TTABlog Collection of Section 2(e)(2) "Primarily Geographically Descriptive" Cases

I've been writing a response to a Section 2(e)(2) refusal, and I thought it would be useful for me and others to compile a list of TTABlog postings on the issue. The great majority of the decisions are not precedential, but even non-precedential decisions may be helpful in framing effective arguments and locating precedential support for them.


For a mark to be deemed primarily geographically descriptive under Section 2(e)(2), it must be shown that (1) the mark's primary significance is a generally known geographic location; (2) the relevant public would be likely to make a goods/place association, that is, would be likely to believe that the goods originate in the place named in the mark; and (3) the goods do originate in that place. When the goods do come from the location named, then a goods/place association may be presumed.

Marks found to be primarily geographically descriptive under Section 2(e)(2):

• CAFC Reverses TTAB: NEWBRIDGE HOME Not Geographically Descriptive of Cutlery
• TTAB Affirms Geographical Descriptiveness Refusal of NEWBRIDGE HOME for Household Goods
• TTAB Affirms Section 2(e)(2) Geographical Descriptiveness Refusal of PITTSBURGH GLASS WORKS for Glass
• TTAB Affirms 2(e)(2) Refusal of "THE MUNICH & Design" for Business Services Without a Disclaimer of MUNICH
• TTAB Finds FIRE ISLAND Primarily Geographically Descriptive of Beer 
• NORTH AMERICAN RANGE Primarily Geographically Descriptive of Beef, Says TTAB
• TTAB Affirms 2(e)(2) Refusal of EAST COAST for Vehicle Towing Services
• WYHA? TTAB Finds CALIFORNIA GREEN CLEAN Primarily Geographically Descriptive of Janitorial Services
• TTAB Finds "ROC USA" to be Primarily Geographically Descriptive but Registrable Under Section 2(f)
• TTAB Affirms 2(e)(2) Geographical Descriptiveness Refusal of "US PATIENT REGISTRY" for Medical Information Database
• TTAB Sustains Nike's Section 2(e)(2) Opposition to "B-MORE" for Clothing
• "CHÊNE DES DOMAINES DE FRANCE" Geographically Descriptive of Wood from France, Knot Registrable, Says TTAB 
• Precedential No. 4: TTAB Affirms Triple Refusal of "NORMANDIE CAMEMBERT" for Cheese
• "AMERICAN MASALA" Geographically Descriptive of Food Products, Says TTAB
•  Precedential No. 66: TTAB Finds "YOSEMITE BEER" Geographically Descriptive, Affirms 2(e)(2) Refusal
• TTAB Affirms 2(e)(2) Refusal of "CONFERENCE AMERICA" as Geographically Descriptive
• TTAB Squashes "NEW YORK CURRANTS," Finding It Primarily Geographically Descriptive
• Citable No. 33: TTAB Affirms 2(e)(2) Refusal of "BAIKALSKAYA" as Geographically Descriptive of Vodka
• TTAB Okays "SWISSAIRE" Drawing But Affirms 2(e)(2) Refusal

Marks found not to be primarily geographically descriptive under Section 2(e)(2):

• CAFC Reverses TTAB: NEWBRIDGE HOME Not Geographically Descriptive of Cutlery
• Test Your TTAB Judge-Ability: Is TINSELTOWN Geographically Descriptive of Clothing from Hollywood?
• Test Your TTAB Judge-Ability: Is "MDF IT & Design" Primarily Geographically Descriptive of Furniture?
• "METRO LIVING & Design" Not Descriptive of Real Estate Brokerage Services, Says TTAB
• Reversing a 2(e)(2) Geographical Descriptiveness Refusal, TTAB Asks, Where The Heck Is WINDHOEK?
• Test Your TTAB Judge-Ability: Is This "HOT SPRINGS NATIONAL PARK ARKANSAS" Logo Primarily Geographically Descriptive?
• TTAB Reverses Section 2(e)(2) Refusal of "CATALINA ISLAND GRANOLA": Goods/Place Association Lacking
• Finding "BELL HILL" for Wine and "BELL'S" for Beer Too Dissimilar, TTAB Dismisses 2(d) Opposition 
• Finding Double Entendre, TTAB Reverses 2(e)(2) Refusal of "PROFUMO DE FIRENZE" for Perfume
• Precedential No. 14: TTAB Finds "THE MONTECITO DIET" Not Primarily Geographically Descriptive of Diet Publications
• "ROMANTIC ROAD" 2(e)(2) Cancellation Proceeding Hits Dead End: Summary Judgment to Registrant
• Citable No. 40: TTAB Finds "BALASHI" Not Primarily Geographically Descriptive of Beer