IP Law Daily, TRADEMARK—TTAB: Registration for BMF mark in entertainment services canceled for nonuse, (Mar 17, 2026)

By Steven D. Cole, J.D.

The petitioner successfully demonstrated that the registration owner of the mark BMF in connection with entertainment media did not commercially use the mark during the relevant time.

The Trademark Trial and Appeal Board (the Board) granted a cancellation petition filed by Zuffa, LLC (Zuffa) with regard to the mark BMF. The respondent, Byron Belin, owned the mark’s registration in connection with 12 listed services in Class 41, all relating to entertainment media. No reliable evidence in the record showed that Belin used the BMF mark in connection with the services listed in his registration prior to January 30, 2020, the (extended) deadline provided to him for filing a Statement of Use (SOU). The Board’s decision was strongly influenced by the lack of documentary evidence purporting to demonstrate commercial use, as well as Belin’s vague and evasive deposition testimony, which evinced his extreme lack of credibility (Zuffa, LLC v. Belin, No. 92077633 (T.T.A.B. Mar. 10, 2026)).

Background. Belin was issued Registration No. 6002970 on March 3, 2020, maturing from an application filed on July 19, 2017, for the standard character mark BMF covering 12 services in Class 41 pertaining to entertainment media. (Relatedly, Belin filed suit against entertainer 50 Cent and others in December 2021 over their use of the acronym BMF for the Starz television series “Black Mafia Family”).

Zuffa attempted to register the mark BMF in September 2019 in connection with live stage shows and performances featuring sports and mixed martial arts, among other Class 41 services, and was refused registration due to likelihood of confusion. (Zuffa owns and runs the Ultimate Fighting Championship and sought to trademark BMF as an acronym for “Baddest Mother F*cker” for marketing use.) Consequently, Zuffa filed a petition to cancel Belin’s registration based on abandonment through nonuse, arguing that Belin had not used the BMF mark in connection with the 12 services listed in his registration prior to the expiration date for filing an SOU, which, after three extensions of time, was January 30, 2020.

The parties conducted discovery and attended an oral hearing before the TTAB on November 25, 2025.

Zuffa’s arguments in support of cancellation. According to Zuffa, Belin “identified himself as the person most knowledgeable about the facts and circumstances related to his use of the BMF Mark in commerce.” Remarkably, during his discovery deposition taken in March 2024, Belin testified that he had no recollection of his use of the BMF mark for the relevant time. When pressed on several points, he was evasive and repeatedly responded, “I don’t recall,” and that his attorney had the information sought. And though Zuffa specifically requested Belin to admit into evidence any records showing sales information for the services listed in the registration, and Belin had ample time to do so, Belin produced a single $600 sales receipt, dated December 18, 2019, addressed both to and from “HeataHD Visuals,” on which “FOR BMF PROP MONEY” was hand-written.

Belin’s arguments against cancellation. Belin, on the other hand, contended that he hired a videographer in October 2017 to film “BMF The Series.” He submitted a non-disclosure agreement as evidence, but it was illegible and appeared to be signed by only a single party. Belin claimed to have hired a writer for the show in 2018 and started hiring actors, but there was no evidence that any production or project ever materialized. He also claimed to have filmed a first episode and created a 44-second promotional video (comprised of a montage of still images), but did not introduce them into evidence. Instead, Belin provided only website addresses for these putative recordings, which are insufficient to be considered content of record because URLs “an be changed or deleted. See In re Olin Corp., No. 86651083, 2017 TTAB LEXIS 337 (TTAB Sept. 22, 2017). Finally, Belin relied upon screenshots taken from his Facebook page, which appeared to have a January 10, 2020, date, portraying BMF merchandise.

The Board’s decision. The Board ultimately found Belin’s testimony to be “not at all credible.” Its decision articulated that the Board members were “left with an ‘extreme skepticism regarding the credibility’ of Respondent because he … professed not to know basic information that a person in his position would normally be expected to know” (quoting Nationstar Mortg. LLC v. Ahmad, No. 91177036, 2014 TTAB LEXIS 350, at *37 (TTAB Sept. 30, 2014)). The Board also drew adverse inferences from Belin’s responses to Zuffa’s discovery requests, as he produced documents having “serious flaws” which did not persuade the Board that Belin was actually rendering any of the listed services on or before January 30, 2020: “Put simply, we are not convinced that the single sale of ‘prop money’ is tantamount to multimedia production services.”

Therefore, finding no credible evidence in the record that Belin, prior to January 30, 2020, used BMF as a mark in connection with the services listed in his registration, the TTAB granted Zuffa’s petition to cancel Belin’s registration for the mark BMF for all of the listed services on the ground of nonuse.

The Case is Cancellation No. 92077633.

Judge: NA.

Attorneys: John L. Krieger (Dickinson Wright PLLC) for Zuffa, LLC. Jeremy T. Katz (Hall Griffin LLP) for Byron Belin.

Companies: Zuffa, LLC

Cases: Trademark USPTO