TTABlog Test: How Did These Three Section 2(d) Appeals Turn Out?

Section 2(d) affirmances continue to run at a 90% clip this year (as usual). Here are three recent appeals. No hints this time. How do you think they came out? [Answer in first comment].

In re Curo Health Services, LLC, Serial No. 98414104 (November 19, 2025) [not precedential] (Opinion by Judge Thomas W. Wellington). [Section 2(d) refusal of the mark ILLUMIA HEALTH for “palliative care services; hospice services; home health care services" [HEALTH disclaimed] in view of the registered mark ILLUMINA for, inter alia, "medical services."]

In re Herbert, Rowland & Grubic, Inc., Serial Nos. 97698576 and 97698586 (November 21, 2025) (Opinion by Judge David K. Heasley) [Section 2(d) refusal to register the mark HRG, in standard character and logo form (below left), for "engineering services focusing on the coordination and design of civil infrastructure systems; structural engineering design services; site design services, namely, engineering design services for commercial buildings; land surveying services” in view of the registered mark shown below right, for "professional engineering services for the design and construction of facilities in the transportation, water, governmental services, senior living and energy markets."]

In re Bruhhl LLC, Serial No. 97741879 (November 21, 2025) [not precedential] (Opinion by Judge Christoper C. Larkin). [Section 2(d) refusal of the mark SANITEE for “Spray sanitizer for personal use," in view of the registered mark SANITY for "Disinfectants, hand sanitizers."]

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Text Copyright John L. Welch 2025.