Trademark rights in the United States are established through use. As such, trademark applicants are not permitted to register a trademark with the United States Patent and Trademark Office to simply reserve rights in a mark that the applicant intends to use at some indeterminate future date. The Trademark Trial and Appeal Board (“TTAB”) reminded applicants of that requirement in In re Alessandra Suuberg, 2021 USPQ2d 1209 (TTAB 2021) when it affirmed a non-use refusal under Trademark Act Section 1(a).