Which action would not typically require a filing fee?

The action that does not typically require a filing fee is filing a Notice of Opposition. A Notice of Opposition is a formal objection to the registration of a trademark that has been published in the Trademark Official Gazette. The process is designed to allow parties who believe they would be harmed by the registration of a mark to voice their concerns. The USPTO allows the filing of a Notice of Opposition without requiring an additional fee because it is part of the process that protects the rights of third parties against potential trademark conflicts.

In contrast, filing a new trademark application and requesting an update to TSDR after publication both involve actions that require submission fees. The initial trademark application requires a fee because it involves examination and potential publication, while updates to the Trademark Status and Document Retrieval (TSDR) typically involve administrative changes that also come with associated costs.

A Voluntary Amendment Not in Response to Office Action may also require a fee, depending on the nature of the amendment being sought. Therefore, the Notice of Opposition stands out as the only action among the options that does not incur a filing fee.