IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIAJOHN N. XEREAS, )2520 13th Street, NW, Apt. 7, )Washington, DC 20009 ))Plaintiff, ) CIVIL ACTION NO. 1:12-cv-456-RWR)v. )) JURY TRIAL DEMANDEDMARJORIE A. HEISS, )GEOFFREY O.S. DAWSON, )RIOT ACT DC, LLC, and )SQUIID, INC., ))Defendants. )
As his Amended Complaint in this action, Plaintiff John N. Xereas (“Plaintiff” or“Xereas”), by his undersigned attorneys, alleges as follows, upon actual knowledge withrespect to his own acts and upon information and belief with respect to all other matters.
NATURE OF THE CASE
1. This is a civil action to remedy acts of,
infringement of anunregistered trademark pursuant to Section 43(a) of the Lanham Act, 15 U.S.C. § 1051
; federal unfair competition; misappropriation; conversion; breach of contract andof the covenant of good faith and fair dealing; fraudulent inducement; conspiracy todefraud; tortious interference with contractual relations; unjust enrichment undercommon law; cybersquatting; defamation; and libel.2. Plaintiff brings this action because Defendants, individually and inassociation with each other and/or third parties, have willfully infringed the RIOT ACTtrademarks owned by Plaintiff; have engaged in unfair business practices; have
Case 1:12-cv-00456-RWR Document 3 Filed 03/27/12 Page 1 of 36