IP Law Daily, TRADEMARK—TTAB: Opposition to ‘LA’ mark for beverage products dismissed, substantially dissimilar to LAV mark, (Jul 20, 2026)

By Jonathan Anderson

Substantial dissimilarity in sound, appearance, meaning, and commercial impression outweighed the similarity of the goods and trade channels.

The Trademark Trial and Appeal Board (TTAB) dismissed opposition against an application for the stylized mark LA for beverage-related products, concluding that the proposed mark is not likely to cause confusion with the registered stylized mark LAV for various household goods, including beverage products. The Board concluded that the substantial dissimilarity of the marks in sound, appearance, meaning, and commercial impression outweighed the similarity of the goods and trade channels. In particular, the Board noted that the LA mark is so highly stylized that it is akin to a design mark rather than LAV’s mark, which is merely a stylized display of the letters (NameGürok Turizm v. TGL Golf Holdings, LLC, No. 91293362 (T.T.A.B. Jul. 15, 2026)).

Background. Applicant, TGL Golf Holdings, LLC, filed a multi-class application on the Principal Register to register the stylized mark LA for a wide variety of goods and services, including in International Class 21 for beverage-related products. Applicant’s stylized mark consists of the letters “LA” with a golf club separating the two letters; color is not claimed as a feature of the mark, and “LA” is disclaimed. Opposer, Gürok Turizm Ve Madencilik Anonim Sirketi, filed an opposition to registration of Applicant’s mark for the Class 21 goods on the ground of likelihood of confusion under Trademark Act Section 2(d), 15 U.S.C. § 1052(d). Opposer pleaded ownership of multiple stylized LAV marks and common law rights in LAV for various household goods in International Class 21. The applicant denied the salient allegations.

Likelihood of confusion. The Board analyzed all the probative facts of record bearing on a likelihood of confusion and considered each DuPont factor for which there was evidence and argument.

Similarity of the goods. The second DuPont factor considers the similarity or dissimilarity and nature of the goods or services. The Board found this factor weighs heavily in favor of likelihood of confusion. The goods are identical and legally identical in part.

Trade channels. The third DuPont factor considers the similarity or dissimilarity of established, likely to continue trade channels; the Board found this factor weighs heavily in favor of a likelihood of confusion. There are no trade channel restrictions, nor are there limitations as to the classes of consumers in either Applicant’s or Opposer’s registrations, the Board noted. The classes of consumers for Applicant’s and Registrant’s drinkware and beverageware goods are the general public. Because the goods in Applicant’s identification and Opposer’s registration are in-part identical and legally identical, the Board said it presumes that they are offered to the same classes of consumers and move through the identical trade channels.

Conditions of sale. The fourth DuPont factor considers the sales conditions and degree of consumer sophistication; the Board said this factor was neutral. The Board said it must assume, when goods are unrestricted, that the goods are offered at all price points and to all purchasers. The Board found that the parties’ goods are likely purchased with ordinary care.

Strength. The sixth DuPont factor considers the conceptual and commercial strength of Opposer’s mark and the scope of protection to which it is entitled. The Board found this factor neutral. Regarding conceptual strength, the Board said it did not find evidence of conceptual weakness of the three-letter string LAV that forms Opposer’s LAV stylized marks. As for commercial weakness, the Board did not find LAV commercially weak.

Similarity of the marks. The first DuPont factor considers the similarity or dissimilarity of the marks in their entireties as to appearance, sound, connotation, and commercial impression. The Board found this factor weighs strongly against likelihood of confusion. The Board concluded that the marks, when considered in their entireties, are different in appearance and create different commercial impressions. Opposer’s marks are three-letter stylized marks where the letters LAV are recognizable; LAV has no meaning in English in relation to Opposer’s goods. Applicant’s mark is a composite mark consisting of highly stylized lettering that is less discernable or readily perceived as the letters LA, and incorporating a golf club design element, which adds to the overall commercial impression. LA in Applicant’s mark has meaning as a geographic term that has been disclaimed. The degree of stylization in Applicant’s mark is so high that it is more akin to a design mark rather than a stylized display of the letters.

The Case is Opposition No. 91293362.

Attorneys: Michael F. Swartz (Egbert, McDaniel & Swartz, PLLC) for NameGürok Turizm Ve Madencilik Anonim Sirketi. Jordan A. Lavine (Flaster Greenberg PC) for TGL Golf Holdings, LLC.

Companies: TGL Golf Holdings, LLC

Cases: Trademark