UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

MICHAEL REGER; and

MLR HOLDINGS 2020, LLC, 

a Florida limited liability company,

 Plaintiffs, 

v.

ALL THINGS GEL, LLC, a Florida

limited liability company, GELTECH LABS

CORPORATION, a Florida Corporation, ATG 

LABORATORIES CORP, a Florida Corporation, 

DYNO TECH LABORATORIES CORP, a 

Florida Corporation, DYNOMAT INC., a Florida 

Corporation, WHALE TANK VENTURES INC, 

a Florida Corporation, LOGAN’S WIPE MAGIC 

INC, FIREICE GEL, LLC, a Florida limited 

liability company, and Individually, PETER J. 

CORDANI, LOGAN CORDANI and MARK 

DANIELS. 

 Defendants. 

Case No. 

JURY TRIAL DEMANDED 

 

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF

The Plaintiffs, Michael Reger (“Mr. Reger”) and MLR Holdings 2020, LLC (“MLR”), 

(collectively “Plaintiffs”), by and through their undersigned counsel, hereby bring this Complaint 

against the Defendants, All Things Gel, LLC (“ATG”), ATG Laboratories Corp (“ATG Labs”)

GelTech Labs Corporation (“GTL”), Dyno Tech Laboratories Corp (“Dyno Labs”), Dynomat Inc. 

(“Dynomat Inc.”),Whale Tank Ventures Inc (“Whale”), Logan’s Wipe Magic Inc (“LWM”) Peter 

J. Cordani (“Mr. Cordani”), Logan Cordani (“L. Cordani”), and Mark Daniels (“Mr. Daniels”), 

(collectively “Defendants”), and allege as follows: 

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NATURE OF THE ACTION

Defendant Peter Cordani was the Chief Technology Officer (“CTO”) and a board member 

of GelTech Solutions, Inc (“Geltech”) since the company’s inception in 2007, and he served as 

Geltech’s Chief Executive Officer from 2014 until 2018. Geltech, a publicly traded company, was

a leading fire suppression technology provider that invested in rigorous research, testing and 

certifications, including to meet criteria established by the U.S. Forest Service, Underwriters 

Laboratories, and the Food and Drug Administration and other highly regulated local and state 

government agencies.

To protect itself and its valuable product lines, Geltech entered into an Employment 

Agreement with Mr. Cordani. The Employment Agreement specifically provided that Mr. Cordani 

would assign all inventions he created to Geltech; further, and more importantly, Mr. Cordani

agreed to keep all of the proprietary formulations, customer lists, and technical information 

confidential, and to refrain from soliciting Geltech’s customers or competing with Geltech for one 

year after termination of his employment. 

As CTO and the lead inventor, Mr. Cordani knew how the Geltech products were made, 

which companies supplied raw materials, how the products were marketed, what certifications 

were required, and who the customers were. He knew what molecular size was required to create

effective products for the various product lines. He knew everything.

In January 2020, Geltech entered into a Settlement Agreement with Michael Reger, its 

secured lender and former Chairman of the Board and Chief Executive Officer, pursuant to which 

Geltech assigned all of its assets, including its intellectual property, to Mr. Reger in consideration 

for a release of the debt it owed Mr. Reger. 

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Seeing that Geltech would be reborn as a new company under Mr. Reger, Mr. Cordani

made plans to leave. With the help of other soon-to-be-ex-Geltech employees, Mr. Cordani stashed 

away Geltech’s products in various locations outside of Geltech’s facilities and created copies of 

Geltech’s confidential information, including Geltech’s customer and vendor lists. Mr. Cordani

then exploited the property he stole from Geltech, claiming it was his own, and capitalized on his 

well-known association with Geltech to raise significant capital, including more than $250,000 

from one unexpecting investor alone.

With his cache of stolen Geltech property and investment money, Mr. Cordani left Geltech

in 2020 to create a replica business, All Things Gel, LLC (“ATG”). He used the same suppliers, 

the same product offerings, the same advertisements, and the same customer lists. He leased space 

in Geltech’s former warehouse and hung up Geltech’s product posters in the conference room, 

which of course depicted Geltech’s products and trademarks. Potential investors and customers 

would visit the ATG offices, in the exact spot where Geltech had been located, with Geltech posters 

on the walls, and be presented with product offerings in nearly identical packaging, with 

extraordinarily similar names, as to those offered by Geltech. The confusion was deliberate.

Not only did Mr. Cordani create an imposter company, he created imposter certifications, 

advertising that his products have the same certifications as the Geltech products; of course, they

do not – nor could they, given that these certifications require years to obtain. Perhaps most 

shockingly, on at least one occasion, he told a customer that his new company was Geltech, just 

under a new name. 

Mr. Cordani’s dishonest and anticompetitive actions break every intellectual property rule 

in the book. He has violated his employment agreement, stolen numerous trade secrets, made false 

claims about his products that are material to purchasing decisions, used infringing trademarks, 

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and displayed copyright-protected posters. Plaintiffs file this action seeking an injunction and 

damages for Mr. Cordani’s theft of trade secrets, trademark infringement, unfair competition, 

copyright infringement, breach of employment agreement, and breach of fiduciary duty. 

THE PARTIES

1. Michael Reger is an individual over the age of eighteen (18), and resides in Palm 

Beach County, Florida. 

2. MLR Holdings 2020, LLC is a Florida limited liability Company with its principal 

place of business in Palm Beach County, Florida. 

3. All Things Gel, LLC is a Florida limited liability company with its principal place 

of business listed at 1460 Park Lane S., Suite 3, Jupiter, Florida 33458. 

4. GelTech Labs Corporation is a Florida Corporation with its principal place of 

business listed at 1460 Park Lane S., Suite 3, Jupiter, Florida 33458. 

5. ATG Laboratories Corp is a Florida Corporation with its principal place of business 

listed at 1460 Park Lane S., Suite 3, Jupiter, Florida 33458 

6. Dyno Tech Laboratories is a Florida Corporation with its principal place of business 

listed at 1460 Park Lane S., Suite 3, Jupiter, Florida 33458. 

7. Dynomat Inc. is a Florida Corporation with its principal place of business listed at 

1460 Park Lane S., Suite 3, Jupiter, Florida 33458. 

8. Whale Tank Ventures Inc is a Florida Corporation with its principal place of 

business listed at 266 Rudder Cay Way, Jupiter, Florida 33458. 

9. Logan’s Wipe Magic Inc. is a Florida Corporation with its principal place of 

business listed at 266 Rudder Cay Way, Jupiter, Florida 33458. 

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10. FireIce Gel, LLC is a Florida Corporation with its principal place of business listed 

at 1460 Park Lane S., Suite 3, Jupiter, Florida 33458. 

11. Peter J. Cordani is an individual over the age of eighteen (18), and upon information 

and belief, resides in Palm Beach County, Florida. 

12. Logan Cordani is an individual over the age of eighteen (18), and upon information 

and belief, resides in Palm Beach County, Florida. 

13. Mark Daniels is an individual over the age of eighteen (18), and upon information 

and belief, resides in Palm Beach County, Florida. 

JURISDICTION AND VENUE

14. This Court has personal jurisdiction over the Defendants because all the Defendants 

are residents of Florida and conduct business in Florida. 

15. This Court has subject matter jurisdiction over the Plaintiffs’ claims pursuant to 

Section 39 of the Lanham Act, 15 U.S.C § 1121(a) and 28 U.S.C. § 1331. 

16. Venue is proper in the Southern District of Florida pursuant to 28 U.S.C. § 1391(b) 

because ATG and GTL have their principal place of business in Palm Beach County, Florida, and 

a substantial part of the events giving rise to the claims occurred in Palm Beach County, Florida. 

GENERAL ALLEGATIONS

I. FACTUAL BACKGROUND

17. GelTech Solutions, Inc. a Delaware Corporation (“Geltech”) is a product 

innovation company that at one point specialized in environmentally friendly chemicals and 

products associated with fighting fire, protecting assets, and water retention throughout the world. 

18. Geltech sold four main product lines: FIREICE - a line of fire suppression and fireretardant products and the equipment used for their varied applications; FIREICE SHIELD- a line 

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of asset protection products including welding blankets; SOIL2O Dust Control products, and 

SOIL2O - a line of agricultural moisture retention products, including SOIL2O Topical and 

SOIL2O Granular.

19. These products were mainly used for agriculture, landscaping, fire protection, 

firefighting, and residential purposes.

20. These products were, and continue to be, recognized throughout the world as highly 

innovative.

21. To further the goals of the company, Geltech hired employees to create and 

innovate products. One such employee was Peter J. Cordani. On November 15, 2012, Geltech and 

Mr. Cordani entered into an Employment Agreement. A copy of the Employment Agreement is 

attached as Exhibit “A”. Mr. Cordani was to serve as the CTO of the Company. 

22. The Employment Agreement established, in pertinent part to this action, that:

a. Geltech had acquired and developed certain trade secrets that it sought to protect.

b. Mr. Cordani was restricted from competing against Geltech and soliciting its 

customers.

c. Mr. Cordani was to protect Geltech’s confidential information and keep it 

confidential. 

d. All inventions, ideas, processes, programs, software, and designs (including all 

improvements) conceived or made by Mr. Cordani during the course of his 

employment with Geltech was the sole and exclusive property of Geltech.

e. All Confidential Information, including trademarks, trade secrets, and other 

intellectual property was to be the exclusive property of Geltech.

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f. Mr. Cordani was strictly prohibited from copying or removing any of the named 

and identified exclusive property belonging to Geltech, which all of which became 

the property of Mr. Reger pursuant to the January 2020 Settlement Agreement. 

23. As part of Mr. Cordani’s employment, he had contact with utility companies and 

manufacturing companies throughout the world regarding the production and use of Geltech

Product and therefore had an in-depth knowledge of both Geltech’s customers and its vendors.

24. Over the years, Geltech developed and/or obtained valuable intellectual property, 

including numerous trade secrets, trademarks, patents, copyrights, and testing certifications and 

approvals (“Intellectual Property”).

25. Geltech filed numerous trademarks, including “FireIce” and “GelTech Solutions.”

26. Specifically, Geltech obtained at least 23 patents and applied for at least an 

additional 33 patents, owned at least eleven registered trademarks, created creative works of 

advertising, and had innumerable trade secrets including, but not limited to, its FIREICE and 

SOIL2O products’ formulas and compilations, its supplier information, and its customer list.

27. Geltech invested a tremendous amount of time, energy, and money in not just 

creating its products, but also submitted them to various companies and agencies to perform 

rigorous testing to ultimately obtain certifications and approvals.

28. For example, Geltech submitted its FIREICE products for testing with the United 

States Department of Agriculture, Forest Service, National Technology and Development Program 

(“U.S. Forest Service”). Geltech’s testing of its FIREICE products with the U.S. Forest Service 

cost more than $100,000 for each product tested and took almost two years to obtain final approval

for each of its products to be listed on the available Qualified Product List (“QPL”). 

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29. Tellingly, products claimed to be tested by ATG are not listed on the publicly

available QPL, meaning they were never so tested and approved. 

30. Furthermore, an inquiry was made to the U.S. Forest Service. The Program 

Manager of the Wildland Fire Chemical Systems, Mrs. Shirley Zystra, confirmed that ATG had 

never submitted the FireStorm product for testing, and is in fact not listed on QPL and cannot be 

used on Federal lands. 

31. Mr. Cordani was aware of Geltech’s Intellectual Property as he was its Chief 

Technology Officer and was involved in some of the development of products, including 

knowledge of the raw material suppliers and the proprietary formulas developed by those 

suppliers. 

32. Mr. Cordani also had intimate knowledge of all of Geltech’s customers and 

vendors, including access to Geltech’s address books and lists.

33. As a result of liquidity issues, Geltech eventually borrowed funds from Mr. Reger, 

a private lender.

34. By 2020, Geltech’s liability to Mr. Reger was approximately Seven Million Dollars 

($7,000,000) of secured convertible debt. 

35. On January 31, 2020, Geltech and Mr. Reger entered into a settlement and 

assignment agreement in which Geltech agreed to assign and transfer all of its assets, including its 

contract rights, intangibles, and intellectual property to Mr. Reger in consideration for Mr. Reger

releasing Geltech from any liability related to the debt owed to Mr. Reger (“Settlement 

Agreement”). A copy of the Form 8-K filing acknowledging the Settlement Agreement is attached 

hereto as Exhibit “B”. 

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36. Subsequent to the execution of the Settlement Agreement, the assignment of 

Geltech’s patents and trademarks to Mr. Reger was recorded with the United States Patent and 

Trademark Office. 

37. Accordingly, in exchange for releasing Geltech’s debt, Mr. Reger acquired all of 

Geltech’s assets, which includes, but is not limited to, the aforementioned contract rights and 

Intellectual Property (“Reger Settlement”).

38. Mr. Reger thereafter opened a new business, MLR Holdings 2020, LLC (“MLR”). 

39. MLR now operates as “Geltech” and manufactures, markets, and sells the same 

products that Geltech had sold, including the popular products sold under the federally registered 

FIREICE, GelTech Solution and SOIL2O trademarks.

II. DEFENDANTS’ DECEIT

40. Shortly after Geltech entered into the Settlement Agreement with Mr. Reger, Mr. 

Cordani left his employment with Geltech and formed All Things Gel, LLC (which does business 

as “ATG”) and GelTech Labs Corporation (which does business as “GTL”), with the cooperation 

and assistance of Mr. Daniels.

41. Specifically, ATG was formed by Mr. Cordani on April 29, 2020, with Mr. Cordani

as its sole officer. Mr. Cordani filed Articles of Dissolution and voluntarily dissolved ATG on June 

17, 2021, a mere seven (7) days after the Plaintiffs filed their original Complaint against ATG, but 

it is unclear whether ATG has actually ceased any operations.

42. As of the date of filing this Complaint, ATG’s website remains active and continues 

to advertise and sell products. 

43. GTL was formed on April 7, 2020, with Mr. Cordani as its CEO and remains an 

active entity. Mr. Daniels is the incorporator and President of GTL. 

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44. ATG and GTL share the same office and have the same principal address. Mr. 

Cordani is an authorized agent for both ATG and GTL, and upon information and belief, both 

ATG and GTL are owned and controlled by Mr. Cordani.

45. ATG and GTL sell fire suppression equipment that is identical to the Geltech 

products developed by Geltech and now sold by MLR. 

46. Indeed, the sole purpose of Mr. Cordani’s new companies is to compete against 

MLR. Mr. Cordani, Mr. Daniels, ATG, and GTL have employed numerous tactics to “copy and 

paste” the Geltech business, discussed in detail below. 

THEFT OF CUSTOMER LISTS

47. Geltech maintained an address book that was kept confidential.

48. Prior to departing Geltech, Mr. Cordani caused a Geltech employee to download 

Geltech’s entire electronic address book to be duplicated for Mr. Cordani. This address book 

included all of Geltech’s contacts, including its customers and suppliers.

49. Defendants then used the address book to call Geltech’s customers to market the 

products of ATG and GTL, and to invite them to an “open house” hosted by Defendants. Even if 

Defendants had developed their own products to sell, the theft and use of this customer list violated 

Mr. Cordani’s employment agreement and constituted theft of trade secrets, identified as an 

exclusive property of Geltech transferred to Mr. Reger under the Settlement Agreement

THEFT OF SUPPLIER

50. In 2016, Geltech engaged a manufacturer (“the Manufacturer”) to develop 

proprietary raw polymers for use in its fire suppression products. The identity of the manufacturer 

is a trade secret, and therefore is not disclosed in this pleading. 

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51. The Manufacturer’s agreement with Geltech prohibited the Manufacturer from 

providing the propriety products, or disclosing the technology behind the propriety products, to 

any competitor.

52. The Manufacturer’s agreement with Geltech inured to the benefit of, and was 

binding on, Geltech’s successors, which is now Mr. Reger.

53. The Manufacturer did create proprietary formulas for Geltech, including the 

formulas that became the basis of the FIREICE and SOIL2O products. 

54. Subsequent to leaving Geltech, Mr. Cordani and/or the other Defendants contacted 

the Manufacturer and placed orders for products using proprietary technology owned by Geltech

(and now by Mr. Reger) that are directly competitive to the proprietary FIREICE and SOIL2O

products.

55. Prior to the Agreement with the Manufacturer, Geltech had used this manufacturer 

as the single and sole supplier of the polymer used in the FIREICE and SOIL2O products. 

56. There were less than a handful of employees who had available to them the 

formulation, and specification for micron size utilized for each of the products; one of these 

persons was Mr. Cordani. 

57. Mr. Cordani would add to the formulation, including stabilizing material, and other 

propriety chemical components in order to obtain the desired viscosity for each one of the Geltech

products. In essence, Mr. Cordani, as CTO of Geltech, was in charge of quality control for each 

of the Geltech products and intimately knew each and every formulation and variation of such 

formulation and design of each of the products. 

58. He worked closely with the Purchasing Agent of Geltech to order and create the 

same exact formulation for quality assurance and product efficacy. 

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59. The Purchasing Agent was subsequently hired by Cordani to work for him and 

place orders with the Manufacturer using the same specifications that were used in both FIREICE

and SOIL2O. 

THEFT OF PRODUCT

60. Prior to departing Geltech, Mr. Cordani stole a substantial quantity of Geltech’s 

products from the Geltech warehouse.

61. He secreted the product in various warehouses, trailers and even residential 

dwellings owned by Mr. Cordani and his mother.

62. He stole and stored these products so he could use these assets in his new 

companies, ATG and GTL.

63. The accounting of these secreted assets was never disclosed to Mr. Reger or 

Geltech. This theft created liability to Geltech for conversion, which was assigned to Mr. Reger in 

the Settlement Agreement. 

64. Prior to opening ATG and GTL, Mr. Cordani accessed the stolen Geltech products 

and removed the labels from them, and placed labels for “FIRESTORM” on them.

THEFT OF TRADEMARKS

65. The trademarks owned by Mr. Reger, and licensed by MLR, include “SOIL2O” 

under Reg. No. 85356619, “FIREICE,” under Reg. No 3429533, and “GELTECH

SOLUTIONS,” under Reg. No. 3503586 (collectively “Trademarks”).

66. Mr. Cordani and Mr. Daniels are aware of the Trademarks.

67. Indeed, Mr. Cordani attempted to license the Trademarks and Patents from Mr. 

Reger, but Mr. Reger rejected, and did not license the Trademarks nor the Patents to Mr. Cordani. 

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68. The proposed license agreement provided by Mr. Cordani and his associates, 

acknowledged, and stated, that the licensor is the exclusive owner of trade names, trademarks, and 

product marks Mr. Reger acquired under the Settlement Agreement.

69. During this time, Mr. Daniels was advising Mr. Cordani, and was aware that neither 

he nor Mr. Cordani had any legal rights to the Trademarks. Mr. Daniels was present with Mr. 

Cordani and his legal counsel, and Mr. Reger’s legal counsel to discuss a potential license 

agreement. When asked about Daniels’ presence at the meeting, Mr. Reger’s legal counsel was 

told that Mr. Daniels was an advisor to Mr. Cordani for these matters. 

70. Defendants’ inventory consists entirely of (1) product stolen from Geltech, and (2) 

product ordered from the Manufacturer. Thus, Defendants’ products are sold in packaging that has

an identical size, shape, color, and handle to the corresponding products sold by MLR.

71. Defendants named the FIREICE-competitive product “FIRESTORM” and used the 

same black and red coloring used by MLR.

72. Defendants named the SOIL2O-competitive product “SOIL MD” and used the 

same green coloring used by MLR.

73. Use of the mark “GELTECH LABS” is also clearly intended to evoke the “Geltech 

Solutions” name.

74. Standing each of the products side-by-side, a consumer would find it very difficult

to distinguish them.

75. Use of similar names on identical packaging and/ or an identical business is 

intended to, and likely will, cause consumer confusion. 

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THEFT OF ADVERTISING

76. Geltech developed marketing collateral for its products. This collateral included 

product posters (“Geltech Posters”), which were displayed in Geltech’s conference room.

77. These Geltech Posters prominently displayed the FIREICE trademark.

78. After the dissolution of Geltech, Mr. Cordani leased the exact same warehouse 

space where Geltech had its principal place of business.

79. Mr. Cordani hung the Geltech Posters in his new conference room, in Geltech’s old 

space.

80. Using the stolen client list, Mr. Cordani and ATG invited Geltech’s customers to 

Geltech’s former space for an open house, where they were presented with posters showing visual 

images of Geltech’s products, and where Mr. Cordani presented product samples that were stolen 

Geltech products.

81. The copyright registrations owned by Mr. Reger, and licensed by MLR include at 

least one poster presented to customers and registered under Reg. No. VA 2-319-511, with an 

effective date of registration of September 22, 2022. 

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82. By putting up posters bearing Plaintiffs’ trademark and displaying products that 

were visual replicas of Plaintiffs’ products, Defendants intended to, and did mislead consumers

into believing that Defendants were affiliated with Mr. Reger and/or MLR.

83. At all times material, Defendants Mr. Cordani and Mr. Daniels directed, controlled, 

authorized, ratified, and/or participated in the infringement of Plaintiff’s Trademarks. 

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FALSE STATEMENTS

FALSE SUCCESSOR STATEMENTS

84. In an attempt to deceive others, Defendants have falsely claimed to customers of 

Mr. Reger and MLR, including previous customers of Geltech, that ATG is the successor to

Geltech and that ATG products have the same licensing and testing certifications as the Geltech

Products now owned and licensed by Mr. Reger and MLR. 

85. Defendants Mr. Cordani and ATG have represented to customers of Mr. Reger and 

MLR that ATG was “formally Geltech Solutions.” 

86. As a result, Defendants Mr. Cordani and ATG have confused and deceived 

consumers, and diverted their business to ATG. 

87. In one instance, MLR received an order from a customer, and the product was 

readied for pickup. The customer never came to pick up the product. 

88. When MLR inquired, the customer said that it had already picked up the product 

and paid ATG. ATG had advised the customer that ATG was formerly Geltech Solutions. 

89. Not only is this an issue of consumer confusion, but worse, the consumer 

purchased uncertified, untested soil products, which creates an environmental safety hazard with 

the potential to harm waterways, people and animals. 

FALSE CUSTOMER STATEMENTS

90. ATG publishes “customer testimonials” on its website. 

91. These testimonials purport to be from at least four customers of ATG.

92. Upon information and belief, some or all of these testimonials are fabricated.

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FALSE CERTIFICATION STATEMENTS

93. Additionally, Defendants hosted demonstrations, created YouTube videos, and 

provided testimonials falsely claiming that ATG products have the same claimed efficacy, thirdparty testing, and licenses as that of the former Geltech products now owned and licensed by Mr. 

Reger and MLR. 

94. These deceptive advertisements and practices create a life and health safety issue 

to consumers and the public at large because the testing and certifications claimed by Defendants 

are untrue. These false claims lead consumers to believe that these life safety products have been 

proven to work through testing by neutral third-party entities and/or the public organizations 

identified, such as the U.S. Forest Service and UL.

FALSE UL CERTIFICATION

95. Knowing they lack the testing certifications they claim they have, Mr. Cordani and 

ATG attempted to steal the UL listing for FIREICE products by having it transferred to ATG. 

96. Mr. Cordani and ATG’s representative advised UL that ATG “is the same CEO and 

same office location in Florida” as Geltech. When UL requested authorization from their listed 

contact with Geltech, Mr. Cordani knew the fraudulent scheme was up and failed to respond to 

UL’s emails to effectuate the transfer. 

97. Defendants do not presently have a UL certification on any of their products.

98. Companies that are in highly regulated areas are required to follow strict Fire Code 

regulations. For example, under certain Municipal Fires Codes, only UL extinguishers can be 

used. Mr. Cordani and ATG’s false claims that their extinguisher is UL rated places the public’s 

safety at risk and could potentially cost the consumer thousands of dollars in fines or even subject 

them to litigation in the event the ATG extinguisher fails to perform. 

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99. ATG’s Website currently lists its “FIRESTORM” XT Suppression Aerosol as 

passing UL equivalent tests. The website reads as follows:

100. This is false. No UL testing or equivalent testing has been done on the 

“FIRESTORM” products.

101. ATG’s wording is directly lifted off the website of Geltech for substantially the 

same product, with the same labeling and same container. 

102. ATG also has a brochure about its “FIRESTORM XT” 20 oz Aerosol, which

provides nearly identical repesentations as those for the FIREICE XT 20 oz Aerosol.

103. This brochure includes the false claim that the product has passed UL conformity 

testing:

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FALSE CLAIM OF PROTECTION UP TO 5,000°F 

104. ATG states that its “FIRESTORM XT” 20 oz Aerosol “utilizes the same powerful 

suppression agent as contained in the [sic] making it capable of containing a fire up to 5,000°F.” 

105. ATG could not even plagerise Geltech’s materials accurately, and failed to state 

what the suppression agent is comparable to.

106. The Geltech brochure for its FIREICE XT 20 oz Aerosol states that it “utilizes the 

same powerful suppression agent as contained in the FireIce® UL-Listed Extinguisher, making it 

capable of containing a fire up to 5,000°F.”

107. At a minimum, the statement in the ATG brochure about “FIRESTORM XT” 20 

oz Aerosol’s agent protecting up to 5,000°F is misleading. 

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108. Upon information and belief, the claim about “FIRESTORM XT” 20 oz Aerosol’s 

agent protecting up to 5,000°F is literally false. 

109. Unlike the “FIRESTORM XT” product, Mr. Reger’s FIREICE XT suppression 

agent has passed UL-Listing Equivalent testing.

110. Mr. Cordani’s statements in the ATG brochure mislead consumers that its agent is 

somehow comparable to something contained in something else, presumably a UL-Listed 

Extinguisher (which it is not), and therefore is capable of containing a fire up to 5,000°F.

111. Mr. Cordani and ATG are making false and misleading statements to consumers 

about “FIRESTORM XT” 20 oz Aerosol’s agent to deceive them about the product’s safety and 

reliability. 

112. These certifications are critical to consumer’s decisions to purchase these products; 

indeed, many agencies have policies in place that require these certifications as a prerequisite to 

purchase. 

FALSE CLAIM OF FIRE SUPPRESSION RATINGS

113. Mr. Cordani and ATG further claim its “Agent has passed custom UL 711-40A 

Listing Equivalent testing.”

114. This is another example of Defendants’ fraudulent use of the rigorous UL testing 

standards and certifications to bolster their product’s creditability and engender trust in consumers 

when selecting a product.

115. On UL’s website, in the about section, it claims that “as the global safety science 

leader, UL helps companies to demonstrate safety, enhance sustainability, strengthen security, 

deliver quality, manage risk and achieve regulatory compliance.” These are the benefits to products 

that go through its testing and certification process.

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116. Further, under product certification on its website, UL states that “our certifications 

demonstrate that your products have been tested to applicable standards. UL’s recognized 

regulatory expertise provides critical creditability to authorities and the marketplace. Bring your 

products to market more efficiently and clearly differentiate them on crowded shelves with 

certification from the safety science leader.”

117. Upon information and belief, “FIRESTORM XT” has not been UL tested, 

approved, or obtained certification.

118. Upon information and belief, the agent in “FIRESTORM XT” has not been UL 

tested, approved, or obtained certification.

119. The statement that its “Agent has passed custom UL 711-40A Listing Equivalent 

testing” is intentionally misleading.

120. Upon information and belief, the statement that its “Agent has passed custom UL 

711-40A Listing Equivalent testing” is literally false. 

121. On the other hand, the suppression agent in Mr. Reger’s FIREICE product has 

undergone UL testing, and has obtained UL certification. The UL file number is EX26444, and 

model number is 240-FI90-50/5.

122. On UL’s website regarding Fire Extinguisher Testing and Certification, they state 

that “The UL Mark on a fire extinguisher, as well as on fire extinguisher components and agents, 

is widely recognized to indicate that they meet the standards for safety and performance.”

123. Defendants are making false, and misleading statements to consumers about the UL 

testing of their product to deceive them about the product’s safety and reliability. 

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FALSE CLAIM OF ECO FRIENDLY TESTING

124. The ATG sales brochure states that its FIRESTORM XT 20 oz Aerosol is “deemed 

environmentally benign by the EPA and USDA. FIRESTORM has been tested by the U.S. Forest 

Service and is classified as non-toxic to mammals, aquatic, and terrestrial species.”

125. The Safety and Data Sheet for “FIRESTORM XT” that is advertised on ATG’s 

Website states in Section 12.1 that “no negative or toxic effects on the environment are anticipated 

when released in dilution for terrestrial and aquatic ecosystems; based on government testing.”

126. The above statements are misleading and upon information and belief, the above 

statements are literally false.

127. Upon information and belief, “FIRESTORM” has not undergone any testing by the 

EPA, USDA, U.S. Forest Service, or other “government testing.”

128. Upon information and belief, the agent in “FIRESTORM” has not undergone any 

testing by the EPA, USDA, the U.S. Forest Service, or other “government testing.”

129. The U.S. Forest Service conducts rigorous testing of products and has its own 

manufacturer submission procedures for qualification testing of wildland fire chemical products.

This is important as the USDA Forest service policy requires that the agency only use evaluated, 

approved, and qualified chemicals. 

130. When submitting a product for testing to the U.S. Forest Service, the entity 

submitting the product and paying the costs of the evaluation is the only entity that may benefit 

from the results of the evaluation.

131. In fact, the U.S. Forest Service will not acknowledge that a submitted formulation 

is similar to or the same as a product submitted by another. Testing of each product will proceed 

independently of products submitted by any other company.

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132. Mr. Reger’s FIREICE has been tested by the U.S. Forest Service and is classified 

as non-toxic to mammals, aquatic, and terrestrial species. Mr. Reger’s FIREICE is a part of the 

U.S. Forest Service’s list of qualified products with the approved classifications and application 

methods. 

133. The evaluation and approval of the U.S. Forest Service to FIREICE belongs solely 

to Mr. Reger, and neither Mr. Cordani nor ATG is permitted to use FIREICE’s evaluation and 

approval as its own. 

FALSE CLAIMS REGARDING SOIL MD

134. Defendants’ “SOIL MD” Granular is a copy of Mr. Reger’s SOIL2O granular.

135. Similar to Defendants using the research and testing information for Mr. Reger’s 

FIREICE, Defendants are doing the same thing with Mr. Reger’s SOIL2O granular by engaging 

in false advertising of its “SOIL MD” product, making statements concerning its efficiency and 

safety without conducting its own research and testing to substantiate such statements. 

136. Defendants claim that “SOIL MD” can reduce irrigation needs, and that there is 

“up to 30-50% reduction in irrigation needs saving both water and money.”

137. Defendants claim that “SOIL MD” is “safe for kids, pets, and the environment,” 

that it is “eco friendly,” and it is compatible with all types of soil and vegetation.

138. Defendants’ claims about “SOIL MD” in the preceding Paragraphs are misleading.

139. Upon information and belief, Defendants’ claims about “SOIL MD” in the 

preceding Paragraphs are literally false.

COLLUSION AND COORDINATION AMONG DEFENDANTS

140. Peter Cordani has colluded with his son Logan Cordani and Daniels (“the 

Individual Defendants”) to engage in all of the fraudulent and unlawful activity describe above. 

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141. Knowing that ATG was subject to liability for these wrongful acts, the Individual 

Defendants administratively dissolved ATG right before the litigation, and then opened various 

new companies; namely, GelTech Labs Corporation (“GTL”), Dyno Tech Laboratories Corp 

(“Dyno Labs”), Dynomat Inc. (“Dyno Inc.”),Whale Tank Ventures Inc. (“Whale”), and Logan’s 

Wipe Magic, Inc. (“LWM”) (collectively “Sham Companies”).

142. The Sham Companies either exist today, or existed at some point in time, as a 

vehicle to fraudulently avoid liability and to collect revenue from the business that holds itself out 

as All Things Gel. When a litigation threat is raised against any of the Sham Companies, that 

company dissolves and the Individual Defendants direct the revenue to a different Sham Company.

143. The Individual Defendants are all owners, managers, and/or employees in the Sham 

Companies, and they identify the same principal address and contact information for each of the 

Sham Companies. 

144. For example, the form Non-Disclosure Agreement for Dyno Labs lists the contact 

as P.cordani@atg-labs.com. 

145. Each of Cordani, L. Cordani, and Mark Daniels control the Defendant corporations 

through various degrees of ownership interest, and as owners did direct and control the sales 

through these various companies, and marshalled all the revenue from these various sham 

corporations through one website, atg_labs.com. 

COUNT I – FALSE ADVERTISING

Lanham Act Violation, 15 U.S.C. § 1125(a) 

(Mr. Reger and MLR against Defendants) 

146. The Plaintiffs repeat and reallege each and every allegation contained in Paragraphs 

1 through 145 as if fully set forth herein. 

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147. This section will refer to the acts of “ATG,” which should be read to include all 

Individual Defendants, who actively directed the unlawful conduct described herein, and against 

all Sham Companies, which are “mere continuations” of ATG.

148. ATG did, and continues, to advertise its “FIRESTORM” and “SOIL MD” products 

for sale in interstate commerce.

149. ATG engages in commercial speech for the purpose of influencing consumers to 

buy its products. ATG’s commercial speech includes, but is not limited to, its statements on its 

Website, its Brochures and its Safety and Data Sheets, banners, and posters (“Advertising”).

150. ATG’s Advertising is provided and disseminated to the purchasing public in an 

attempt to affect the consumer’s buying decisions. 

151. ATG’s Advertising claims made regarding its “FIRESTORM XT” 20 oz Aerosol 

and “SOIL MD” are false and misleading.

152. ATG’s claims regarding customer testimonials are false and misleading.

153. ATG’s claims are likely to deceive or confuse a substantial segment of the buying 

public. 

154. ATG’s deceptive conduct is and has been willful and deliberate, and has injured

and continues to injure Mr. Reger, MLR, and consumers.

155. ATG knows or should know that the claims it is making regarding its customer 

testimonials and “FIRESTORM XT” 20 oz Aerosol and “SOIL MD” are false and misleading.

156. ATG’s Advertising violates Section 43(a) of the Lanham Act, 15 U.S.C. §1125(a).

157. Mr. Reger and MLR have been, and will continue, to be damaged by ATG’s false 

advertising, including through direct diversion of sales from Plaintiffs to ATG.

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WHEREFORE, Mr. Reger and MLR respectfully request that the Court enter judgment 

against Defendants as follows:

A. An Order adjudging that Defendants have violated Section 43(a) of the Lanham 

Act, 15 U.S.C. § 1125(a);

B. An Order preliminarily and permanently enjoining Defendants and their officers, 

agents, employees, and all persons acting in concert or participation with them, from:

i. Making or disseminating, or causing the making or dissemination of, the 

Defendants’ false and misleading claims, as alleged herein, including enjoining 

any advertising that uses the false and misleading claims, and any variations 

thereof; 

ii. Effecting assignments or transfers, forming new entities or associations, or 

utilizing any other device for the purpose of circumventing or otherwise 

avoiding the prohibitions set forth herein;

C. An Order requiring the Defendants to disseminate corrective advertising to correct 

the false and misleading impressions created among consumers by the false claims, as alleged 

herein;

D. An Order requiring that the Defendants disgorge all profits from their sales as ATG 

was formed for the sole purpose to clone products of Mr. Reger and MLR, and divert such sales 

with misinformation and false information using past employees who are intimate with the sales, 

customers and vendors of Geltech;

E. An Order requiring that Defendants recall ATG’s products sold concerning its false 

advertising;

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F. An Order awarding Mr. Reger and MLR damages to the fullest extent allowed by 

law, including any lost profits sustained by the Plaintiffs which were caused by the Defendants’ 

false advertising and/or the gains, profits, savings, and advantages the Defendants realized by 

reason of their false advertising;

G. An Order trebling Mr. Reger and MLR’s recovery pursuant to Section 35 of the 

Lanham Act, 15 U.S.C. §1117; 

H. An Order granting the Plaintiffs their costs and disbursements in this action, 

including its reasonable attorney’s fees; and

I. An Order granting Plaintiffs such other and further relief as this Court may deem 

just and proper. 

COUNT II – UNFAIR COMPETITION 

Lanham Act Violation, 15 U.S.C. § 1125(a) 

(Mr. Reger and MLR against Defendants) 

158. The Plaintiffs repeat and reallaged each and every allegation contained in 

Paragrpahs 1 through 157 as if fully set forth herein. 

159. This section will refer to the acts of “ATG,” which should be read to include all 

Individual Defendants, who actively directed the unlawful conduct described herein, and against 

all Sham Companies, which are “mere continuations” of ATG. 

160. ATG advertises itself as an authorized seller or distributor of FIREICE products. 

161. ATG engages in commercial speech for the purpose of influencing consumers to 

buy its products. ATG’s commercial speech includes, but is not limited to, its website, its 

brochures, its marketing events, and its posters in its offices that are open and available to the 

public. 

162. ATG offers identical products as those offered by MLR. 

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163. Defendants have engaged in a pattern of false and misleading activity designed to 

mislead the public into believing that they are associated with the trademarks and products offered 

by Mr. Reger and MLR. These include (1) the use of identical product packaging, (2) the use of 

similar names, (3) the use of posters bearing the FIREICE trademark, and (4) statements that ATG 

is the successor to Geltech.

164. ATG’s claims are likely to deceive or confuse a substantial segment of the buying 

public.

165. Defendant ATG’s use in commerce of Mr. Reger and MLR’s Trademarks, as 

described herein for its advertising and promotion of services, without Mr. Reger and MLR’s 

consent and/or authorization, constitutes unfair competition under § 1125(a) in that said conduct 

tends to falsely represent or designate that Defendant ATG’s products and/or services is offered 

by, sponsored by, or otherwise affiliated with Mr. Reger and MLR’s Trademarks and Intellectual 

Property, has caused, causes, and is likely to continue to cause consumer confusion, mistake or 

deception and to cause the relevant public to mistakenly believe that Mr. Reger and/or MLR offers, 

endorses, provides sponsors, is associated with, and/or is otherwise with Defendant ATG. 

166. ATG’s infringing acts have been with full knowledge of Plaintiffs’ rights in their 

Trademarks.

167. At all times material, Defendant ATG directed, controlled, ratified, and/or 

participated in the unauthorized use and infringement of Plaintiff’s’ valuable Trademarks. 

168. ATG’s deceptive conduct is and has been willful and deliberate, and has injured 

and continues to injure Mr. Reger, MLR, and consumers.

WHEREFORE, Mr. Reger and MLR respectfully request that the Court enter judgment 

against Defendants as follows:

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A. An Order adjudging that the Defendants have violated Section 43(a) of the Lanham 

Act,15 U.S.C. § 1125(a);

B. An Order preliminarily and permanently enjoining the Defendants and their

officers, agents, employees, and all persons acting in concert or participation with them, from:

i. Making any statement or representation whatsoever, or using any false 

designation of origin or false description, or performing any act, which can or 

is likely to lead the trade or public, or individual members thereof, to believe 

that any products manufactured, distributed, or sold by Defendants is in any 

manner associated or connected with Plaintiffs and/or the FireIce® mark, or are 

sold, manufactured, licensed, sponsored, approved, or authorized by Plaintiffs;

ii. Effecting assignments or transfers, forming new entities or associations, or 

utilizing any other device for the purpose of circumventing or otherwise 

avoiding the prohibitions set forth herein;

C. An Order requiring the Defendants to disseminate corrective advertising and/or 

statements to correct the false and misleading impressions created among consumers and vendors 

by the false claims, as alleged herein;

D. An Order requiring that the Defendants disgorge all profits from ATG’s sales as 

ATG was formed for the sole purpose to clone products of Mr. Reger and MLR, and divert such 

sales with misinformation and false information using past employees who are intimate with the 

sales, customers and vendors of Geltech;

E. An Order requiring that Defendants recall their products sold concerning its false 

and misleading advertising;

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F. An Order awarding Mr. Reger and MLR damages to the fullest extent allowed by 

law, including any lost profits sustained by the Plaintiffs which were caused by the Defendants’ 

false advertising and statements of origin, and/or the gains, profits, savings, and advantages the 

Defendants realized by reason of their deceptive and misleading conduct; 

G. An Order trebling Mr. Reger and MLR’s recovery pursuant to Section 35 of the 

Lanham Act, 15 U.S.C. §1117; 

H. An Order granting the Plaintiffs their costs and disbursements in this action, 

including its reasonable attorney’s fees; and 

I. An Order granting Plaintiffs such other and further relief as this Court may deem 

just and proper. 

COUNT III – TRADEMARK INFRINGEMENT 

Lanham Act Violation, 15 U.S.C. § 1114(1)(a) 

(Mr. Reger against Defendants) 

169. Mr. Reger repeats and reallages each and every allegation contained in Paragraphs 

1 through 168 as if fully set forth herein. 

170. This section will refer to the acts of “ATG,” which should be read to include all 

Individual Defendants, who actively directed the unlawful conduct described herein, and against 

all Sham Companies, which are “mere continuations” of ATG. 

171. Defendants’ use in commerce of Mr. Reger’s FIREICE trademark without Mr. 

Reger’s consent and/or authorization, constitutes an infringement of Mr. Reger’s trademark in 

violation of 15 U.S. C. § 1114(1), in that said conduct has caused confusion, mistake or deception, 

and is likely to continue to cause confusion, misstate, or deception, and to cause the relevant public 

to mistakenly believe that Mr. Reger endorses, sponsors, is associated with, and/or is otherwise 

affiliated with Defendants. 

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172. Defendants’ use of the marks “FIRESTORM”, “SOIL MD”, and Geltech without 

Mr. Reger’s consent and/or authorization, constitutes an infringement of Mr. Reger’s FIREICE, 

SOIL2O, and GELTECH SOLUTIONS trademarks in violation of 15 U.S. C. § 1114(1), in that 

said conduct has caused confusion, mistake or deception, and is likely to continue to cause 

confusion, misstate, or deception, and to cause the relevant public to mistakenly believe that Mr. 

Reger endorses, sponsors, is associated with, and/or is otherwise affiliated with ATG.

173. ATG’s infringing acts have been with full knowledge of Mr. Reger’s rights in his 

trademarks.

174. At all times material, Defendants directed, controlled, ratified, and/or participated 

in the unauthorized use and infringement of Mr. Reger’s valuable trademarks.

175. Defendants’ conduct is willful and reflects an intent to exploit the goodwill and 

strong brand recognition associated with the trademarks.

176. Through the unauthorized use of Mr. Reger’s trademarks, Defendants are unfairly 

benefiting from and misappropriating Mr. Reger’s goodwill and reputation, as well as the fame of 

the trademarks. This has resulted in substantial and irreparable injury to the public and to Mr. 

Reger. 

177. Defendants’ acts have caused, and will continue to cause, irreparable injury to Mr. 

Reger. Mr. Reger has no adequate remedy at law and is thus damaged in an amount not yet 

determined.

WHEREFORE, Mr. Reger respectfully requests that the Court enter judgment against 

ATG as follows:

A. An Order adjudging that the Defendant has violated Section 32(1)(a) of the Lanham 

Act, 15 U.S. C. § 1114(1);

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B. An Order preliminarily and permanently enjoining the Defendants and their

officers, agents, employees, and all persons acting in concert or participation with it in any manner, 

form, medium, and/or fashion, from:

i. Using Mr. Reger’s FIREICE, SOIL2O, or GELTECH SOLUTIONS

trademarks or any other reproduction, counterfeit, copy or imitation of the 

trademarks, including use of “FIRESTORM”, “SOIL MD”, “GELTECH 

LABS”, and “GTL” on or in connection with any goods or services, or in 

connection with the promotion, advertisement, display, sale, offer for sale, 

manufacture, production, importation, circulation, or distribution of any 

products;

ii. Destroying, altering, removing, or otherwise dealing with unauthorized 

products or any books or records which contain any information relating to the 

importation, manufacture, production, distribution, circulation, sale, marketing, 

offer for sale, advertising, promotion, rental or display of all products which 

infringe Mr. Reger’s trademarks;

iii. Effecting assignments or transfers, forming new entities or associations, or 

utilizing any other device for the purpose of circumventing or otherwise 

avoiding the prohibitions set forth herein;

C. For the entry of an Order directing Defendants to deliver up for destruction to Mr. 

Reger all products, advertisements, promotional materials, and packaging in its possession or 

under its control bearing the FIREICE, SOIL2O, or GELTECH SOLUTIONS trademark, or any 

simulation, reproduction, counterfeit, copy or imitation thereof pursuant to 15 U.S.C. §1118;

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D. An Order awarding Mr. Reger damages to the fullest extent allowed by law, 

including any lost profits sustained by the Plaintiffs which were caused by the Defendants’ false 

advertising and/or the gains, profits, savings, and advantages the Defendants realized by reason of 

their infringement; 

E. An Order trebling Mr. Reger’s recovery pursuant to Section 35 of the Lanham Act, 

15 U.S.C. §1117; 

F. An Order granting the Plaintiffs their costs and disbursements in this action, 

including its reasonable attorney’s fees; and

G. An Order granting Plaintiffs such other and further relief as this Court may deem 

just and proper. 

COUNT IV - MISAPPROPRIATION OF TRADE SECRETS 

18 U.S.C. §§ 1832 AND 1836) 

(Mr. Reger and MLR against All Defendants)

178. Mr. Reger repeats and reallages each and every allegation contained in Paragrpahs 

1 through 177 as if fully set forth herein. 

179. This section will refer to the acts of “ATG,” which should be read to include all 

Individual Defendants, who actively directed the unlawful conduct described herein, and against 

all Sham Companies, which are “mere continuations” of ATG. 

180. Defendants’ conduct constitutes a misappropriation of trade secrets under the 

Defend Trade Secrets Act, codified at 18 U.S.C. §§ 1836 and 1839. 

181. Mr. Reger and his licensee, MLR, have an advantage in trade competition over 

MLR’s competitors by virtue of the Geltech customer list, the identity of Geltech’s manufacturer, 

Geltech’s relationship with its Manufacturer, the propriety formulas developed by the 

Manufacturer for Geltech’s exclusive use, and other trade secrets.

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182. Geltech transferred the trade secrets to Mr. Reger, who exclusively licenses them 

to MLR.

183. These trade secrets are not generally known by others in the industry nor are they 

readily ascertainable by an independent investigation.

184. Geltech kept, and Mr. Reger and MLR continue to keep, this information secret.

185. Mr. Cordani acquired the trade secrets “under circumstances giving rise to a duty 

to maintain the secrecy of the trade secret or limit the use the of the trade secret ...” 18 U.S.C. § 

1839(5)(b)(ii)(II). Namely, Geltech hired Mr. Cordani to be its Chief Technology Officer.

186. However, Mr. Cordani and the other Defendants used the trade secrets to solicit 

customers and develop a competing product.

187. Plaintiffs have been damaged by the misappropriation of their trade secrets by 

losing customers.

188. Because the future harm caused by Mr. Cordani’s ongoing use of Plaintiffs’ trade 

secrets is not fully quantifiable, Plaintiffs have no adequate remedy at law to his continued 

possession or use of the trade secrets. Mr. Cordani’s conduct has caused, and if not enjoined will 

continue to cause, irreparable damage to Plaintiffs. Accordingly, Plaintiffs are entitled to injunctive 

relief.

WHEREFORE, Mr. Reger and MLR respectfully requests that the Court enter judgment 

against Mr. Cordani as follows:

A. An Order adjudging that the Defendant has violated 18 U.S.C. §§ 1836 and 1839;

B. An Order preliminarily and permanently enjoining the Defendants and their

officers, agents, employees, and all persons acting in concert or participation with them in any 

manner, form, medium, and/or fashion, from:

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i. Using Mr. Reger’s customer lists, soliciting Geltech’s former customers, 

engaging in any relationship with the Manufacturer, and continuing to 

manufacture, sell or distribute any products containing the trade secret 

formulations and polymers produced by the Manufacturer for Geltech;

ii. Destroying, altering, removing, or otherwise dealing with unauthorized 

products or any books or records which contain any information relating to the 

importation, manufacture, production, distribution, circulation, sale, marketing, 

offer for sale, advertising, promotion, rental or display of all products which 

misappropriate Mr. Reger’s trade secrets;

iii. Effecting assignments or transfers, forming new entities or associations, or 

utilizing any other device for the purpose of circumventing or otherwise 

avoiding the prohibitions set forth herein;

C. For the entry of an Order directing Defendants to deliver up for destruction to Mr. 

Reger all products made by the Manufacturer, or using the trade secret formulations and polymers 

produced by the Manufacturer for Geltech;

D. An Order awarding Mr. Reger damages to the fullest extent allowed by law, 

including any lost profits sustained by the Plaintiffs which were caused by the Defendants’

misappropriation of trade secrets;

E. An Order for exemplary damages due to Defendants’ willful and malicious 

misappropriation; 

F. An Order granting the Plaintiffs their costs and disbursements in this action, 

including its reasonable attorney’s fees; and

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G. An Order granting Plaintiffs such other and further relief as this Court may deem 

just and proper. 

COUNT V - MISAPPROPRIATION OF TRADE SECRETS 

Florida Uniform Trade Secrets Act – §688, Fla. Stat. 

(Mr. Reger and MLR against All Defendants)

189. Mr. Reger repeats and reallages each and every allegation contained in Paragrpahs 

1 through 188 as if fully set forth herein. 

190. This section will refer to the acts of “ATG,” which should be read to include all 

Individual Defendants, who actively directed the unlawful conduct described herein, and against 

all Sham Companies, which are “mere continuations” of ATG. 

191. Defendants’ conduct constitutes a misappropriation of trade secrets under the 

Florida Uniform Trade Secrets Act, codified at §688.001, et seq., Fla. Stat.

192. Mr. Reger and his licensee, MLR, have an advantage in trade competition over 

MLR’s competitors by virtue of the Geltech customer list, the identity of Geltech’s manufacturer, 

Geltech’s relationship with its Manufacturer, the propriety formulas developed by the 

Manufacturer for Geltech’s exclusive use, and other trade secrets.

193. Geltech transferred the trade secrets to Mr. Reger, who exclusively licenses them 

to MLR.

194. These trade secrets are not generally known by others in the industry nor are they 

readily ascertainable by an independent investigation. 

195. Geltech kept, and Mr. Reger and MLR continue to keep, this information secret. 

196. However, Mr. Cordani and the other Defendants used the trade secrets to solicit 

customers and develop a competing product. 

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197. Plaintiffs have been damaged by the misappropriation of their trade secrets by 

losing customers.

198. Because the future harm caused by Mr. Cordani’s ongoing use of Plaintiffs’ trade 

secrets is not fully quantifiable, Plaintiffs have no adequate remedy at law to his continued 

possession or use of the trade secrets. Mr. Cordani’s conduct has caused, and if not enjoined, will 

continue to cause, irreparable damage to Plaintiffs. Accordingly, Plaintiffs are entitled to injunctive 

relief.

WHEREFORE, Mr. Reger and MLR respectfully requests that the Court enter judgment 

against Mr. Cordani as follows:

A. An Order adjudging that the Defendant has violated the Florida Uniform Trade 

Secrets Act;

B. An Order preliminarily and permanently enjoining the Defendants and their

officers, agents, employees, and all persons acting in concert or participation with them in any 

manner, form, medium, and/or fashion, from:

i. Using Mr. Reger’s customer lists, soliciting Geltech’s former customers, 

engaging in any relationship with the Manufacturer, and continuing to 

manufacture, sell or distribute any products containing the trade secret 

formulations and polymers produced by the Manufacturer for Geltech;

ii. Destroying, altering, removing, or otherwise dealing with unauthorized 

products or any books or records which contain any information relating to the 

importation, manufacture, production, distribution, circulation, sale, marketing, 

offer for sale, advertising, promotion, rental or display of all products which 

misappropriate Mr. Reger’s trade secrets;

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iii. Effecting assignments or transfers, forming new entities or associations, or 

utilizing any other device for the purpose of circumventing or otherwise 

avoiding the prohibitions set forth herein;

C. For the entry of an Order directing Defendants to deliver up for destruction to Mr. 

Reger all products made by the Manufacturer, or using the trade secret formulations and polymers 

produced by the Manufacturer for Geltech;

D. An Order awarding Mr. Reger damages to the fullest extent allowed by law, 

including any lost profits sustained by the Plaintiffs which were caused by the Defendants’

misappropriation of trade secrets;

E. An Order for exemplary damages due to Mr. Cordani’s willful and malicious 

misappropriation; 

F. An Order granting the Plaintiffs their costs and disbursements in this action, 

including its reasonable attorney’s fees; and

G. An Order granting Plaintiffs such other and further relief as this Court may deem 

just and proper.

COUNT VI: BREACH OF FIDUCIARY DUTY

(Mr. Reger against Mr. Cordani)

199. Mr. Reger repeats and realleges each and every allegation contained in Paragrpahs 

1 through 198 as if fully set forth herein.

200. Given his duties to and his special relationship with Geltech, Mr. Cordani owed 

Geltech a fiduciary duty. 

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201. Geltech placed Mr. Cordani in a position of trust and confidence by granting him 

access to its highly confidential, protected trade secrets and other information, so that he could 

perform his functions for Geltech. At all times, Mr. Cordani understood the economic and 

exploitive value of that confidential information and that misappropriation thereof would injure 

and damage Geltech and any successor. 

202. Mr. Cordani acted as an employee that performed specialized functions for Geltech, 

and who was authorized to communicate with suppliers, vendors, and customers. As such, he was 

Geltech’s agent. 

203. As Geltech’s agent, Mr. Cordani owed Geltech (1) a duty of loyalty and utmost 

good faith; (2) a duty to refrain from self-dealing; (3) a duty to act with integrity of the strictest 

kind; (4) a duty of fair, honest dealing; and (5) a duty of full disclosure.

204. Mr. Cordani breached his duties of loyalty and good faith dealing owed to Geltech

by unlawfully appropriating and mis-using Geltech’s trade secrets and other confidential, 

proprietary assets, including but not limited to the Geltech customer list, the identity of Geltech’s 

manufacturer, Geltech’s relationship with its Manufacturer, and the propriety formulas developed 

by the Manufacturer for Geltech’s exclusive use for his personal profit and commercial 

exploitation in developing competing products for a competing business, and by soliciting 

Geltech’s manufacturer and customers, and by diverting business opportunities away from MLR, 

both directly and as controlling person of ATG and GTL.

205. By virtue of the Settlement Agreement, Mr. Reger owns the causes of action and 

all rights of recovery and relief for Mr. Cordani’s breaches of fiduciary duty to Geltech, and in 

turn, to Mr. Reger and his exclusive licensee MLR, as he acquired ownership of those trade secrets 

and other confidential, proprietary assets of Geltech through the Settlement Agreement.

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206. Mr. Cordani’s breaches have directly injured and damaged Mr. Reger by unlawfully 

causing MLR’s customers to purchase competing product offered by ATG and/or GTL. 

WHEREFORE, Mr. Reger and MLR respectfully requests that the Court enter judgment against 

Mr. Cordani as follows: 

A. An Order awarding Mr. Reger damages to the fullest extent allowed by law, 

including disgorgements of any lost profits sustained by the Plaintiffs which were 

caused by the Defendant’s breaches of fiduciary duty; 

B. An Order for enhanced damages as allowed by law; 

C. An Order granting the Plaintiffs their costs and disbursements in this action, 

including its reasonable attorney’s fees; and 

D. An Order granting Plaintiffs such other and further relief as this Court may deem 

just and proper. 

COUNT VII – UNFAIR TRADE PRACTICES 

Florida Deceptive and Unfair Trade Practices Act Violation, §§ 501.201-212, Fla. Stat. 

(Mr. Reger and MLR against All Defendants)

207. The Plaintiffs repeat and reallege each and every allegation contained in Paragraphs 

1 through 206 as if fully set forth herein. 

208. The Defendants are not authorized to promote, sell, or otherwise represent any 

affiliation with any of the Plaintiffs’ products, including, but not limited to, the Plaintiffs’ FireIce®

products and trademark. 

209. The Defendants’ products have not undergone the requisite testing or certification 

approval for the Defendants to claim that their products are comparable to the Plaintiffs’ products, 

or have the same qualities, certifications, and approvals as Plaintiffs have for their products. 

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210. The Defendants’ promotion, advertisement, or offering of the products is unfair 

competition and constitutes a deceptive act or trade practices in violation of Florida’s Deceptive 

and Unfair Trade Practices Act.

211. Defendants’ unauthorized use of Mr. Reger’s FIREICE trademark, and false 

advertising, in conjunction with its services provided to reasonable consumers is unfair, deceptive, 

immoral, unethical, oppressive, unscrupulous and substantially injurious in that:

a. it creates the false, deceptive and misleading impression that Mr. Reger, MLR or 

the FIREICE brand is associated with, sponsors, offers, endorses, or is otherwise affiliated with 

Defendants’ services, and endorses or provides such products to Defendants; 

b. it dilutes, blurs, and tarnishes Mr. Reger, MLR and the FIREICE trademark’s

highly regarded, famous, and renowned name and reputation in the community and industry; 

c. it deceives and confuses consumers into believing that the advertising statements 

made regarding testing, approval, and certifications are valid providing false credibility and 

assurance to customers by life safety products that are highly regulated; and

d. it causes and is likely to continue to cause confusion, deception, and/or 

mistake on the part of the public and reasonable consumers.

212. The Defendants have acted willfully, intentionally, and deliberately in derogation 

of the Plaintiffs’ rights.

213. At all times material, Defendants directed, controlled, ratified, and/or participated 

in these unfair, deceptive, immoral, unethical, oppressive, unscrupulous and substantially injurious 

acts or practices.

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214. As a direct and proximate result of Defendants’ unfair, deceptive, immoral, 

unethical, oppressive, unscrupulous and substantially injurious acts or practices, the Plaintiffs have

and will continue to suffer damages.

215. Plaintiffs are entitled to injunctive relief pursuant to Section 501.211(1), Florida 

Statutes, to prevent future injury to its reputation and its mark, and to prevent consumer deception 

and confusion.

WHEREFORE, Plaintiffs respectfully requests that this Court enter judgment against 

Defendants for the following:

A. Preliminarily and permanently enjoining Defendants and their officers, agents, 

servants, employees and all persons acting in concert or participation with it from using, in any 

manner, form, medium, and/or fashion, the FIREICE trademark, for and/or in connection with its 

Advertising or services for any other purpose, and from infringing the FIREICE trademark, or 

using any names or marks confusingly similar thereto;

B. Award Mr. Reger and MLR damages to the fullest extent allowed by law, including 

any lost profits sustained by the Plaintiffs which were caused by the Defendants’ false advertising 

and infringement, and/or the gains, profits, savings, and advantages the Defendants realized by 

reason of their fraudulent and deceptive conduct;

B. Award attorney’s fees and costs to Plaintiffs’ counsel as provided for under

Section 501.2105, Florida Statutes; and

C. Provide such other relief as may be proper.

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COUNT VIII – BREACH OF EMPLOYMENT AGREEMENT

(Mr. Reger against Cordani) 

216. The Plaintiffs repeat and reallege each and every allegation contained in Paragraphs 

1 through 215 as if fully set forth herein. 

217. Mr. Cordani executed an employment agreement on October 1, 2012, with Geltech

(“Employment Agreement”). A true and correct copy of that Employment Agreement is attached 

as Exhibit A. 

218. In the Employment Agreement, in exchange for his employment as Geltech’s Chief 

Technology Officer and a generous salary, Mr. Cordani agreed, inter alia, to valid and enforceable 

restrictive covenants that prohibited him from engaging in anti-competitive actions.

219. Pursuant to Paragraph 8(a), Mr. Cordani agreed not to compete with Geltech for a 

period of one year following his termination in geographic areas in which Geltech had customers.

220. However, immediately following his departure from Geltech, Mr. Cordani opened 

ATG, a directly competitive business, soliciting customers in Geltech’s precise geographic 

markets. Such action constituted a breach of the Employment Agreement. 

221. Pursuant to Paragraph 8(b), Mr. Cordani agreed not to solicit Geltech’s customers 

for a period of one year following his termination. 

222. However, immediately following his departure from Geltech, Mr. Cordani opened 

ATG, a directly competitive business, soliciting Geltech’s customers. Such action constituted a 

breach of the Employment Agreement. 

223. Pursuant to Paragraph 9(c), Mr. Cordani agreed not to use for his own benefit or 

disclose any of Geltech’s confidential information.

224. However, immediately following his departure from Geltech, Mr. Cordani used for 

his own personal benefit Geltech’s customer list, the identity of Geltech’s manufacturer, Geltech’s 

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relationship with its Manufacturer, and the propriety formulas developed by the Manufacturer for 

Geltech’s exclusive use. Such action constituted a breach of the Employment Agreement. 

225. By violating Paragraphs 8(a), 8(b), and 9(b) of the Employment Agreement, Mr. 

Cordani breached the Employment Agreement. 

226. The Employment Agreement inured to the benefit of Geltech’s successors, defined 

as successors the acquired “all or substantially all of the securities or assets and business” of 

Geltech. 

227. Therefore, the Employment Agreement inures to the benefit of, and is enforceable 

by, Mr. Reger. 

WHEREFORE, Mr. Reger and MLR respectfully requests that the Court enter judgment 

against Mr. Cordani as follows: 

A. An Order declaring that Mr. Cordani has breached his Employment Agreement 

B. An Order requiring Mr. Cordani to terminate relationships with the Manufacturer, to 

terminate relationships with all Geltech former customers, to cease all manufacture, 

sales, and marketing of products made by the Manufacturer or manufactured by 

utilizing Mr. Reger’s confidential information; and

C. An Order for attorney’s fees, as required by the Employment Agreement. 

COUNT IX – COPYRIGHT INFRINGEMENT 

(Mr. Reger and MLR against All Defendants)

228. The Plaintiffs repeat and reallege each and every allegation contained in 

Paragraphs 1 through 227 as if fully set forth herein. 

229. Mr. Reger owns all title and interest in its copyright protected visual work. 

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230. On information and belief, Defendants have reproduced, displayed, and prepared 

derivative works of the poster that infringe on Mr. Reger’s copyrighted work.

231. Defendant’s actions violate Mr. Reger’s exclusive rights as provided by 17 U.S.C.

§ 106. 

232. On information and belief, Defendants have willfully, intentionally, and 

deliberately infringed on Mr. Reger’s copyrighted visual work. 

233. In accordance with 17 U.S.C. § 504, Mr. Reger is entitled to recover the actual 

damages suffered as a result of the infringement, and any profits of the infringement, and profits 

of the infringer that are attributable to the infringement. 

234. Mr. Reger is entitled to a permanent injunction pursuant to 17 U.S.C. § 502 

preventing Defendants from copying, manipulating, reproducing, distributing, selling, or 

displaying any infringing or derivative works. 

WHEREFORE, Mr. Reger and MLR respectfully request that the Court enter judgment 

against Mr. Cordani as follows:

A. An Order declaring that Mr. Cordani has reproduced, displayed, and prepared 

derivative works of the copyrighted work;

B. An Order requiring all Defendants should be preliminarily and permanently enjoined 

from marketing or selling any product containing all or any portion of or derived from 

Mr. Reger’s copyrighted visual work; and 

C. An Order for all damages and costs suffered as a result of the copyright 

infringement, and any profits of the infringement, and any profits attributable to the 

infringement. 

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DEMAND FOR JURY TRIAL

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Plaintiffs demand trial by 

jury in this action of all issues so triable.

Dated: November 15, 2022. 

/s/ Amanda G. Hyland

Amanda G. Hyland 

Georgia Bar No. 37554 

TAYLOR ENGLISH DUMA LLP

1600 Parkwood Circle, Suite 400 

Atlanta, Georgia 30339 

Telephone: (770) 434 6868 

Fax: (404) 434-7376 

 Email: ahyland@taylorenglish.com 

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