This item was on the 06-2013 LoAR

15: Marek Casimir of Krakow - New Device
OSCAR finds the name registered exactly as it appears in May of 2012, via the East
Checky sable and argent, a chief enarched Or and overall an eagle displayed gules
The submitter's original device submission was returned on the May 2012 LoAR with the following analysis:
Marek Casimir of Krakow. Device. Checky sable and argent, a chief enarched argent, overall an eagle gules.
The submitter provided two independent examples of the motif of the primary charge overlying a chief. However, one of the examples is the horns only of a bull, and may be merely artistic license; even given the benefit of the doubt, this is only two examples of the exact practice. A third example was provided by Batonvert in commentary. However, all of the examples given show a plain chief that has good contrast with the field. This submission, on the other hand, has a chief with poor contrast, as it shares a tincture with the field. Also, the line of the chief is enarched; while we grant no difference for a plain chief versus a chief enarched, the combination of low-contrast combined with the enarched line renders the chief unidentifiable when overlain by the eagle. Resubmitting with a chief Or, or a different field, would likely resolve the issue.
The submitter has followed the suggestion made on the LoAR and resubmitted with a chief Or.