In re Kapalua Land Company, Ltd. , Serial No. 76670962 (March 26, 2013) [not precedential].A mark is primarily geographically descriptive under Section 2(e)(2) if (1) the mark’s primary significance is the name of a place generally known to the public, and (2) the relevant public would be likely to make a goods or services/place association (i.e., would be likely to believe that the services originate in the place named in the mark).Applicant owns the… [read post]