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Martin
B.
Schwimmer (MS 7011)Peter
S.
Sloane (PS 7204)Cameron
S.
Reuber (CS 7001)LEASON ELLIS LLPOne BarkerA venue, Fifth FloorWhitePlains,New York
10601
Phone:(914) 288-0022Fax: (914) 288-0023
Counsel
for
PlaintifJ
UNITED STATES DISTRICT COURT
FOR
THE
SOUTHERN DISTRICT OF NEW YORK
LEASON ELLIS LLP,Plaintiff,
v.
USA TRADEMARK ENTERPRISES, INC.TIMEA CSIKOS and ANDRAS NEMETH,Defendants.
COMPLAINT
Civil Action No.
JUDGE
RAMOS
Plaintiff Leason Ellis LLP ("Leason Ellis" or
"P
laintiff'),a New Yorklimited liability partnership,acting
pro
se,
alleges foritsComplaint againstDefendantsUSA Trademark Enterprises,Inc.,Timea Csikos and Andras Nemeth (collectively"USATrademark" or "Defendants")asfollows:
{OOOOO
\
608738-000
\
OOI82293.1
}
-1-
 
 
{00000\608738-000\00182293.1}
-2-
THE PARTIES
1.
 
Plaintiff Leason Ellis is a New York limited liability partnership with its addressat One Barker Avenue, Fifth Floor, White Plains, New York 10601.2.
 
Upon information and belief, Defendant USA Trademark Enterprises, Inc. (“USATrademark Enterprises”) is a Florida corporation with its address at 677 N. Washington Blvd.#57, Sarasota, Florida 34236.3.
 
Upon information and belief, Defendant Timea Csikos (“Csikos”) is an officer orprincipal of USA Trademark Enterprises.4.
 
Upon information and belief, Csikos has an address at 677 North WashingtonBlvd., Suite #57, Sarasota, Florida 34236.5.
 
Upon information and belief, Defendant Andras Nemeth (“Nemeth”) is an officeror principal of USA Trademark Enterprises.6.
 
Upon information and belief, Nemeth has an address at 677 North WashingtonBlvd., Suite #57, Sarasota, Florida 34236.7.
 
Upon information and belief, Csikos and Nemeth are the primary actors in thetortious acts complained of herein, including the activities of USA Trademark Enterprises.8.
 
Upon information and belief, USA Trademark Enterprises is operating as theagent of Csikos and Nemeth such that all corporate transactions of USA Trademark Enterprisesare subject to the complete control and direction of Csikos and Nemeth.9.
 
Upon information and belief, Csikos and Nemeth are the driving force behindUSA Trademark Enterprises’ solicitations in this District, including those to Plaintiff and itsclients, and that, but for Csikos and Nemeth, none of the tortious acts complained of hereinwould have been committed.
 
 
{00000\608738-000\00182293.1}
-3-
JURISDICTION
10.
 
This Court has personal jurisdiction over Defendants by reason of theirtransaction of business in the State of New York and in this District and the commission of tortious acts within the State of New York and in this District pursuant to New York’s C.P.L.R.§§301 and 302.11.
 
The subject matter jurisdiction of this Court over Counts I and II rests uponcauses of action arising under the Trademark Act of 1946 (as amended), 15 U.S.C. §§1051 etseq. Therefore, this Court has original jurisdiction over these Counts pursuant to 15 U.S.C.§1121, and 28 U.S.C § 1338(a).12.
 
Counts III through VI are joined as substantial and related claims and,accordingly, subject matter jurisdiction for these Counts is conferred upon this Court pursuant to28 U.S.C. §1338(b) and the doctrine of pendent jurisdiction.13.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §1391.
FACTS COMMON TO ALL COUNTSPlaintiff and its Business
14.
 
Plaintiff is a well-regarded law firm practicing primarily in the area of intellectualproperty law including trademark law.15.
 
Clients of Plaintiff include large, midsize, and small companies and organizationsas well as partnerships and individuals.16.
 
In providing trademark-related services for its clients, among other things,Plaintiff assists its clients in obtaining trademark registrations with the United States Patent andTrademark Office (the “USPTO”).
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