IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE

REGISTERED AGENTS, LTD.,Plaintiff,v.REGISTERED AGENT, INC.Defendant.))))))))))))C.A. No.__________________

JURY TRIAL DEMANDEDCOMPLAINT

Plaintiff Registered Agents, Ltd., through their attorneys at Connolly Bove Lodge & HutzLLP, for their complaint against defendant Registered Agent, Inc. allege as follows:

NATURE OF THE ACTION

This is a civil action for: (i) trademark infringement arising under Section 32(1)of the Lanham Act of 1946, as amended, 15 U.S.C. § 1051

et seq

.; (ii) use of false designationsof origin in commerce and false advertisement, arising under Section 43(a) of the Lanham Act of 1946, as amended, 15 U.S.C. § 1125(a); (iii) unfair competition under Section 43(a) of theLanham Act, as amended, 15 U.S.C. § 1125(a); (iv) statutory unfair competition under theDelaware Uniform Deceptive Trade Practices Act, 6

Del. C

. § 2531

et seq

.; (v) common lawunfair competition under the common law of the State of Delaware; and (vi) unjust enrichmentunder the common law of the State of Delaware.

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JURISDICTION AND VENUE

This Court has original jurisdiction over the claims arising under the Lanham Actpursuant to 15 U.S.C. § 1121 and 28 U.S.C. §§ 1331 and 1338. This Court has supplemental jurisdiction over the claims arising under state statutory and common law pursuant to 28 U.S.C.§ 1367.3.

This Court has personal jurisdiction over Defendant because, on information andbelief, Defendant transacts business in Delaware, directs advertising into Delaware, enters intocontracts to supply services and/or products in Delaware, with Delaware entities and citizens,and has purposefully availed itself of the privilege of conducting activities in Delaware.4.

Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b) and (c).

PARTIES

Registered Agents, Ltd. (RAL) is a “small business incorporation solution expert”offering corporate services, including, but not limited to, corporate headquarters services andother new entity services, and business services such as filing and retrieval of incorporation andcorporate documents with government agencies that has been operating since 1979 and isheadquartered at 1220 North Market Street, Suite 804, Wilmington, Delaware 19801.6.

Upon information and belief, Registered Agent, Inc. (RAI) is a corporation of Nevada headquartered at 769 Basque Way, Suite 300, Carson City, Nevada 89706. Uponinformation and belief, RAI provides corporate services, including, but not limited to, corporateheadquarters services and other new entity services.7.

Upon information and belief, RAI is the owner of and is responsible for thewebsite at www.registeredagentinc.com. Through this website, at least, RAI offers servicesdirectly to consumers in all 50 states, including Delaware. In connection with its business, upon

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3information and belief, RAI transacts business, and enters into contracts to supply servicesand/or products in Delaware, with Delaware companies and citizens, and advertises its servicesand solicits business in all 50 states, including Delaware.8.

Upon information and belief, RAI has purposefully availed itself of the privilegeof conducting activities within Delaware. RAI has, on at least two occasions, sent letterssoliciting business from at least one Delaware Corporation at a Delaware address, attached atExhibit A. Additionally, at least one former RAL client has registered with RAI, uponinformation and belief, in response to a RAI solicitation.

FACTSRAL and its Long History of Service In Connection With theREGISTERED AGENTS, LTD. Mark

RAL was founded in 1979 and for at least the past 32 years has continuously usedthe REGISTERED AGENTS, LTD. name and trademark in connection with its business services(the “REGISTERED AGENTS, LTD. Mark”).10.

RAL has devoted significant advertising resources and creative energies towardsthe REGISTERED AGENTS, LTD. Mark. The REGISTERED AGENTS, LTD. Mark is wellknown and is widely recognized by the consuming public as a designation of source, andspecifically as a designation of source of RAL’s business services.11.

RAL offers corporate filing services including, but not limited to, new entityformations, foreign qualifications, amendments, mergers, and dissolutions. RAL offersadditional services including, but not limited to, document retrieval services, internationalauthentications, Uniform Commercial Code (UCC) searches and filings, and registered agentservice in all 50 States plus the District of Columbia. RAL assists its clients in obtainingcorporate kits, forms, disks, Employer Identification Numbers (EIN) and business licenses. RAL