# A surname plus a word for the business is still just a surname

> 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.

Published 2026-09-22 · Updated 2026-10-21

Canonical: https://distinctive-mark.com/rulings/in-re-hansen-honey-farm/

A common surname followed by words that name the kind of business behind the goods is still primarily merely a surname. The Board keeps refusing such marks, and this non-precedential decision follows the line it cites, such as WEISS WATCH COMPANY (at 8). An applicant's own descriptive use of the phrase can be the most damaging evidence (at 15).

The limits are the routes still open. A §2(f) claim, a distinctive design, or the Supplemental Register with a disclaimer can change the result (at 2 n.2, 20–21). The applicant's third-party registrations were distinguished for carrying disclaimers, prominent designs or a §2(f) claim (at 19–21). Other names for the business do not make the phrase less descriptive (at 16), and lack of confusion with other users does not override the surname bar (at 22). In the editors' view, an owner registering a family name with a trade descriptor should plan on one of those routes rather than argue the descriptor is suggestive.

The case: HANSEN HONEY FARM for honey products. HANSEN, the president's surname, appeared 286,420 times in a LexisNexis surname database (at 6–7). The applicant's slogan "More Than A Honey Farm" was strong evidence that HONEY FARM is descriptive (at 15–16), as were many honey businesses named for their owners plus "Honey Farm" (at 21–22). The Board did not consider 805 pages of exhibits and two DVDs filed after the appeal brief, untimely even if duplicative (at 2–5). The refusal was affirmed.

**Data angle:** surname frequency was shown with a commercial database count, which the applicant did not dispute (at 6).