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Rebecca Curtin v. United Trademark Holdings, Inc.

Paid petition · United States Court of Appeals for the Federal Circuit, No. 2023-2140 · judgment May 22, 2025


Certiorari denied · April 20, 2026
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

Whether a party desiring to participate in an administrative agency proceeding, including a trademark opposition proceeding at the United States Patent and Trademark Office, must satisfy the zone-of-interests and proximate-causation tests set forth in Lexmark International, Inc. v. Static Control Components, Inc., 572 U.S. 118 (2014), for causes of action in federal court.

Counsel of record

For petitioner
Ryan C. Morris
Workman Nydegger

For respondent
Thomas Willcox Brooke
Holland & Knight LLP

Case

Conference history
Distributed for 2 conferences

Amicus briefs
1 cert-stage

Linked docket
25A157

Proceedings

  1. Apr 20 2026
    Petition DENIED.
  2. Mar 25 2026
    DISTRIBUTED for Conference of 4/17/2026.
  3. Mar 24 2026
    Reply of petitioner Rebecca Curtin filed. (Distributed)
  4. Mar 11 2026
    Brief of respondent United Trademark Holdings, Inc. in opposition filed.
  5. Feb 11 2026
    Motion to extend the time to file a response is granted and the time is extended to and including March 11, 2026.
  6. Feb 09 2026
    Motion to extend the time to file a response from January 5, 2026 to March 11, 2026, submitted to The Clerk.
  7. Dec 04 2025
    Response Requested. (Due January 5, 2026)
  8. Nov 25 2025
    DISTRIBUTED for Conference of 12/12/2025.
  9. Nov 10 2025
    Brief amicus curiae of Organization for Transformative Works filed.
  10. Oct 03 2025
    Petition for a writ of certiorari filed. (Response due November 10, 2025)
  11. Aug 06 2025
    Application (25A157) granted by The Chief Justice extending the time to file until October 3, 2025.
  12. Aug 04 2025
    Application (25A157) to extend the time to file a petition for a writ of certiorari from August 20, 2025 to October 3, 2025, submitted to The Chief Justice.