On September 30, 2021, in a precedential decision, the Trademark Trial and Appeal Board (“TTAB”) clarified that “reckless disregard satisfies the requisite intent for fraud on the USPTO in trademark matters.” Chutter, Inc. v. Great Concepts, LLC, 2021 USPQ2d 1001 (TTAB 2021). This question was left open by the Federal Circuit in the seminal case of In re Bose. Since Bose, the number of …