US trade marks: Threats of TTAB Cancellations

Managing IP is part of Legal Benchmarking Limited, 1-2 Paris Gardens, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

US trade marks: Threats of TTAB Cancellations

In Teksystems v Teksavvy Solutions, the US District Court for the District of Maryland addressed the issue of whether a party's threat to initiate a cancellation action against a trade mark registration before the US Trademark Trial and Appeal Board (TTAB) was sufficient to create a case or controversy which provides a basis upon which a party may seek a declaratory judgment concerning the validity of a mark.

Defendant, Teksavvy, had filed a trade mark application for the mark TEKSAVVY which was refused by the United States Patent and Trademark Office based on a likelihood of confusion with a US trade mark registration for the TEKSAVVY mark owned by plaintiff, Teksystems. Following the issuance of the refusal, Teksavvy's attorney sent Teksystems a letter which sought a consent to registration from Teksystems, noting that Teksavvy had superior rights in the TEKSAVVY mark based on its prior use of the mark which would provide a basis to seek cancellation of Teksavvy's registration if the parties could not reach an amicable resolution. Teksystems responded by filing a lawsuit seeking a declaratory judgment of the validity of its mark and asserting a claim for trade mark infringement under the Lanham Act. Teksavvy, in turn, filed a motion to dismiss the claims, asserting that the court lacked subject matter jurisdiction to decide the declaratory judgment claim because no case or controversy existed.

Under US law, a party who has been threatened with a trade mark infringement claim has the basis upon which to initiate a declaratory judgment action to determine its rights rather than wait for the threatening party to take action. As the court in Teksystems noted, in order to bring a declaratory judgment action, a plaintiff must satisfy the case or controversy requirement which requires that it establish the existence of a dispute that is "definite and concrete, touching the legal relations of parties having adverse legal interests; and that is real and substantial." In its motion to dismiss, Teksavvy argued that no controversy existed because it never threatened litigation but, rather, threatened only to file a cancellation action with the TTAB.

Citing prior precedent, the court held that the threat of a cancellation action, alone, was not sufficient to establish subject matter jurisdiction or a standalone cause of action. The court distinguished this case from cases where a plaintiff sought declaratory action based on a fear of an impending infringement suit, indicating that since the plaintiff owned the trade mark registration, it was "not decidedly faced with the position of either pursuing arguably infringing behaviour or abandoning it use of the mark." As such, the court found that there was no "conclusive evidence of the existence of a live infringement suit" and granted Teksavvy's motion to dismiss the declaratory judgment claim. The court did, however, indicate that Teksystems could bring an infringement action against Teksavvy if it so desired and denied the motion to dismiss that claim.

This case is instructional as it provides guidance to parties involved in a trade mark dispute as to which threats may serve as the basis for filing a declaratory judgment action (and which threats may not provide such a basis).

ash-karen-artz.jpg

danow.jpg

Karen Artz Ash

Bret J Danow

Katten Muchin Rosenman LLP 

575 Madison Avenue

New York, NY 10022-2585

United States

Tel: +1 212 940 8554

Fax: +1 212 940 8671

karen.ash@kattenlaw.com

www.kattenlaw.com

more from across site and SHARED ros bottom lb

More from across our site

As trade secret filings rise due to AI development and economic espionage concerns, firms are relying on proactive counselling to help clients navigate disputes
IP firm leaders share why they remain positive in the face of falling patent applications from US filers, and how they are meeting a rising demand from China
The power of DEI to swing IP pitches is welcome, but why does it have to be left so late?
Mathew Lucas has joined Pearce IP after spending more than 25 years at Qantm IP-owned firm Davies Collison Cave
Exclusive survey data reveals a generally lax in-house attitude towards DEI, but pitches have been known to turn on a final diversity question
Managing IP will host a ceremony in London on May 1 to reveal the winners
Abigail Wise shares her unusual pathway into the profession, from failing A-levels to becoming Lewis Silkin’s first female IP partner
There are some impressive AI tools available for trademark lawyers, but law firm leaders say humans can still outthink the bots
Lawyers at Simmons & Simmons look ahead to a UK Supreme Court hearing in which the court will consider whether English courts can determine FRAND terms when the licence is offered by an intermediary rather than an SEP owner
Firm says appointment of Jeremy Drew from RPC will help create ‘unrivalled IP powerhouse’, as it looks to shore up IP offering ahead of merger
Gift this article