On October 18, 2023, nearly two years after the Trademark Trial and Appeal Board ruled in Chutter that reckless disregard satisfied the requisite intent for fraud at the USPTO in trademark matters, the Court of Appeals for the Federal Circuit (“CAFC”) in a precedential split decision (Great Concepts, LLC v Chutter, Inc., 2023 USPQ2d XXXX (Fed. Cir. 2023)) reversed the …