A phrase used only as a document's heading is not a service mark
When specimens show a phrase only as the heading of an organization's statement of values, the Board reads it as the name of that document, not as a mark for the organization's services. Prominent title placement does not help, and third-party use of the phrase for other values statements reinforces that reading (at 7–9, 12–14). A §2(f) claim cannot overcome a failure-to-function refusal (at 14 n.31).
The decision is non-precedential and rests on the specimens of record; the Board did not reach the informational-matter or direct-association grounds (at 3, 15). Unsupported argument that program titles routinely function as service marks did not substitute for evidence (at 13). In the editors' view, specimens for a program name should show it identifying the program offered, not introducing a list of principles.
The applicant sought to register DECLARATION OF INTERDEPENDENCE for STEM education programs and competitions. Its specimens were a wall plaque and a web page displaying its guiding principles under that heading (slip op. at 6–13). The Board held that the wording "merely identifies the type and nature of the statement" (at 7), relying also on declarations of interdependence from Whole Foods Market, B Corp and others (at 8–9).
Data and AI angle: a search engine "AI Overview" screenshot lacked its URL and access date; after an objection the applicant did not cure, the Board excluded it. AI-generated search summaries face the same requirements as other internet evidence (at 3–4, citing In re I-Coat). A referenced video not made of record could not be assessed (at 13 n.29).