UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO.:____________________________

Y.Z.Y., INC., a Florida corporation,

Plaintiff,

vs.

USA FEILONG INT’L TRADING CORP., a 

New York corporation; BAI SONG CHEN; and

DAVID CHEN,

Defendants.

_________________________________________/

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF FOR FEDERAL

TRADEMARK INFRINGEMENT AND COUNTERFEITING, FALSE DESIGNATION

OF ORIGIN/UNFAIR COMPETITION OR MISLEADING ADVERTISING, TRADE

DRESS INFRINGEMENT, COMMON LAW UNFAIR COMPETITION, AND SLOGAN

INFRINGEMENT

DEMAND FOR JURY TRIAL

COMES NOW, Plaintiff, Y.Z.Y., INC. (“Plaintiff” and/or “YZY”), who sues the

Defendants, USA FEILONG INT’L TRADING CORP., a New York corporation; BAI SONG

CHEN; and DAVID CHEN (Individually and respectively “Defendant USA Feilong,” “Defendant

Bai Song Chen,” and “Defendant David Chen,” or collectively “Defendants”), hereby alleges as

follows:

PARTIES

1. Plaintiff is now, and was at the time of the filing of this Complaint and at all intervening

times, a Florida corporation, with its principal place of business located within the Southern

District of Florida.

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2. Plaintiff alleges, upon information and belief, that Defendant USA Feilong is a New York

corporation.

3. Plaintiff alleges, upon information and belief, that Defendant Bai SongChen is an officer and

the Chief Executive Officer of Defendant USA Feilong, and as such, authorizes, directs, 

participates in or controls its business operations, including the wrongful activities alleged

herein, and financially benefits from the said activities.

4. Plaintiff alleges, upon information and belief, that Defendant David Chen is an officer and

the President of Defendant USA Feilong, and as such, authorizes, directs, participates in or

controls its business operations, including the wrongful activities alleged herein, and

financially benefits from the said activities.

5. Plaintiff alleges, upon information and belief, that at all times mentioned herein, the

Defendants, and each of them, are and were the agents, servants or employees of Defendant

USA Feilong and the acts of each Defendant, as alleged herein, are and were performed

within the course and scope of that agency, service or employment.

JURISDICTION / VENUE

6. This Court has subject matter jurisdiction over this matter pursuant to 28 U.S.C. §§ 1331 and

1338(a) and (b), in that the case arises out of claims for trademark infringement and

counterfeiting, false designation of origin and unfair competition, and trade dress

infringement, under the Lanham Act (15 U.S.C. § 1051 et seq.); and this Court has

supplemental jurisdiction pursuant to 28 U.S.C. §§ 1367(a) and 1338(a) and (b) over the

other claims.

7. This Court has personal jurisdiction over all Defendants since Defendants have committed

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the tortious and illegal activities of infringement and unfair competition in this District and

within Broward County, Florida, and/or Defendants have sufficient minimum contacts with

this District such that the exercise of jurisdiction over Defendants by this Court does not

offend traditional notions of fair play and substantial justice. Among other things,

Defendants have purposefully advertised, offered for sale, sold and have purposely directed

or sent to consumers within and to this District products that infringe and counterfeit the

trademark and slogan of Plaintiff, and Defendants have purposefully availed themselves of

the laws and privileges of this jurisdiction by entering into contracts for the sale of goods

with parties residing in the District. Additionally, Defendants have purposefully offered for

sale and sold counterfeit and/or knock-off products (described more fully below) knowing

or having reason to know that consumers throughout the United States, including within this

District, would purchase such counterfeit and/or knock-off products from Defendants,

believing that they were authentic goods manufactured, distributed, authorized by, or

associated with, or connected to, Plaintiff.

8. Additionally, this Court has supplemental jurisdiction over Defendants because, upon

information and belief, Defendants conduct business in Florida and in this District, or have

otherwise availed themselves of the privileges and protections of the laws of the state of

Florida, such that this Court’s assertion of jurisdiction over Defendants does not offend

traditional notions of fair play and due process. Further, the supplemental claims set forth

herein arise from the same case or controversy and same operative facts as the action over

which this Court has original jurisdiction.

9. Venue is proper, inter alia, pursuant to 28 U.S.C. Section 1391(b) because, upon information

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and belief, a substantial part of the events or omissions giving rise to the claims occurred in

this District and within Broward County, Florida, and have caused damage to Plaintiff in this

District. The infringing and counterfeit products were advertised, sold and purchased in

Florida and Defendants purposefully shipped, or authorized the shipment of, infringing and

counterfeit products in Florida. Defendants’ actions within this District directly interfered

with and damaged Plaintiff’s commercial efforts and endeavors and harmed Plaintiff’s

goodwillwithin thisDistrict. Additionally, Plaintiff conducts substantial business within this

District.

GENERAL ALLEGATIONS

10. Since at least as early as 1986, Plaintiff has been engaged in the business manufacturing,

distributing and selling, among other goods, fine fragrances for personal use.

11. Plaintiff has, since its early years, created, adopted and used in commerce proprietary brands

and slogans for its goods, including its fragrance products. To date, Plaintiff has created

more than one hundred seventy five (175) proprietarybrands and slogans, and has registered

more than seventy five (75) of them with the United States Patent and Trademark Office.

12. One of Plaintiff’s United States federally registered trademarks, which was first used in

commerce of the United States at least as early as July 25, 2007, and is pertinent to this

action includes BLACK POINT, U.S. Reg. No. 3,423,956 (“Mark”). The registration for the

Mark is attached as Exhibit A.

13. Plaintiff sells three different versions of BLACK POINT, specifically, BLACK POINT,

BLACK POINT (Black Edition), and BLACK POINT (Sport).

14. Genuine sample packaging for the Mark in all versions is attached as Composite Exhibit B.

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15. The registration for the Mark covers a variety of fragrances, including, but not limited to, eau

de perfume. The Mark has been used continuously in commerce of the United States since

its inception. Additionally, the Mark’s registration is valid, subsisting, and incontestable

under 15 U.S.C. §1065, and renewed.

16. Plaintiff has extensively promoted and marketed, and otherwise used its Mark in commerce

of the United States, including within this District.

17. Products bearing Plaintiff’s Mark have come to be known by the consuming public

throughout the United States as a fragrance of the highest quality. Accordingly, the Mark

and the good will associated with it are of extraordinary value to Plaintiff.

18. Consumers of Plaintiff’s products are familiar with the Mark, and would likely presume that

products bearing it as trademark originate from, or are otherwise associated with, or are

authorized by, Plaintiff.

19. Beginning in June, 2022, Plaintiff discovered counterfeit and competing knockoff products

(“Infringing Goods”) being sold as genuine Plaintiff’s products under the Mark by the

Defendants. Sample packaging showing counterfeit use of the Infringing Goods by the

Defendants under their versions BLACK POINT and BLACK POINT (Gold) is attached as

Composite Exhibit C.

20. Plaintiff acquired samples of the Defendants’ counterfeit Infringing Goods shown in

Composite Exhibit C.

21. The packaging of Defendants’ counterfeit Infringing Goods shown in Composite Exhibit C

includes wording that states “Essential Oil manufactured in FRANCE.”

22. The Infringing Goods utilize a trade dress packaging that is nearly identical to, or is

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confusingly similar with, the trade dress packaging sold by Plaintiff under its Mark.

23. The Defendants’ packaging shows use of BLACK POINT in the same or confusingly similar

manner as Plaintiff’s packaging. For example, the Defendants employ a font that is the same

as or is confusingly similar to the words BLACK and POINT as the Plaintiff’s font. The

layout of the front of Defendants’ packaging is the same as or is confusingly similar to that

of Plaintiff’s packaging in that the word BLACK is above and offset to the left relative to the

word POINT; regarding Plaintiff’s BLACK POINT version of its genuine goods, the

Defendants copied the color of the word BLACK which is in silver, and of the word POINT,

which is in white; and, additionally, the Defendants copied the words “Pour Homme” as

shown in Plaintiff’s genuine packaging identicallyin that the Defendants’ packaging uses the

same words and have placed them in the same location relative to BLACK POINT as shown

in Plaintiff’s packaging. Moreover, Defendants copied the color of the packaging, generally

black, and utilize a confusingly similar shape as Plaintiff’s packaging, namely, a rectangular

cuboid.

24. The Infringing Goods are counterfeit in that they bear the identical mark as Plaintiff’s

federally registered Mark, namely, BLACK POINT.

25. On August 5, 2022, Plaintiff’s counsel sent Defendant USA Feilong and the individual

Defendants a cease and desist letter advising them of their trademark infringement and

counterfeiting, false designation of origin, trade dress infringement and slogan infringement. 

In the letter, Plaintiff informed Defendants to cease and desist from advertising and selling

the Infringing Goods, and not to spoliate them or otherwise dispossess themselves of the

Infringing Goods.

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26. Defendant USA Feilong responded to the cease and desist letter through counsel, but took

no action to prevent future sales of then ongoing counterfeit and Infringing Goods that were

being offered for sale to the consuming public. As a result, Plaintiff took unilateral action

to cause continued sales on Amazon.com, Walmart.com and Ebay.com, retail on line stores

where it was aware of the wrongful counterfeiting sales, to cease and desist.

27. Upon information and belief, at the time of this filing, the Defendants continue to advertise

and offer for sale the Infringing Goods to the consuming public by themselves or through

their resellers.

FIRST CAUSE OF ACTION

(Trademark Infringement and Counterfeiting, 15 U.S.C. §1114)

28. Plaintiff hereby incorporates by reference each of the other allegations set forth above in this

Complaint as though fully set forth in this cause of action.

29. Defendants’ actions as described herein create a likelihood of confusion among the

consuming public and constitute direct and/or contributory trademark infringement in

violation of 15 U.S.C. §1114(1)(a).

30. As a proximate result of Defendants’ trademark infringement, Plaintiff has been damaged

in an amount to be proven at trial.

31. Plaintiff alleges upon information and belief that, as a proximate result of Defendants’

trademark infringement, Defendants have unlawfully profited in an amount to be proven at

trial.

32. At allrelevant times, Defendants acted intentionallyand/or willfullyin usingPlaintiff’s Mark

in its advertising and sales, knowing Plaintiff’s Mark belongs to Plaintiff, and that

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Defendants were not authorized to use Plaintiff’s Mark in the advertising and sales of the

Infringing Goods. Plaintiff is therefore entitled to a recovery of treble damages pursuant to

15 U.S.C. §1117(a).

33. Defendants’ knowing, intentional and/or willful actions make this an exceptional case,

entitling Plaintiff to an award of reasonable attorney fees pursuant to 15 U.S.C. §1117(a).

34. Defendants’ actions also constitute the use byDefendants of one or more “counterfeit marks”

as defined in 15 U.S.C. §1116(d)(1)(B). Plaintiff therefore reserves the right to elect, at any

time before final judgment is entered in this case, an award of statutory damages up to and

including $2,000,000 per counterfeit mark per type of goods pursuant to 15 U.S.C.

§1117(c)(1) and/or (2).

35. The acts of direct and/or contributorytrademark infringement committed byDefendants have

caused, and will continue to cause, Plaintiff irreparable harm unless they are enjoined by this

Court.

SECOND CAUSE OF ACTION

(False Designation of Origin, False or Misleading Advertising, 15 U.S.C. §1125(a)(1))

36. Plaintiff herebyincorporates byreference each of the other allegations set forth in Paragraphs

1-27 of this Complaint as though fully set forth in this cause of action.

37. Defendants’ actions as described herein constitute direct and/or contributory violation of 15

U.S.C. §1125(a)(1)(A), as such actions are likely to: (a) cause confusion; (b) cause mistake;

or (c) deceive as to the affiliation, connection, or association of Defendants with Plaintiff

and/or to the origin, sponsorship, and/or approval of such goods by Plaintiff.

38. As a proximate result of Defendants’ false designation of origin, or false or misleading

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advertising, Plaintiff has been damaged in an amount to be proven at trial.

39. Plaintiff alleges upon information and belief that, as a proximate result of Defendants’ false

designation of origin, or false or misleading advertising, Defendants have unlawfullyprofited

in an amount to be proven at trial.

40. Upon information and belief, and at all relevant times, Defendants acted intentionally and/or

willfully in falsely designating the origin of the Infringing Goods, or falsely or misleadingly

advertising and selling the Infringing Goods under Plaintiff’s Mark by stating they were

manufactured of “Essential Oil manufactured in France,” even though the Defendants knew

the Infringing Goods were made in China. Plaintiff is therefore entitled to a recovery of

treble damages pursuant to 15 U.S.C. §1117(a).

41. Defendants’ acts of violating, directly and/or contributorily, Section 1125 have caused, and

will continue to cause, Plaintiff irreparable harm unless they are enjoined by this Court.

THIRD CAUSE OF ACTION

(Trade Dress Infringement, 15 U.S.C. §1125(a)(3))

42. Plaintiff herebyincorporates byreference each of the other allegations set forth in Paragraphs

1-27 of this Complaint as though fully set forth in this cause of action.

43. Prior to Defendants’ conduct that forms the basis of this Complaint, consumers had come to

associate the distinctive trade dress of Plaintiff’s packaging sold under its Mark for its

fragrance goods.

44. Through its promotional efforts, business conduct, and continuous use of the Mark along

with its packaging, Plaintiff has developed a distinctive, non-functional trade dress which has

become an asset of substantial value as a symbol of Plaintiff, its high quality goods and

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services, and its goodwill.

45. Plaintiff has established valid and enforceable rights in the trade dress of the Plaintiff’s Mark

and packaging as alleged above.

46. Notwithstanding Plaintiff’s preexisting valid and enforceable rights in its trade dress,

Defendants, without permission or approval, infringed Plaintiff’s trade dress by copying

substantial, non-functional elements as awhole of Plaintiff’s packaging, including Plaintiff’s

Mark, to offer, advertise and sell the Infringing Goods.

47. Defendants offer their trade dress Infringing Goods to the same or similar types of consumers

as does the Plaintiff. 

48. The Defendants are direct competitors of Plaintiff.

49. The trade dress of the Defendants’ Infringing Goods are likely to cause consumer confusion

and mistake, and to deceive consumers as to the source, origin, or affiliation of Plaintiff’s

goods sold under its trade dress and the Mark.

50. Plaintiff has a discernible interest in the trade dress of its goods under the Mark, and Plaintiff

has been, and continues to be, injured by Defendants’ unauthorized and unlawful use of

Plaintiff’s trade dress.

51. Defendants’ unauthorized use of the trade dress of Plaintiff in connection with related and

competingInfringingGoods is causing confusion among purchasers and potential purchasers

of Plaintiff’s goods sold under the Mark.

52. The acts of Defendants described above constitute an infringement and misappropriation of

Plaintiff’s rights in and to the use of the trade dress of Plaintiff”s goods under its Mark, with

consequent damages to Plaintiff and the business and goodwill associated with and

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symbolized by Plaintiff’s trade dress.

53. Defendants’ acts of trade dress infringement have caused and are causing great and

irreparable harm to Plaintiff, Plaintiff’s goodwill, and Plaintiff’s exclusive rights in and to

the trade dress of Plaintiff’s packaging under its Mark, in an amount which cannot be

adequatelydetermined at this time and, unlessrestrained, will cause further irreparable injury

and damage, leaving Plaintiff with no adequate remedy at law.

54. Plaintiff alleges upon information and belief that Defendants’ acts of trade dress

infringement have been and are being committed with actual knowledge of Plaintiff’s prior

existing rights in the trade dress of Plaintiff’s goods under its Mark, and are willful and in

gross disregard to Plaintiff’s rights.

55. Plaintiff is entitled to recover any damages proved to have been caused by reason of

Defendants’ aforesaid acts of trade dress infringement, and to recover enhanced damages

based upon the willful, intentional, and/or grossly negligent activities of Defendants.

56. Defendants’ acts of violating, directly and/or contributorily, Plaintiff’s trade dress have

caused, and will continue to cause, Plaintiff irreparable harm unless they are enjoined by this

Court.

FOURTH CAUSE OF ACTION

(Florida Common Law Unfair Competition)

57. Plaintiff herebyincorporates by reference each of the other allegations set forth in Paragraphs

1-27 of this Complaint as though fully set forth in this cause of action.

58. Due to Plaintiff’s long and continuous use of its protected Mark and trade dress, Plaintiff 

has established common law trademark rights in the Mark and in and to trade dress for the

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Mark’s packaging.

59. Plaintiff and Defendants are competitors in the field of personal care products, specifically

fragrances for personal use, as are sold by Plaintiff under its trademarks and the Mark.

60. Defendants have commenced, through advertising, marketing, offering for sale, sale, and the

use of an identical or confusingly similar Mark and trade dress to indicate or identify similar

services rendered or similar goods advertised and marketed by them in competition with

Plaintiff in the same trade areas in which the Plaintiff has already established its Mark and

trade dress.

61. Defendants’ actions as described herein have misappropriated the advertisingidea of Plaintiff

to advertise, market, offer to sell and sell its fragrance goods under its Mark and trade dress.

62. Defendants’ actions as described herein are in violation of Florida’s common law of unfair

competition in that they were fraudulent, created a likelihood of confusion among the

consuming public, made in bad faith, and intended to deceive, or had the capacity to deceive,

consumers thus having a material effect on consumer purchasing decisions to the detriment

of Plaintiff.

63. As a proximate result of Defendants’ unfair competition, Plaintiff has been damaged in an

amount to be proven at trial.

64. Plaintiff alleges upon information and belief that, as a proximate result of Defendants’ unfair

competition, Defendants have unlawfully profited in an amount to be proven at trial.

65. Defendants’ willful acts of unfair competition, misrepresentation, fraud and deceit have

unjustly enriched Defendants in violation of Plaintiff’s rights.

66. Defendants’ acts of unfair competition have caused, and will continue to cause, Plaintiff

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irreparable harm unless they are enjoined by this Court.

FIFTH CAUSE OF ACTION

(Slogan Infringement)

67. Plaintiff herebyincorporates byreference each of the other allegations set forth in Paragraphs

1-9 of this Complaint as though fully set forth in this cause of action.

68. Plaintiff owns and uses, relative to this Complaint, one slogan in the advertising of its

fragrance products in commerce of the United States, namely, BLACK POINT.

69. Plaintiff’s slogan comprises a distinctive term or phrase.

70. Plaintiff’s slogan further comprises a catchword or catch phrase that is intended to promote

and advertise Plaintiff’s fragrance products.

71. Defendants, without authorization from Plaintiff, infringed Plaintiff’s slogan by advertising

the Defendants’ goods or causing others to advertise those goods bearing the infringing

slogan in order to attract customers to purchase those goods from Defendants.

72. Defendants’ actions as described herein create a likelihood of confusion among the

consuming public and constitute slogan infringement.

73. As a proximate result of Defendants’ slogan infringement, Plaintiff has been damaged in an

amount to be proven at trial.

74. Plaintiff alleges upon information and belief that, as a proximate result of Defendants’ slogan

infringement, Defendants have unlawfully profited in an amount to be proven at trial.

75. At all relevant times, Defendants acted intentionally and/or willfully in using Plaintiff’s

slogan in their advertising and sales, knowing Plaintiff’s slogan belongs to Plaintiff, and that

Defendants were not authorized to use Plaintiff’s slogan in the advertising and sales of their

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goods. 

76. The acts of direct and/or contributory slogan infringement committed by Defendants have

caused, and will continue to cause, Plaintiff irreparable harm unless they are enjoined by this

Court. 

REQUEST FOR RELIEF

WHEREFORE, Plaintiff Y.Z.Y., INC., hereby respectfully requests the following

relief against Defendants, inclusive, and each of them, jointly and severally:

1. For an award of Defendants’ profits and Plaintiff’s damages in an amount to be proven at

trial for trademark infringement under 15 U.S.C. §1114(a).

2. For an award of Defendants’ profits and Plaintiff’s damages in an amount to be proven at

trial for false designation of origin and unfair competition under 15 U.S.C. §1125(a).

3. For an award of Defendants’ profits and Plaintiff’s damages in an amount to be proven at

trial for trade dress infringement under 15 U.S.C. §1125(a)(3).

4. In the alternative to actual damages and Defendants’ profits for the infringement of

Plaintiff’s trademarks pursuant to the Lanham Act, for statutory damages pursuant to 15

U.S.C. §1117(c), for counterfeit marks, which election Plaintiff will make prior to final

judgment, and will seek up to $2,000,000 per mark per product as provided by statute.

5. For an award of Defendants’ profits and Plaintiff’s damages for claims brought pursuant to

this Court’s supplemental jurisdiction.

6. Preliminarily and permanently enjoining Defendants and their agents, employees, officers,

directors, owners, representatives, successor companies, affiliates, subsidiaries and related

companies, and all persons acting in concern or participation with it, and each of them, from: 

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A. The import, export, making, manufacture, reproduction, assembly, use,

acquisition, purchase, offer, sale, transfer, brokerage, consignment,

distribution, storage, shipment, licensing, development, display, delivery,

marketing, advertising or promotion of the Infringing Goods identified in the

Complaint and any other product which infringes any of Plaintiff’s

intellectual property, Plaintiff’s trademarks, trade dresses, or slogans,

including, but not limited to, Plaintiff’s Mark or slogan at issue in this action.

B. The unauthorized use, in any manner whatsoever, of any of Plaintiff’s

intellectual property, Plaintiff’s trademarks, trade dresses, or slogans,

including, but not limited to, the Plaintiff’s Mark and slogan at issue in this

action, any variants, colorable imitations, translations, and/or simulations

thereof and/or any items that are confusingly similar thereto, including

specifically:

i. On or in conjunction with any product or service; and

ii. On or in conjunction with any advertising, promotional materials,

labels, hang tags, packaging or containers.

C. The use of any Plaintiff’s intellectual property, Plaintiff’s trademarks, trade

dresses or slogans that falsely represents, or is likely to confuse, mislead, or

deceive purchasers, customers, or members of the public to believe that

unauthorized product imported, exported, manufactured, reproduced,

distributed, assembles, acquired, purchased, offered, sold, transferred,

brokered, consigned, distributed, stored, shipped, marketed, advertised and/or

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promoted by Defendants originate from Plaintiff, or that said products or

goods have been sponsored, approved, licensed by, or associated with

Plaintiff or is in some way, connected or affiliated with Plaintiff.

D. Engaging in any conduct that falsely represents that, or is likely to confuse,

mislead, or deceive purchasers, customers, or members of the public to

believe that Defendants are connected with, or are in some way sponsored by

or affiliated with Plaintiff, purchases product from or otherwise have a

business relationship with Plaintiff.

E. Affixing, applying, annexing, or using in connection with the manufacture,

distribution, advertising, sale, and/or offering for sale or other use of any

goods, a false description or representation, including words or symbols,

tending to falsely describe or represent such goods as being those of Plaintiff.

F. Hiding, disposing of, destroying, spoliating, moving, relocating or

transferring any and all products, advertising, promotional materials, labels,

hang tags, packaging or containers bearing Plaintiff’s Mark, trade dress or

slogan or which otherwise refer or relate to Plaintiff or any of Plaintiff’s

Mark, trade dress or slogan.

G. Disposing of, destroying, spoliating, moving, relocating or transferring any

documents or things, including electronic records, pertaining to the purchase,

procurement, development, making, manufacture, use, display,

advertisement, marketing, licensing, sale, offer for sale, distribution,

shipping, or delivery of any products or services bearing any of Plaintiff’s

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Mark, trade dress or slogan or which otherwise refer or relate to Plaintiff or

any of Plaintiff’s Mark, trade dress or slogan.

7. Pursuant to 15 U.S.C. §1116(a), directing Defendants to file with the Court and serve on

Plaintiff within thirty (30) days after issuance of an injunction, a report in writing and under

oath setting forth in detail the manner and form in which Defendants have complied with the

injunction.

8. For an order from the Court requiring Defendants to provide complete accountings and for

equitable relief, including that Defendants disgorge and return or pay their ill-gotten gains

obtained from the illegal transactions entered into and/or pay restitution, including the

amounts of monies that should have been paid if Defendants complied with their legal

obligations, or as equity requires.

9. For an order from the Court that an asset freeze or constructive trust be imposed over all

monies and profits in Defendants’ possession which rightfully belong to Plaintiff.

10. Pursuant to 15 U.S.C. §1118, requiring that Defendants and all others acting under

Defendants’ authority at their cost, be required to deliver up to Plaintiff all products,

accessories, labels, signs, prints, packages, wrappers, receptacles, advertisements, and other

material in their possession, custodyor control bearingPlaintiff’s Mark, trade dress or slogan

alone, or in combination with any other word, words, or design(s).

11. For treble damages or profits suffered by Plaintiff as a result of the willful and intentional

infringements engaged in by Defendants, under 15 U.S.C. §l1l7(a) and (b).

12. For an award of Plaintiff’s reasonable attorneys’ fees.

13. For all costs of suit.

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14. For such other and further relief as the Court may deem just and equitable.

JURY DEMAND

Plaintiff hereby demands a trial by jury on all issues so triable.

Date: October 4, 2022 Respectfully submitted,

/Richard S. Ross, Esq./

RICHARD S. ROSS, ESQ.

525 N.E. 14 Avenue

Fort Lauderdale, Florida 33301

Tel 954/252-9110

Fax 954/252-9192

E mail: prodp@ix.netcom.com

Florida Bar No. 436630

Attorney for Plaintiff

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