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Usually when an alleged surname is combined with a design, the
Office will approve the mark for publication. Not this time. The
Board affirmed a Section 2(e)(4) refusal of the word-and-design
mark shown below, for firearms and related goods. The panel
majority found that the additional geographically descriptive
term US and the plain diamond background do not remove the primary
surname significance. Judge Bergsman dissented, opining that [t]he Board should restrict the application of what is primarily a surname to trademarks that consist of a mark