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As a result, the Board granted respondent’s motion for summary judgement and dismissed petitioner’s petition to cancel the mark with prejudice.

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The Board further noted that the petitioner did not meet its burden, as petitioner did not present any “competent” evidence to augment its allegations; instead, as the Board noted, petitioner’s evidence only indicates that one blogger “appreciates respondent’s product, not that there is anything about the term that is descriptive.” Finally, the Board noted that “even if one could conclude from petitioner’s evidence that some altered state of behavior may follow ingesting the goods,” no evidence shows that the term “Naughty Girl” relays any information at to the ingredients, quality, characteristics, function, feature, purpose of use of the wine.

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