthy’ that

Petitioner relies on Inwood Laboratories

v. Ives Laboratories, 456 U.S. 844, 855

(1982) wherein the Court held:

"In reviewing the factual

findings of the District Court,

the Court of Appeals was bound

by the ‘clearly erroneous'

standard of Rule 52(a), Federal

Rules of Civil Procedure.

Pullman-Standard v, Swint, ante,

p. 273. That Rule recognizes

and rests n the unique

opportunity afforded the trial

court judge to evaluate the

credibility of witnesses and to

weigh the evidence. Zenith

» ase Vv. Bi ae,

123 (1969). Because of the

deference due the trial judge,

unless an appellate court is

left with the 'definite and firm

conviction that a mistake has

been committed,' United States

, Bas

U. S. 264, 295 (1948) it must

=~39.

accept the trial court's

findings."

As there is no showing of

"special and important reasons" and as "an

important question of federal law" is not

involved,

it is respectfully requested

that the Petition be dismissed.

The Petition should also be

denied for at least the following more

specific reasons:

NO

The TTAB fully considered and

correctly decided the issues

(infra, pages 21 - 31).

The Petition disputes’ the

evidence and factual findings to

which reviewing courts must

defer unless clearly erroneous

(supra, pages 3 - 16 and 28 -

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an

The TTAB's decision, as affirmed

by the Federal Circuit is not in

conflict with the authority

cited by Petitioner (Inwood v.

Ives) (infra, pages 21 - 27).

Contrary to the allegation at

the top of page 17 of the Petition, the

TTAB's "'functionality' conclusion" is not

clearly in error, but is amply supported

by the evidence referred to herein

beginning at page 3.

It is indisputable that granting

trademark registration on a color conveys

a renewable, and therefore perpetual,

monopoly on that color and on any

function(s) which that color inherently

provides.

Sears, Roebuck & Co, v. Stiffel

Co., 376 U.S. 225, (1964) stands for the

proposition that maintenance of free and

unhindered competition (except when

patents and "palming off" are involved,

neither of which is present herein) is the

-22-

basic business law of the land. Use by

competitors of the functional features of

a product in furtherance of free and

unhindered competition is authorized by

law and is to be encouraged for the

benefit of the public. "Reproduction of a

functional attribute is a legitimate

competitive activity." Inwood v. Ives

(supra, p. 863). Competitive need arises

when a feature is functional, i.e., is

needed by competitors, i.e., is "essential

to effective competition." Ives

Laboratories, Inc, v. Darby Drug Co., 601

F.2d 631, 643 (2d Cir. 1979). It is the

effect upon competition, supported by the

extensive factual record below in this

case, which establishes competitive need

and, thus, functionability. In Re Morton-

Norwich Products, Inc., 671 F.2d 1332,

1341 (CCPA 1982).

-23-

The general test referred to in

footnote #10 in Inwood v. Ives (supra, p.

850) has been factually satisfied in this

case, ji.e., free competition in the

marketing of outboard motors is dependent

on the color compatibility utility and the

perceived size reduction utility of the

color black, which features are not

available with use of other colors. In

effect, the TTAB held below, and the

Federal Circuit affirmed, that use of the

color black is essential to the use (sale)

of outboard motors because without the

color compatibility utility and the

perceived size reduction utility of black

(only available from black), competition

by competitors would be hindered (A000012

- 000013; A000022).

Even more significantly, Inwood

vy. Ives requires, yes, even demands,

denial or dismissal of the Petition.

-24-

Specifically, on the merits, in Inwood v.

Ives, this Court did not reverse, but,

indeed, approved, the decision below of

the District Court that use of a color

(blue) on one drug capsule, and use of a

color combination (red-blue) on another

drug capsule was de jure functional

(without using this term). The following

features were confirmed as (de jure)

functional by this Court (supra, p. 853)

when this Court held:

In reaching its conclusion, the

(district) court found that the blue

and blue-red colors were functional

to patients as well as to doctors and

hospitals: many elderly patients

associate color with therapeutic

effect; some patients conmmingle

medications in a container and rely

on color to differentiate one from

another; colors are of som, if

limited, help in identifying s in

emergency situations; and use of the

same color for brand name drugs and

their generic equivalents helps avoid

confusion on the part of those

responsible for di ing drugs.

Id., at 399. In addition, because

Ives had failed to show that the

colors indicated the drug's origin,

«25.

the court found that the colors had

not acquired a secondary meaning.

Id., at 399. (insert supplied)

These de jure functions are not

unlike the color compatibility and

perceived size reduction de jure functions

in this case.

This Court noted, in Inwood v.

Ives (supra, p. 853) that the District

Court found that "Ives failed to establish

its claim based upon §43(a)", and also

held "because Ives had failed to show that

the colors indicated the drug's origin ...

the colors had not acquired secondary

meaning." (supra, p. 853). Similarly, in

the case at bar, the TTAB also held that

Petitioner had failed to’ establish

secondary meaning (A000056) .

Thus, in reality, Petitioner is

attempting to improperly set aside factual

findings of the TTAB, which findings are

clearly supported in the voluminous trial

-26-

record, and to drive a linguistic wedge

between "competitive need" and "essential

to the use or purpose of an article". In

this case, that which hinders free and

unhindered competition (by monopolizing

functional features not otherwise

available) is essential to the (effective)

use (sale) of outboard motors, because

purchasing boat manufacturers and at least

one major retailer want these features,

and therefore, without such features, free

and unhindered competition is necessarily

restrained. Thus, this case does not

constitute a departure from Inwood v.

ives.

Inwood v. Ives does not support

grant of the Petition, but instead,

clearly indicates that the decisions below

were correct because Inwood v. Ives

affirmed de jure functionality (without

using that term) and because factual

=»

findings at the trial level must be

respected and can only be put aside if

clearly in error. The Petition contains

no showing of clear error. Contrary to

Petitioner's assumption (assertion) that

the TTAB applied a "functionality" test

more expansively to the Petitioner's

application for a color trademark than to

other types of federal trademarks, the

decision below is in full accord with

Inwood v. Ives. Accordingly, Inwood v.

Ives clearly calls for denial or dismissal

of the Petition. In addition, the dual

holding in Inwood v. Ives affirming de

jure functionality and requiring that

factual findings at the trial level not be

disturbed, makes this Petition, based on

Inwood v. Ives, frivolous.

The comment with respect to

competitive need (near the bottom of page

16 of the Petition) represents

Petitioner's view of the facts, not that

of the TTAB, and totally disregards the

movement of the market to boat

manufacturers (Supra, pages 6 - 8).

With respect to the contention,

at page 18 of the Petition, that the TTAB

failed to cite the record for specific

evidence to support its factual findings,

there is no rule of law which requires a

trial court to cross reference the record

when making findings of fact. The only

requirement is that the findings be

supported in the evidence. In this case,

the findings are clearly supported in the

record.

-29-

With respect to the evaluation

of "credible evidence" made at the middle

of page 18 of the Petition, such

evaluation is that of Petitioner and not

that of the TTAB.

The statement in the Petition,

at page 18, that there "was no evidence in

the record suggesting Mercury's ‘all

black' mark is essential for 'effective'

competition" is Petitioner's reading of

the evidence, and not that of the TTAB.

The record clearly supports both the

finding of competitive need by the TTAB

and the decision of the TTAB, which

decision was affirmed by the Federal

Circuit (A000022).

In the Petition, at page 13, in

the section entitled "PROCEEDINGS BELOW',

a portion of the decision of the TTAB is

quoted, which portion is only a part of a

full paragraph, is taken out of context,

~30-

and therefore is misleading. The full

paragraph of the decision of the TTAB is

set out hereinafter, with omitted portions

underlined.

although the color

black is not functional in the sense

that it makes these engines work

better, or that it makes them easier

or less expensive to manufacture,

black is more desirable from the

perspective of prospective purchasers

because it is color compatible with a

wider variety of boat colors and

because objects colored black appear

smaller than they do when they are

painted other lighter or brighter

colors. The evidence shows that

people who buy outboard motors for

ion of the si =i

in_proportion to the boats _

- 000035).

(A000034

tn

Thus, although the TTAB

admittedly did not find that the color

black made the outboard engine work better

or is easier or less expensive to

manufacture (which was never contended by

either side), the TTAB did make specific

factual findings of functionality, which

findings are not in the conflict with the

finding in Inwood v. Ives.

The Petition should therefore be

denied.

«BD a

The question presented in the

Petition does not bear on the basic issue

of the registrability of color, which is

the only question accepted by this Court

in Qualitex v. Jacobson Products Co.,

inc., 63 U.S.L.W. 3255 (Sept. 26, 1994).

The question raised herein refers to the

issue of preclusion of registrability

because of competitive need and

functionality, which issue is entirely

separate and apart from the basic issue of

the registrability of color. Accordingly,

Respondents respectively submit that there

is no reason for consolidation with

Qualitex.

ee

CONCLUSION

Petitioner has failed to

demonstrate the presence of any "special

and important reasons" and any "important

question of federal law" which qualifies

this case for a writ of certiorari.

Petitioner merely seeks to overturm

factual findings clearly supported by the

evidence by asserting linguistic

differences of no import between the

precedent of this Court (Inwood v. Ives)

and the reasoning of the decisions below.

Petitioner's allegation of conflict with

the precedent of Inwood v. Ives is totally

erroneous and frivolous. Accordingly,

Respondents respectfully request that the

Petition be dismissed.

In addition, Respondents

respectfully request an award of damages

(attorney's fees), interest, and double

34

costs in view of the frivolous character

of the Petition (Rules 42.2, and 28 U.S.C.

§1912).

Dated: Jan 13, 1995

Robert E. Clemen Esq. *

Lee J. Geronime, Hsq.

R. Warren Comstock, Esq. **

Michael, Best & Friedrich

100 East Wisconsin Avenue

Milwaukee, Wisconsin 53202-4108

(414) 271-6560

*Attorney of Record

**Of Counsel

-35-

CERTIFICATE OF SERVICE

The undersigned hereby

certifies that three copies of the

foregoing BRIEF IN OPPOSITION were served

via First Class Mail, postage prepaid on

this 16th day of January 1995 on the below

listed counsel:

Timothy J. Haller

Niro, Scavone, Haller & Niro

181 West Madison, Suite 4600

Chicago, Illinois 60602

(Counsel for Petitioners)

Fred E. McKelvey

2121 Crystal Drive

Suite 918

Arlington, Virginia 22202

(Counsel for the Commissioner of

aad

Robert E. Clemen

State of Wisconsin

Milwaukee County y

Sworn before me this 16th day of January, 1995.

a

i Fd

ary Tic, 7Staté/of Wisconsin

My commission expires: F- VE y