# TTAB Rulings: September 2026

> Trademark Trial and Appeal Board decisions tracked this month, week by week.

- [A phrase used only as a document's heading is not a service mark](https://distinctive-mark.com/rulings/in-re-international-first-committee-association/index.md): A phrase used only as the heading of a values statement reads as its title, not as a service mark; DECLARATION OF INTERDEPENDENCE refused. (2026-09-28)
- [A surname plus a word for the business is still just a surname](https://distinctive-mark.com/rulings/in-re-hansen-honey-farm/index.md): A common surname followed by a phrase that names the kind of business behind the goods is still primarily merely a surname; here, HANSEN HONEY FARM for honey. (2026-09-22)
- [A word for a product category can describe the services built around it](https://distinctive-mark.com/rulings/in-re-agbio/index.md): A term that names a category of products can describe broadly identified services built around them; BIOINPUT refused for agricultural services. (2026-09-15)
- [A mark an employee first uses on the job belongs to the employer](https://distinctive-mark.com/rulings/olsman-mackenzie-peacock-wallace-v-thomas/index.md): Ownership follows first use, and use made as an employee is presumed to be the employer's. A brand idea brought to a new job, a domain name and friendly emails about "your logo" will not overcome that presumption. Anyone who wants to keep a mark through a change of employer should use it in their o… (2026-09-10)
- [Third-party marks using a translation do not show a foreign-word mark is weak](https://distinctive-mark.com/rulings/cielo-e-terra-v-hoteles-y-vinedos-del-valle-de-guadalupe/index.md): Applicants who argue that a cited mark is weak must show third parties using the shared term itself, not its English meaning. And a handful of web captures will not prove a crowded field in a large national market, because the Board ties the number of uses needed to the number of sellers in that ma… (2026-09-03)