TTABlog Test: Which of These Three Section 2(d) Refusals Was/Were Overturned on Appeal?

The TTAB affirmance rate for Section 2(d) appeals last year fell just under 90%. So far this year it's back to 90%. Here are three recent Board decisions, at least one of which reversed the refusal. How do you think they came out? [Answer in first comment].

In re Quantum Group, LLC, Serial No. 97540994 (April 28, 2025) [not precedential] (Opinion by Judge Christopher C. Larkin). [Section 2(d) refusal of the mark shown below for "On-line retail store services featuring cases and protectors for collectible trading cards" [SPORTS disclaimed] in view of the registered mark QUANTUM for "sports trading cards."] 

In re Couscous Maghrebi Grill LLC, Serial No. 98085780 (April 28, 2025) [not precedential] (Opinion by Judge Angela Lykos). [Section 2(d) refusal of the mark COUSABLANCA for restaurant services in view of the registered mark CASABLANCA for "Hotel and restaurant services."]

In re James Rice-Pena, Serial No. 98077056 (April 23, 2025) [not precedential] (Opinion by Judge Christopher C. Larkin). [Section 2(d) refusal to register the mark shown below, for Restoration services in the field of water, smoke and fire damage, mold remediations services, and mold testing [FLCLEANUP disclaimed], in view of the registered mark WE MANAGE THE DAMAGE for "Building and home damage restoration services" [DAMAGE disclaimed].

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Text Copyright John L. Welch 2025.