The Federal Circuit has upheld the Trademark Trial and Appeal Board’s ruling that watchmaker M.Z. Berger did not provide sufficient evidence to show a “bona fide intent” to use the mark iWATCH and could not register same. M.Z. Berger & Co., Inc. v. Swatch AG (Swatch SA) (Swatch Ltd.), Case No. 14-1219 (Fed. Cir. June 5, 2015).