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

TTAB affirmances of Section 2(d) refusals are running at about 84% so far this year. Here are three recent decisions. At least one of them resulted in a reversal. What say you? [Answer in first comment].

In re Connecting Forward, LLC, Serial No. 97565017 (June 26, 2026) [not precedential] (Opinion by Judge Robert Lavache). [Section 2(d) refusal of the mark MISTER JUNETEENTH, for “Organizing events in the field of pageants for cultural or educational purposes; Entertainment in the nature of pageant competitions" [JUNETEENTH disclaimed], in view of the registered marks JUNIOR MISS JUNETEENTH [JUNIOR and JUNETEENTH disclaimed], TEEN MISS JUNETEENTH [TEEN and JUNETEENTH disclaimed], and MISS JUNETEENTH SCHOLARSHIP PAGEANTRY PROGRAM [JUNETEENTH SCHOLARSHIP PAGEANTRY PROGRAM disclaimed] for “Entertainment in the nature of pageant competitions; organization of events for cultural purposes; organization of events in the field of pageants for educational purposes."]

In re Kayed Lafi, Serial No. 98191310 (June 30, 2026) [not precedential] (Opinion by Judge David K. Heasley) [Section 2(d) refusal of the mark GALLO'S ELITE PERFORM LIKE A PRO & design, shown below left [PRO disclaimed], in view of the registered mark GALLO GLOBAL NUTRITION & design, shown below right [GLOBAL NUTRITION disclaimed], both for nutritional supplements.]

In re NowOne Ventures, LLC, Serial No. 98757552 (June 30, 2026) [not precedential] (Opinion by Judge Lawrence T. Stanley, Jr.). [[Section 2(d) refusal of the mark OMMI for "Vitamins; Dietary supplements; Herbal supplements; Nutritional supplements; Gummy vitamins; Mineral supplements" in view of the registered mark OMMIE for "Grain-based food bars also containing dried fruits and seeds."]

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Text Copyright John L. Welch 2026.