TTABlog Test: Is "GOLF DARTS" Merely Descriptive of Action Skill Games?

The USPTO refused to register the proposed mark GOLF DARTS for "action skill games," deeming the mark to be merely descriptive under Section 2(e)(1). Applicant P & P contended that the combination of GOLF and DARTS “presents a bizarre and incongruous meaning that cannot be grasped without some measure of imagination and mental pause,” since its game lacks traditional elements of either golf (no course, holes, etc.) or darts (no feathered darts, needle darts piercing a regulation dartboard, etc.). How do you think this appeal came out? In re P&P Imports LLC, Serial No. 98669267 (September 25, 2026) [not precedential] (Opinion by Judge Catherine Dugan O'Connor).

Examining Attorney Claudia A. Kopenski relied on dictionary definitions of GOLF ("a game in which a player using special clubs attempts to sink a ball with as few strokes as possible into each of the 9 or 18 successive holes on a course"), DART (“a small missile usually with a pointed shaft at one end and feathers at the other”) and DARTS ("a game in which darts are thrown at a target"). The Board found that "[t]hese definitions show that golf and darts are known games that use particular implements to attain particular objectives."

P & P’s specimen of use and excerpts from its website and Amazon.com product listing showed that the goods include a “dartboard target,” “darts scoreboard,” and so-called “‘Chip N’ Stick’ golf balls” that are modified with hook-and-loop fasteners so they can stick to the target. Its advertising states" GOLF DARTS: An exciting new chipping game that combines the precision of darts with the fun of golf; The included Chip N’ Stick golf balls stick to the oversized fabric target for scoring."

This evidence shows that Applicant’s “action skill games” include features that combine elements of both golf and darts. When the words GOLF and DARTS are combined into GOLF DARTS and used for Applicant’s goods, the words retain their original meanings as referring to features of the goods, which include aspects of both golf and darts.

The Board acknowledged that the the term GOLF DARTS "may at first glance seem unusual when considered in the abstract," but it found "nothing bizarre or incongruous about the combination of the words GOLF and DARTS when it is considered in relation to P & P's “action skill games."

As seen in Applicant’s specimen and advertising, Applicant’s game combines features from both golf and darts, including a dartboard-style target and modified golf balls. The specimen depicts players hitting golf balls at the dartboard target, and the game is specifically promoted as a way to improve one’s chipping skills while playing classic darts games.

Nor did the Board find that the combination of GOLF and DARTS would be perceived as jarring or suggestive, "especially in light of P & P’s own advertising materials and specimen." Moreover, the examining attorney provided evidence of others using the terms “Golf Darts” or “Dart Golf” with reference to a game that combines features of both golf and darts.

P & P pointed to existing registrations for SMACK DARTS and RINGER DARTS (DARTS disclaimed in both marks) and cancelled registrations for SEX-DARTS and GOLFDARTS, but the Board was unmoved. The cancelled registrations "are of limited value as they are evidence only of the fact that the registrations issued." The other registrations "involve different marks than the applied-for mark GOLF DARTS and are based on entirely different records." "The great variation in facts from case to case prevents the formulation of specific rules for specific fact situations. Each case must be decided on its own merits."

[T]he proposed mark GOLF DARTS directly and immediately conveys information about Applicant’s “action skill games,” namely, that they include features of the games of golf and darts. We therefore find Applicant’s proposed mark to be merely descriptive of the identified goods.

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Text Copyright John L. Welch 2026.