Trademark Trial and Appeal Board Electronic Filing System. https://estta.uspto.

gov
ESTTA Tracking number: ESTTA1228489
Filing date: 08/11/2022

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

Notice of Opposition
Notice is hereby given that the following parties oppose registration of the indicated application.

Opposers information
Name Ms. Elizabeth Chan
Entity Individual Citizenship UNITED STATES
Address BOWLING GREEN STATION
P.O. BOX 1432
NEW YORK, NY 10274
UNITED STATES

Name Battery Park Media LLC d/b/a Merry Bright Music Enterprises
Entity limited liability company Citizenship New York
Address BOWLING GREEN STATION
P.O. BOX 1432
NEW YORK, NY 10274
UNITED STATES

Attorney informa- LOUIS W TOMPROS

tion WILMER CUTLER PICKERING HALE AND DORR LLP
60 STATE STREET
BOSTON, MA 02109
UNITED STATES
Primary email: [email protected]
Secondary email(s): [email protected], kev-
[email protected], [email protected]
617 526 6886
Docket no. 1999940.699

Applicant information
Application no. 90571927 Publication date 07/12/2022
Opposition filing 08/11/2022 Opposition period 08/11/2022
date ends
Applicant Lotion, LLC
21731 VENTURA BOULEVARD, SUITE 300
WOODLAND HILLS, CA 91364
UNITED STATES

Goods/services affected by opposition

Class 003. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Fragrances for personal use, fragranced-
products, namely, perfume, eau de parfum; scented products, namely, body lotions; cosmetics; non-
medicated skin care preparations; make-up; spa items, namely, massage oils, aromatherapy
products in the nature of aromatherapy sprays comprised of essential oils, lotions for cosmetic pur-
poses, body creams; hair care preparations; nail polish
Class 009. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Musical sound recordings; downloadable
musical sound recordings; audiovisual recordings featuring musical entertainment; downloadable au-
diovisual recordings featuring musical entertainment; motion picture films featuring music, family, holi-
day and variety entertainment; prerecorded phonograph albums featuring singing and music; com-
pact discs, all featuring music; a series of musical sound recordings; a series of musical video record-
ings; a series of audio visual recordings featuring musical and musical based entertainment, a series
of downloadable musical sound recordings, a series of downloadable musical video recordings, a
seriesof downloadable audio visual recordingsfeaturing music and musical based entertainment, and
a series of downloadable ring tones for mobile phones; eyewear, sunglasses, cases for eyeglasses
and sunglasses
Class 010. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Protective masks, namely, sanitary masks
for protection against viral infection; protective face masks, namely, fashionface masks being sanitary
masks for protection against viral infection
Class 014. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Jewelry, jewelry boxes
Class 016. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Printed materials, namely, books featuring
photographs, information and storieson Christmas, children's stories; printed posters
Class 018. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Carrying cases; backpacks; dog clothing;
dog clothing accessories, namely, dog collars and dog leashes
Class 021. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Beverage glassware, cups, mugs, cork-
screws, cocktail shakers; beverageware; mugs
Class 025. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Clothing, namely, shirts, t-shirts, sweat-
shirts, hooded jackets, headwear, caps, sleepwear, pajamas, one-piece garmentsfor children, linger-
ie, tank tops, hooded shirts and sweatshirts, bandanas; footwear; clothing masks in the nature of face
masks and fashion masks, namely, knit face masks being headwear
Class 028. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Christmas tree decorations, namely, orna-
ments and decorations for trees; toys and accessories, namely, dolls
Class 029. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Food products, namely, milk, chocolate milk
and beverages having a milk base; oat milk, coconut milk, almond milk, soy milk, nut milk, rice milk,
lactose-free milk
Class 030. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Food products, namely, cookies, cookie
and cake mixes, hot chocolate and frozenhot chocolate; coffees, teas, chocolates and chocolate-
based ready to eat candies and snacks
Class 032. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Beer, ale, lager, stout and porter; non-
alcoholic beverages, namely, carbonatedbeverages and non-carbonated soft drink, fruit juices, water
beverages, coconutwater
Class 033. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Alcoholic beverages, except beer;
wine;alcoholic coffee-based beverages; alcoholic chocolate-based beverages; alcoholic beverages,
except beer, containing milk, chocolate milk, oat milk, coconut milk, almond milk, soy milk, nut milk, ri-
cemilk, or lactose-free milk; spirits andliqueurs
Class 035. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Online retail store services featuring fra-
grances for personal use, fragranced products, perfume, eau de parfum, scented products, body lo-
tions, cosmetics, non-medicated skin care preparations, make-up, spa items, massage oils, aroma-
 therapy products in the nature of aromatherapysprays comprised of essential oils, lotions for cosmet-
ic purposes, body creams,hair care preparations, nail polish, musical sound recordings, download-
able musical sound recordings, audiovisual recordings featuring musical entertainment, download-
able audiovisual recordings featuring musical entertainment, motion picture films featuring music,
family, holiday and variety entertainment, prerecordedphonograph albums featuring singing
andmusic, compact discs, all featuring music, a series of musical sound recordings, a series of mu-
sical video recordings, a series of audio visual recordings featuring musical and musical based enter-
tainment, a series of downloadable musical sound recordings, a series of downloadable musical
video recordings, a series ofdownloadable audio visual recordings featuring music and musical based
entertainment, a series of downloadable ring tones for mobile phones, eyewear, sunglasses, cases
for eyeglasses and sunglasses, protective masks, sanitary masks for protection against viral infec-
tion, protective face masks, fashion face masks beingsanitary masks for protection against viral infec-
tion, jewelry, jewelry boxes, printed materials, books featuring photographs, information and stories
on Christmas, children's stories, printed posters, carrying cases, backpacks, dog clothing, dog cloth-
ing accessories, dog collars, dog leashes, beverage glassware, cups, mugs, corkscrews, cocktail
shakers, beverageware, mugs, clothing, shirts, t-shirts, sweatshirts, hooded jackets, headwear, caps,
sleepwear, pajamas, one-piecegarments for children, lingerie, tank tops, hooded shirts, sweatshirts,
bandanas, footwear, clothing masks in the nature of face masks and fashion masks, knit face masks
being headwear, Christmas tree decorations, ornaments and decorationsfor trees, toys and ac-
cessories, dolls,food products, milk, chocolate milk andbeverages having a milk base, oat
milk,coconut milk, almond milk, soy milk, nut milk, rice milk, lactose-free milk, cookies, cookie and
cake mixes, hot chocolate and frozen hot chocolate, coffees, teas, chocolates and chocolate-based
ready to eat candies and snacks, beer, ale, lager, stout and porter, non-alcoholic beverages, carbon-
ated beverages and non-carbonated soft drink, fruit juices, water beverages, coconut water, alcoholic
beverages, except beer, wine, alcoholic coffee-based beverages, alcoholic chocolate-based bever-
ages, alcoholic beverages, except beer, containing milk, chocolate milk, oat milk, coconut milk, al-
mond milk, soy milk, nut milk, rice milk, or lactose-free milk, spirits and liqueurs
Class 038. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Streaming of audio and audio visual materi-
al on the internet featuring music and musical based entertainment; providingonline chatrooms for
transmission of messages among computer users concerning amusical artist and such artist's mu-
sic,sound and video recordings, pictures, news, special projects, personal appearances, and bio-
graphical material
Class 041. First Use: None First Use In Commerce: None
All goods and services in the class are opposed, namely: Entertainment services in the nature oflive
musical performances by an individual, online non-downloadable ongoing recorded programs and
specials featuring musical, family, holiday, and variety entertainment, all accessible by television,the
internet and wireless devices; entertainment services and web-based services, namely, online non-
downloadable ongoing recorded programs and specials featuring musical, family, holiday, and variety
entertainment, all accessible by television, the internet and wireless devices; providing online non-
downloadable ongoing prerecorded audio and video programsand specials featuring musical, fam-
ily,holiday and variety entertainment, all accessible via the internet and wirelessdevices; providing on-
line non-downloadable ongoing recorded webisodes featuringmusical, family, holiday and variety en-
tertainment, all available via a global computer network; providing information on a television pro-
gram, special entertainment program, and online entertainmentprogram and motion picture featuring
music, family, holiday and variety entertainment, and providing a website featuring non-downloadable
photographs in the field of such program and motion picture, and other entertainment information via
the internet and wireless devices; entertainment services in the nature of live musical performances
by an individual; entertainment services in the nature of periodic live musical performances by an in-
dividual; entertainment services in the nature of live singing performances byan individual; providing
non-downloadable prerecorded music at a website and entertainment information on a musical per-
former via a website on a global computer network; providing entertainment information on a musical
artist and on such artist's music, sound and video recordings, pictures, news, special projects, an-
dpersonal appearances via a website on aglobal computer network

Grounds for opposition

Priority and likelihood of confusion Trademark Act Section 2(d)
False suggestion of a connection with persons, Trademark Act Section 2(a)
 living or dead, institutions, beliefs, or national
symbols

Mark cited by opposer as basis for opposition

U.S. application/ registration NONE Application date NONE
no.
Register NONE
Registration date NONE
Mark QUEEN OF CHRISTMAS
Goods/services Musical sound recordings, downloadable musical sound recordings,
audiovisual recordings featuring musical entertainment, downloadable
audiovisual recordings featuring musical entertainment, motion pic-
tures featuring music, family, holiday and variety entertainment,
prerecorded phonograph albums featuring singing and music, com-
pact discs, all featuring music, a series of musical sound recordings, a
series of musical video recordings, a series of audio visual recordings
featuring musical and musical based entertainment, a series of down-
loadable musical sound recordings, a series of downloadable musical
video recordings, a series of downloadable audio visual recordings
featuring music and musical based entertainment, and a series of
downloadable ring tones for mobile phones; Â# Streaming of audio
and audio visual information featuring music and musical based enter-
tainment; providing online chatrooms for transmission of messages
among computer users concerning a musical artist and such artistÂ#s
music, sound and video recordings, pictures, news, special projects,
personal appearances and biography; and Â# Entertainment services,
namely, continuing programs and specials featuring musical, family,
holiday, and variety entertainment accessible by television, the inter-
net and wireless internet-connected devices; providing online non-
downloadable prerecorded audio and video content featuring musical,
family, holiday and variety entertainment via the internet and wireless
devices; providing ongoing webisodes featuring musical, family, holi-
day and variety entertainment; providing information on a television
program, special entertainment program, online entertainment pro-
gram, and motion picture featuring music, family, holiday and variety
entertainment; providing a website featuring online, non-
downloadable photographs in the field of such programs and motion
picture, and providing other entertainment information via the internet
and wireless devices; entertainment services in the nature of live mu-
sical performances by an individual; entertainment services in the
nature of periodic live musical performances by an individual; enter-
tainment services in the nature of singing performances by an indi-
vidual; providing a website featuring online, non- downloadable music
and entertainment information on a musical performer via a global
computer network; providing information on a musical artist and such
artist's music, sound and video recordings, pictures, news, special
projects, and personal appearances via a website on a global com-
puter network.

Related proceed- Trademark Opposition No. 91275972 for the mark QOC
ings

Attachments NOP QUEEN OF CHRISTMAS 90571927.pdf(943501 bytes )

Signature /barbara a. barakat/

Name Barbara A. Barakat
Date 08/11/2022
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 1

IN THE UNITED STATES PATENT AND TRADEMARK

OFFICE BEFORE THE TRADEMARK TRIAL AND
APPEAL BOARD

Commissioner for Trademarks

P.O. Box 1451
Alexandria, VA 22313-1451

In the matter of trademark application

Serial No. 90/571927
For the word mark QUEEN OF CHRISTMAS
Published in the Official Gazette on July 12, 2022

)
)
ELIZABETH CHAN, )
)
Opposer, )
)
BATTERY PARK MEDIA, LLC, )
)
Opposer, )
)
v. )
)
LOTION, LLC, )
)
Applicant. )
)
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 2

NOTICE OF OPPOSITION

Christmas is big enough for more than one “Queen.” Over the decades, several

recording artists have been dubbed with the nickname the “Queen of Christmas”, including

Darlene Love, Brenda Lee, Elizabeth Chan, and Mariah Carey. This is a perennial nickname

that has been and will continue to be bestowed on multiple future singers for decades to

come.

Mariah Carey, by her own admission, does not even consider herself to be the

“Queen of Christmas” and has long shunned the nickname, including as recently as

December 2021. But this opposition proceeding is sadly necessary because Ms. Carey’s

“Lotion LLC” company is nevertheless trying to claim sole ownership of the title and

designation “Queen of Christmas” through a series of trademark applications. Specifically,

Ms. Carey’s company is attempting to register and control four “Queen of Christmas”-

related trademarks: “Princess Christmas,” “Christmas Princess,” “QOC” (the acronym for

Queen of Christmas), and the subject of this opposition, “Queen of Christmas”.

But musician Elizabeth Chan—pop music’s only full-time Christmas singer

songwriter—has herself been repeatedly dubbed the “Queen of Christmas.” She has

prolifically written, composed, and performed only original Christmas holiday-themed

songs for more than a decade. Due to the notoriety that she’s attained for this singular and

specific achievement, Elizabeth Chan has been referred to as the “Queen of Christmas” by

multiple media, including in 2018 by The New Yorker magazine.

And Ms. Chan has embraced and used that title, designation, brand, and mark

commercially for years – at least since 2014. The words “Queen of Christmas” should not

be owned or controlled by Lotion LLC—particularly since Ms. Carey herself has candidly
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 3

admitted that she “did not create the title or the moniker ‘Queen of Christmas’,” and she

does not even consider herself the Queen of Christmas. See 'That title belongs to St. Mary':

Mariah Carey renounces 'Queen of Christmas' title as she believes the mother of Jesus is

more deserving, DAILY MAIL (Dec. 17, 2021), available at

https://www.dailymail.co.uk/tvshowbiz/article-10321715/Mariah-Carey-humbly-

confesses-not-Queen-Christmas.html (Ex. 1).

Thus, Opposer, ELIZABETH CHAN (hereinafter “Ms. Chan”), whose address is

Bowling Green Station, P.O. Box 1432, New York, NY 10274, and Opposer, BATTERY PARK

MEDIA LLC, d/b/a MERRY BRIGHT MUSIC ENTERPRISES, whose address is also

Bowling Green Station, P.O. Box 1432, New York, NY 10274, 1 believe that they will be damaged

by the issuance of a registration for the alleged mark QUEEN OF CHRISTMAS, as shown

in Serial No. 90/571927, filed March 10, 2021, by LOTION LLC (hereinafter

“Applicant”), and published for opposition in the Official Gazette of July 12, 2022. Ms.

Chan and Battery Park Media hereby collectively oppose the issuance of that registration

pursuant to Section 13(a) of the Lanham Trademark Act of 1946 (“Lanham Act”), 15 U.S.C.

§ 1063(a), based on both likelihood of confusion under 15 U.S.C. § 1052(d) and false

association under 15 U.S.C. § 1052(a).

As grounds for opposition, Ms. Chan and Battery Park Media allege as follows:

1. Ms. Chan is a musician who has released exclusively Christmas music and

other Christmas-related entertainment products and services for at least the last ten years.

2. Battery Park Media LLC is an entertainment business established and run by

1
Battery Park Media LLC is an entertainment company owned and operated by Ms. Chan. For purposes
of this opposition, all harms and references to the goods and services offered by Ms. Chan apply to those
offered by Battery Park Media LLC.
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 4

Ms. Chan.

3. Media sources dubbed Ms. Chan the “Queen of Christmas” at least as early as

2014. See Mark Strickland, Elizabeth Chan Talks About Writing ONLY Christmas Music,

Her International Record Deal, And How Santa Must Feel, ALL ACCESS MUSIC (Dec. 9,

2014), available at https://music.allaccess.com/elizabeth-chan-talks-about-writing-only-

christmas-music-her-international-record-deal-and-how-santa-must-feel/.

4. Ms. Chan has used the brand “Queen of Christmas” in United States commerce

in connection with, among other various goods and services, the sale and licensing of music,

books, and entertainment services over the last decade. Attached hereto as Exhibit 2 are

photographs and copies of representative samples of marketing materials showing Ms.

Chan’s use of the “Queen of Christmas” brand in connection with these goods and services.

5. As a result of this use, consumers in the United States have come to associate

the “Queen of Christmas” brand with Ms. Chan and Ms. Chan’s goods and services.

6. By virtue of Ms. Chan’s many efforts, as well as expenditures of considerable

sums by Ms. Chan for advertising and promoting her goods and services under and in

connection with the “Queen of Christmas” brand, and by virtue of the excellence of the

goods and entertainment services associated with Ms. Chan’s “Queen of Christmas” brand

mark, Ms. Chan’s “Queen of Christmas” brand has gained a recognizable and valuable

reputation.

7. In addition, the brand “Queen of Christmas” has become associated with Ms.

Chan’s persona. Not only is “Queen of Christmas” used to refer to the source of Ms. Chan’s

goods and services, but it is also used to refer to Ms. Chan herself.

8. As evidenced by the publication of the mark in the July 12, 2022, Official
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 5

Gazette, Applicant seeks to register the word mark QUEEN OF CHRISTMAS as a

trademark for the following international classes of goods and services: 3, 9, 10, 14, 16, 18,

21, 25, 28, 29, 30, 32, 33, 35, 38, 41.

9. The application that is the subject of this opposition (the “Challenged

Application”) was filed on March 10, 2021, based solely upon the Applicant’s intention to

use the mark in the future, without any allegation of prior commercial use.

10. In clear contrast, Ms. Chan’s use of the “Queen of Christmas” brand has been in

commerce continuously and long prior to Applicant’s application filing and use in

commerce.

11. Ms. Chan has been providing goods and services identified in the Challenged

Application in connection with her “Queen of Christmas” brand long before Applicant filed

the Challenged Application indicating an intent to use.

12. The goods and services covered by the Challenged Application are identical in

some instances and confusingly similar in all instances to the goods and services that Ms. Chan

offers under her brand “Queen of Christmas.” The Challenged Application identifies the

following identical goods and services offered by Ms. Chan under the “Queen of Christmas”

brand:

• Musical sound recordings, downloadable musical sound recordings,

audiovisual recordings featuring musical entertainment, downloadable

audiovisual recordings featuring musical entertainment, motion pictures

featuring music, family, holiday and variety entertainment, prerecorded

phonograph albums featuring singing and music, compact discs, all featuring

music, a series of musical sound recordings, a series of musical video

Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 6

recordings, a series of audio visual recordings featuring musical and musical

based entertainment, a series of downloadable musical sound recordings, a

series of downloadable musical video recordings, a series of downloadable

audio visual recordings featuring music and musical based entertainment, and

a series of downloadable ring tones for mobile phones;

• Streaming of audio and audio visual information featuring music and musical

based entertainment; providing online chatrooms for transmission of messages

among computer users concerning a musical artist and such artist’s music,

sound and video recordings, pictures, news, special projects, personal

appearances and biography; and

• Entertainment services, namely, continuing programs and specials featuring

musical, family, holiday, and variety entertainment accessible by television,

the internet and wireless internet-connected devices; providing online

nondownloadable prerecorded audio and video content featuring musical,

family, holiday and variety entertainment via the internet and wireless devices;

providing ongoing webisodes featuring musical, family, holiday and variety

entertainment; providing information on a television program, special

entertainment program, online entertainment program, and motion picture

featuring music, family, holiday and variety entertainment; providing a

website featuring online, non-downloadable photographs in the field of such

programs and motion picture, and providing other entertainment information

via the internet and wireless devices; entertainment services in the nature of

live musical performances by an individual; entertainment services in the

Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 7

nature of periodic live musical performances by an individual; entertainment

services in the nature of singing performances by an individual; providing a

website featuring online, non-downloadable music and entertainment

information on a musical performer via a global computer network; providing

information on a musical artist and such artist's music, sound and video

recordings, pictures, news, special projects, and personal appearances via a

website on a global computer network.

13. The Challenged Application is unrestricted as to consumers and trade channels.

As such, it is presumed that Applicant’s goods and services identified in the Challenged

Application are sold to all ordinary consumers of goods and services, including consumers

of Ms. Chan’s goods and services, and travel in all ordinary trade channels, including the

trade channels through which Ms. Chan sells her goods and services under the brand “Queen

of Christmas.”

14. Registration of QUEEN OF CHRISTMAS in International Classes 3, 9, 10, 14,

16, 18, 21, 25, 28, 29, 30, 32, 33, 35, 38, and 41 would be a source of damage and injury to

Ms. Chan and Battery Park Media and a source of confusion to Ms. Chan’s many consumers

who rely upon the reputation of Ms. Chan and the high quality of Ms. Chan’s goods and

services as reflected by her “Queen of Christmas” brand, because, among other reasons,

consumers are likely to believe that Applicant’s goods and services are affiliated with or

approved by or sponsored or endorsed by Ms. Chan and the quality of the goods and services

bearing Applicant’s Mark have been approved and/or maintained by Ms. Chan.

FIRST GROUND FOR OPPOSITION

LIKELIHOOD OF CONFUSION

15. The proposed mark QUEEN OF CHRISTMAS is barred from registration

Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 8

because it consists of or comprises a mark that so resembles Ms. Chan’s previously used

“Queen of Christmas” brand as to be likely, when used in connection with the alleged goods

and services of Applicant, to cause confusion, mistake, or deception within the meaning of

15 U.S.C. § 1052(d).

SECOND GROUND FOR OPPOSITION

FALSE ASSOCIATION

16. The proposed QUEEN OF CHRISTMAS mark is effectively the same as Ms.

Chan’s “Queen of Christmas” famous title and identity, and points unmistakably to Ms.

Chan in connection with activities not connected to Ms. Chan.

17. The proposed mark QUEEN OF CHRISTMAS is barred from registration

because it consists of or comprises a mark that falsely suggests a connection with Ms.

Chan’s unique identity within the meaning of 15 U.S.C. § 1052(a)

WHEREFORE, Opposers Elizabeth Chan and Battery Park Media believe that they

will be harmed by said registration of QUEEN OF CHRISTMAS and pray that this

opposition be sustained and that registration of Applicant’s Mark “QUEEN OF

CHRISTMAS” as shown in Application Serial No. 90/571927 be refused, and for such other

and further relief in the premises as may be deemed just and proper.

The required filing fee is submitted herewith.

Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 9

Opposers hereby appoint the undersigned in connection herewith.

Respectfully submitted,

Date: 08/11/2022 By: / Louis W. Tompros /

Phone: 617-526-6886
Fax: 617-526-5000
Email:
[email protected];
[email protected];
[email protected];
[email protected]
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 10

Exhibit 1

‘That title belongs to St. Mary’: Mariah Carey renounces ‘Queen of Christmas’ title as she
believes the mother of Jesus is more deserving
DAILY MAIL
By Laura Parkin for Mailonline
Published: 11:20 EDT, 17 December 2021 | Updated: 11:38 EDT, 17 December 2021
Available at: https://www.dailymail.co.uk/tvshowbiz/article-10321715/Mariah-Carey-humbly-
confesses-not-Queen-Christmas.html

She became known as the Queen Of Christmas after releasing the infectious 1994 track All I Want for
Christmas Is You.

Yet Mariah Carey has insisted she never chose the festive moniker herself and believes the title should be
bestowed upon the Virgin Mary.

Speaking on the Zoe Ball Breakfast Show, Mariah, 52, spoke out about her love of the holidays as she
discussed her new track Fall In Love At Christmas and her new venture into writing children's books.
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 11

What! Mariah Carey humbly confessed that she is not 'The Queen of Christmas' as she detailed the
process behind her new festive track, Fall In Love At Christmas

The singer explained: 'That was other people, and I just want to humbly say that I don't consider myself
that.

'I'm someone that loves Christmas, that happened to be blessed to write All I want For Christmas Is You.
And a lot of other Christmas songs. And let's face it, you know, everybody's faith is what it is. But to me,
Mary is the Queen of Christmas.'

Mariah also revealed that she began writing her new festive song in the height of summer in Atlanta.

She began: 'So I started writing Fall In Love At Christmas over the summer. So we were in Atlanta at a
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 12

house where we made this place called the Butterfly Lounge, and we were doing all different kinds of
music. And then we decided, "Oh, this might be cool to do a Christmas song."'

More deserving: Mariah insisted she never chose the festive moniker herself and believes the title should
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 13

be bestowed upon the Virgin Mary

The glamorous star, added that they filmed the whole process so fans get to see the star in a very different
light.

She said: 'So it's not like me all glammed out. It's like me, regular, I'm in pyjamas most of the time.

'And you know, you see me writing, you see me produce and you see me singing to the guitar player, ‘can
you play do dooo doo do’ or whatever.

'So the thing is, is that most people don't see women in that capacity. And when you do, you expect to see
them very broken down, very like behind a piano, like very much behind a guitar. ‘Don't you put on a
little bit of makeup because that's not going to work.

'My thing is, I feel like I'm allowed to be both, but a lot of people are just like, "Oh, the diva, blah blah
blah." And I'm like, I write music. That's what I've been doing since I was a kid.’

Zoe said that the scenes 'are wonderful for us as fans' as the audience gets to 'glimpse' into the writing
process of how the songs come together.

Mariah thanked Zoe before she asked: 'Do you like the snow and like Kirk? We had so much fun. The
kids.'

New song! Mariah also revealed that she began writing her new festive song in the height of summer in
Atlanta as she detailed the process

She shares her twins Moroccan and Monroe, 7, with her ex-husband comedian Nick Cannon, 41, who she
divorced in 2014.

Host Zoe, mentioned the twins being present in the video as she sweetly added: 'It's so lovely to see
Notice of Opposition to Serial No. 90/571927
Mark: QUEEN OF CHRISTMAS
Page 14

Monroe and Moroccan in the video. I also love the fact in the video, they're still going about their regular
business, this is fantastic.'

Mariah: 'I love it because, especially my son, he I mean, yes - I'm not saying my daughter doesn't - but my
son picks certain Christmas songs that I've written and certain songs and he tells me, I like this part or I
like that or whatever, so it makes me really happy.'

When asked what the most over-the-top, sparkly Christmas decoration in her house was, Mariah turned to
her son for his thoughts.

She asked: 'Wow. Rocky, do you have any? So what do you think is the most over-the-top, sparkly or just
like amazing Christmas decoration? Is it a big tree in the living room?'

The youngster Rocky agreed but added: 'I also like the Christmas lights gathered around the house. Those
are cool, pretty much the entire house is pretty cool and sparkly.'

The hit-makers perhaps most famous song, All I Want for Christmas Is You was the inspiration behind
her 2015 children's picture book.

She revealed her future plans to author further publications as she excitedly exclaimed the venture: 'OK,
so I can't call it a series yet, but honey, it's amazing. I live for it, I live for it, I live for it!', she said.

Mariah in PJ's! The glamorous star, added that they filmed the whole process so fans get to see the star
in a very different light and not her usual glamorous self, as pictured

Mariah detailed: 'We have a fabulous - we're working with Macmillan. No one knows this yet, by the
way. And the woman that's working with us, she did the Harry Potter series. She did several other major,
major major books. So it's kind of amazing.'

Finally, Zoe asked the question that is on everyone's lips, as she said: 'Mariah, what is your favourite
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Christmas songs? We'll have to play it.'

Mariah revealed that her favourite Christmas song of all time is This Christmas by Donny Hathaway.

'Oh, I could have chosen one of mine, but that's one of the best, ever, greatest ever... Well, we wish you,
me and my family, we wish you a Merry Christmas,' She said.

And I just want to say thank you to all the listeners who have been supportive of me for all this time with
this song and other songs that I've done. I just want to say thank you and give love to everybody on
Christmas Day ok.'

Festive fun: Mariah revealed that her favourite Christmas song of all time is This Christmas by Donny
Hathaway
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Exhibit 2

2014 Press Release

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2016 Press Release

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Screenshot from 12/22/2020 Interview on Fox 5