Letter Re Kimsaprincess SKKN Trademark Redacted

July 21, 2021
SENT VIA FEDEX TO
With a copy via email to and
FOR SETTLEMENT PURPOSES ONLY – F.R.E. 408
RE: Trademark Filings for SKKN and SKKN BY KIM
Dear
This firm represents Beauty Concepts LLC (“Beauty Concepts”) of Washington, DC, and Brooklyn,
New York, in trademark and intellectual property matters. We write concerning the pending trademark
applications of Kimsaprincess Inc. (“Kimsaprincess”) for SKKN and SKKN BY KIM along with the
pending use of such marks.
Since at least July of 2017, Beauty Concepts has provided salon, skin care, and beauty spa services
under its SKKN+SM brand name. Over the course of four years, Beauty Concepts has built a successful
woman- and black-owned small business and brand, established a strong social media presence, and
served thousands of customers from its Brooklyn location. Beauty Concepts also operates a website at
skknplus.com, where it advertises its services and sells beauty and skin care products. Beauty Concepts’
website and social media handles (Facebook, Instagram, and Twitter) have consistently promoted the
SKKN+ SM services since the summer of 2017. See, for example, and Instagram screenshot below. Since
late 2020, Beauty Concepts has been taking steps to expand into a bigger location in Brooklyn.
For more on the history of Beauty Concepts’ use the SKKN+ SM brand since 2018, see
 www.skknplus.com,
 https://www.facebook.com/SKKNPLUS,
 https://www.twitter.com/skknplus, and
 https://www.instagram.com/skknplus.
On March 28, 2021, Beauty Concepts applied with the U.S. Patent and Trademark Office (“USPTO”) to
register the SKKN+SM word logo for use in connection with “Skin care salon services care services;
Beauty spa services; Skin care services; Beauty salon services” in International Class 44. See
Application Serial No. 90/608,147. At the time of the filing, there were no pending applications or
registrations by any other party featuring any variation of “SKKN.” For three years, Beauty Concepts
has invested considerable time, effort, and money developing and marketing its SKKN+SM services and
brand, and in March it took steps to further protect its brand name.
It has recently come to Beauty Concepts’ attention that Kimsaprincess has filed multiple trademark
applications for SKKN and SKKN BY KIM covering skincare products, beauty products, lifestyle
products, retail store services, online and video entertainment services, and “Beauty salon services;
skincare services; nail salon services; hair salon services; health and beauty spa services, namely,
cosmetic face and body care” in International Class 44. The Kimsaprincess applications were all filed
based on intent to use just days after the Beauty Concepts filing - except for the July 9, 2021, filing for
SKKN in Class 3 that also asserted a January 25, 2021, priority date based on a trademark application
filing in Jamaica, in Serial No. 90/819,462.
Beauty Concepts has clear priority of use of its SKKN+SM mark as it was in use for more than three
years prior to any trademark filing or priority date from Kimsaprincess. The respective marks are almost
indistinguishable as the Kimsaprincess SKKN and SKKN BY KIM marks mimic the innovative
“SKKN” spelling first adopted by Beauty Concepts. The marks are nearly identical in appearance,
sound, and meaning, and the addition of “BY KIM” to some of the Kimsaprincess marks and filing does
little to differentiate the brands. Additionally, the products and services of Beauty Concepts and
Kimsaprincess, as asserted in the USPTO filings, are overlapping or identical as to Class 44 and related
as to the other Classes in the fields of skin and beauty.
Given the foregoing, Beauty Concepts has clear grounds to oppose any of the applications for SKKN or
SKKN BY KIM should they be approved by the USPTO. Furthermore, Beauty Concepts is very
concerned about potential infringement of its mark, as well as the possibility of reverse confusion, in the
event that Kimsaprincess begins use of the SKKN or SKKN BY KIM marks in commerce for any skin
or beauty products or services.
Given Beauty Concepts clear priority in the SKKN+SM name, Beauty Concepts demands that
Kimsaprincess immediately withdraw its pending trademark applications featuring SKKN and SKKN
BY KIM and agree in writing never to use SKKN as part of any brand name for skin care or beauty
services or products.
Beauty Concepts takes this matter extremely seriously. We have written expeditiously upon learning
about the Kimsaprincess trademark filings and intended use of the SKKN and SKKN BY KIM marks.
Beauty Concepts also must note that any use of the SKKN and/or SKKN BY KIM marks in commerce
could constitute infringement of Beauty Concepts SKKN+ SM mark, unfair competition, and other
Lanham Act and/or state intellectual property law violations..
We are aware that Kimsaprincess is in the process of rebranding its KKW brand and that it was
previously announced that KKW would be closing August 1, 2021. As a result, time is of the essence in
addressing this matter.
If Kimsaprincess promptly responds, expressing a genuine intent to comply with these demands, Beauty
Concepts may be willing to agree upon reasonable conditions to help minimize any resulting
disruptions. However, given the urgency of this matter, if we do not receive a favorable response from
Kimsaprincess by the close of business on July 27, 2021, Beauty Concepts will have to consider taking
any necessary legal steps to protect its consumers from confusion, including litigation and seeking an
injunction. If this matter is not resolved quickly, Beauty Concepts may also no choice but to go to the
media to share the business and brand story of SKKN+ SM and the resulting trademark situation. If this
matter is litigated, Beauty Concepts will be entitled to discovery about what Kimsaprincess knew about
the SKKN+SM brand and when, prior to its decision to adopt the SKKN and SKKN BY KIM names.
We note that Beauty Concepts does not wish to stop Kimsaprincess from operating a successful skin
care and beauty product line and/or related services, but only to protect its investment of time and
money building in the SKKN+ SM brand over the last three years and to guard against any confusion
and/or reverse confusion that could ensue. Co-existence of the brands is not tenable given the
similarities and given the social media and online presence of Kimsaprincess principal, Ms. Kardashian.
If you wish to discuss this matter, I can be reached by email at or by phone at
Nothing contained in or omitted from this letter shall be used to prejudice the rights and remedies of
Beauty Concepts LLC, all such rights hereby expressly reserved.
Sincerely,
Erik M. Pelton,
ERIK M. PELTON & ASSOCIATES, PLLC®
cc: Beauty Concepts LLC

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July 21, 2021

SENT VIA FEDEX TO

With a copy via email to and

FOR SETTLEMENT PURPOSES ONLY – F.R.E. 408

RE: Trademark Filings for SKKN and SKKN BY KIM

If you wish to discuss this matter, I can be reached by email at or by phone at

cc: Beauty Concepts LLC

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