“When two or more merely descriptive terms are combined, the determination of whether the composite mark also has a merely descriptive significance turns on whether the combination of terms evokes a new and unique commercial impression.” In re Omniome, Inc., No. 87661190, 2019 TTAB LEXIS 414, at *3. However, if each component retains its merely descriptive significance in relation to the goods, the combination results in a composite that is itself merely descriptive. Id.

The question is not whether someone presented with only the proposed mark could guess the goods listed in the identification, but rather whether someone who knows what the goods are will understand the proposed mark to convey information about them. DuoProSS Meditech Corp. v. Inviro Med. Devices, Ltd., 695 F.3d 1247, 1254 (Fed. Cir. 2012). 

The TTAB recently considered whether the composite GOLF DARTS was merely descriptive of “action skill games.” In re P&P Imports LLC, Ser. No. 98669267 (TTAB Sept. 25, 2026). 

     Dictionary evidence made of record by Applicant defines “golf” as “a game in which a player using special clubs attempts to sink a ball with as few strokes as possible into each of the 9 or 18 successive holes on a course.” “Dart” is defined as “a small missile usually with a pointed shaft at one end and feathers at the other” and “darts” is defined as “a game in which darts are thrown at a target.” These definitions show that golf and darts are known games that use particular implements to attain particular objectives. 

     The specimen provided for Applicant's “action skill games” and excerpts from Applicant's website and Amazon.com product listing show that Applicant's goods include a “dartboard target,” “darts scoreboard,” and so-called “‘Chip N' Stick' golf balls” that are modified with hook and loop fastener so they can stick to the target.

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Advertising on Applicant's website, www.playgosports.com, and an Amazon.com listing states “GOLF DARTS: An exciting new chipping game that combines the precision of darts with the fun of golf; The included Chip N' Stick golf balls stick to the oversized fabric target for scoring.”6 The advertising further states “TRADITIONAL DART GAMES: Practice and improve your chipping skills while playing classic darts games like Cricket and 301, or make up your own (game rules included).” As explained on Applicant's website, “GoSports Golf Darts is a fun twist on two beloved games. Hit the Chip N' Stick golf balls onto the giant fabric dartboard to score points. The target features full color graphics that make you feel like you are playing darts on the golf course!”

     This evidence shows that Applicant's “action skill games” include features that combine elements of both golf and darts. When the words GOLF and DARTS are combined into GOLF DARTS and used for Applicant's goods, the words retain their original meanings as referring to features of the goods, which include aspects of both golf and darts. See, e.g., In re Zuma Array Ltd., No. 79288888, 2022 TTAB LEXIS 281, at *8, 22 (composite mark found descriptive where combination of terms did not “convey[ ] any distinctive source identifying impression contrary to the descriptiveness of the individual parts”) (cleaned up).

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     Although the term GOLF DARTS may at first glance seem unusual when considered in the abstract, we find nothing bizarre or incongruous about the combination of the words GOLF and DARTS when it is considered in relation to Applicant's “action skill games.”

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     The term GOLF DARTS directly and immediately conveys information about characteristics of Applicant's goods. This is unlike cases where incongruity was found because there was a difference or disconnect between the terms in the mark and the goods or services. See, e.g., In re Shutts, No. 73245440, 1983 TTAB LEXIS 150, at *1, 6-7 (SNO-RAKE not merely descriptive of “snow removal hand tool having a handle with a snow-removing head at one end, the head being of solid uninterrupted construction without prongs”); In re Tennis in the Round Inc., 1978 TTAB LEXIS 44, at *6-7 (TENNIS IN THE ROUND not merely descriptive of providing tennis facilities in a setting that was not analogous to a “theater-in-the-round”). 

Furthermore, the record included evidence of others using the terms “Golf Darts” or “Dart Golf” with reference to a game that combines features of both golf and darts. 

Because GOLF DARTS directly and immediately conveys information about “action skill games” that include features of the games of golf and darts, the TTAB held that it was merely descriptive of the identified goods.