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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

VERA BRADLEY DESIGNS, INC., 

Plaintiff, 

vs. 

AIXIN LI, an individual; Case No: 

BRIAN BENSON, an individual; 

DANNY LU, an individual; 

KEVIN LU, an individual; 

XIA LU, an individual; 

WEINA NIU, an individual; and 

YANXIN YANG, an individual; 

Defendants. 

COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF AND JURY DEMAND 

INTRODUCTION 

This is an action for trademark counterfeiting, trademark infringement, unfair competition, 

false designation of origin, and copyright infringement based on the Defendants’ illegal sale of 

counterfeit Vera Bradley® goods. Defendants have violated numerous federal and state laws due 

to their acts of counterfeiting and infringement of Plaintiff’s valuable intellectual property, which 

has been ongoing since at least 2010. Plaintiff has repeatedly demanded that Defendants cease 

selling counterfeit goods and infringing its trademarks and copyrights, but to no avail. Plaintiff is 

seeking the assistance of this Court in the form of injunctive, monetary, and other relief against 

Defendants. 

THE PARTIES 

1. Plaintiff Vera Bradley Designs, Inc. (“Vera Bradley” or “Plaintiff”) is a corporation 

organized and existing under the laws of the State of Indiana with its principal place of business 

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located at 12420 Stonebridge Road, Roanoke, Indiana 46783. Vera Bradley is known nationally 

and internationally for its unique designs for bags, luggage, and accessories. Vera Bradley is the 

owner of 25 federal trademark registrations and seven pending federal trademark applications for 

the marks VERA BRADLEY®, VB VERA BRADLEY®, and variations thereof (the “VERA 

BRADLEY® Marks”). The VERA BRADLEY® Marks are used, and federally registered, in 

Class 18 for bags, purses, backpacks, luggage, and accessories (the “VERA BRADLEY® 

Goods”). Vera Bradley also owns valid and subsisting copyright registrations for over 1,000 of its 

unique fabric designs. 

2. Defendant Aixin Li, upon information and belief, is a citizen and resident of the 

State of Illinois with an address of 1615 Burning Bush Lane, Hoffman Estates, Illinois 61092. 

3. Defendant Brian Benson, upon information and belief, is a citizen and resident of 

the State of Illinois with an address of 5444 Swan Circle, Hoffman Estates, Illinois 60192. 

4. Defendant Danny Lu, upon information and belief, is a citizen and resident of the 

State of Illinois with an address of 1615 Burning Bush Lane, Hoffman Estates, Illinois 60192. 

5. Defendant Kevin Lu, upon information and belief, is a citizen and resident of the 

State of Illinois with an address of 1615 Burning Bush Lane, Hoffman Estates, Illinois 60192. 

6. Defendant Xia Lu, upon information and belief, is a citizen and resident of the State 

of Illinois with an address of 5444 Swan Circle, Hoffman Estates, Illinois 60192. 

7. Defendant Weina Niu, upon information and belief, is a citizen and resident of the 

State of Illinois with an address of 5444 Swan Circle, Hoffman Estates, Illinois 60192. 

8. Defendant Yanxin Yang, upon information and belief, is a citizen and resident of 

the State of Illinois with an address of 5444 Swan Circle, Hoffman Estates, Illinois 60192. 

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NATURE OF THE ACTION; JURISDICTION OF THE COURT 

9. This is an action for trademark counterfeiting, registered trademark infringement, 

false designation of origin, deceptive trade practices, and unjust enrichment under the Lanham 

Act, 15 U.S.C. § 1114 et seq., the Copyright Act, 17 U.S.C. § 501 et seq., 815 ILCS 510 et seq., 

and the common law.

10. The Court has jurisdiction over the subject matter of this action pursuant to 

15 U.S.C. § 1121 and 28 U.S.C. §§ 1331 and 1338(a).

11. This Court has personal jurisdiction over all Defendants because they transacted 

business and committed tortious acts from, within, and directed to the State of Illinois, and Vera 

Bradley’s claims arise from those activities. Defendants reached out to do business with Illinois 

residents by operating a brick-and-mortar retail store in Illinois and commercial, interactive 

internet storefronts through which Illinois residents could purchase products bearing counterfeit 

versions of Vera Bradley’s trademarks and which otherwise infringed Vera Bradley’s copyrights 

and other intellectual property. Defendants targeted sales to Illinois residents by operating this 

brick-and-mortar retail store and internet storefronts that (i) offer shipping to the United States, 

including Illinois; and (ii) on information and belief, sold counterfeit products to residents of 

Illinois. Defendants committed such tortious acts from the State of Illinois. Each of the Defendants 

is committing tortious acts in Illinois and has wrongfully caused Vera Bradley substantial injury 

in Illinois.

12. Venue is proper in this district pursuant to 8 U.S.C. § 1391(b)(1) and (2) because 

the Defendants reside in this District and a substantial part of the events giving rise to Vera 

Bradley’s claims herein occurred in this District. 

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FACTUAL BACKGROUND 

I. PLAINTIFF VERA BRADLEY 

13. Vera Bradley was founded in 1982, and since then, has become a household name 

for its unique, high-quality bags, luggage, and accessories. The VERA BRADLEY® Goods are 

instantly recognizable because of their creative patterns. Moreover, Vera Bradley customers have 

come to expect, and demand, only the highest quality for a product branded with the VERA 

BRADLEY® name.

14. Vera Bradley owns 25 federal trademark registrations and seven pending federal 

trademark applications for its VERA BRADLEY® Marks. 

15. The registrations most relevant to this proceeding are listed below (collectively, the 

“VERA BRADLEY® Registered Marks”). 

Mark Goods/Services Reg. No. Reg. Date 

VERA BRADLEY IC 018: Luggage made from textiles; 

namely, sport bags, duffle bags, garment 

bags for travel, backpacks, purses, 

handbags, tote bags, attaché bags, 

cosmetic bags sold empty, purse and 

handbag accessory; namely, overnight 

cases and travelling bags. 

IC 025: Women's clothing; namely, 

dresses, jumpers, skirts, blouses, 

camisoles, and sashes. 

1745799 January 12, 1993 

IC 009: Eyeglass cases. 

IC 018: Purses, handbags; Luggage made 

from textiles, namely, sport bags, duffel 

bags, garment bags for travel, backpacks, 

tote bags, attaché bags, cosmetic bags sold 

empty, purse and handbag accessories, 

namely, wallets, drawstring pouches for 

jewelry, overnight cases and travelling 

bags. 

2962647 June 14, 2005 

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IC 024: Table linens, namely placemats 

and napkins. 

IC 036: Charitable fundraising services 

IC 009: Textile curling iron covers. 

IC 018: Luggage made from textiles, 

namely, coin purses, baby bags for 

carrying babies’ accessories sold empty, 

luggage tags. 

IC 024: Textile baby changing pads. 

3138150 September 5, 

2006 

VERA BRADLEY IC 009: Textile curling iron covers. 

IC 018: Luggage made from textiles, 

namely, coin purses, baby bags for 

carrying babies’ accessories sold empty, 

luggage tags. 

IC 024; Textile baby changing pads. 

3161672 October 24, 2006 

VERA BRADLEY IC 018: Luggage including rolling 

luggage; luggage inserts, namely, packing 

cubes; backpacks; sack packs, namely, 

drawstring bags used as backpacks; 

satchels; bags for carrying babies' 

accessories; sport bags; duffel bags; 

garment bags for travel; leather purses; 

purses made of other fabrications; 

handbags; cross body bags; hipster bags; 

tote bags; attaché cases; cosmetic and 

toiletry bags sold empty; belt bags; wristlet 

bags; drawstring pouches; leather key 

chains; imitation leather key chains; 

shoulder bags; card cases, namely, 

business card cases, credit card cases, and 

calling card cases; messenger bags; 

luggage tags; coin purses; wallets; 

travelling bags; travel pill cases; ditty 

bags; umbrellas; grooming organizers for 

travel; beach bags. 

IC 020: Non-metal fabric hanging 

organizers. 

IC 021: Personal travel dispensers for pills 

or capsules for domestic use. 

5136200 February 7, 2017 

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IC 018: Luggage including rolling 

luggage; luggage inserts, namely, packing 

cubes; backpacks; sack packs, namely, 

drawstring bags used as backpacks; 

satchels; bags for carrying babies’ 

accessories; sport bags; duffel bags; 

garment bags for travel; leather purses; 

purses made of other fabrications; 

handbags; cross body bags; hipster bags; 

tote bags; cosmetic and toiletry bags sold 

empty; belt bags; wristlet bags; leather key 

chains; shoulder bags; card cases, namely, 

business card cases, credit card cases, and 

calling card cases; messenger bags; 

luggage tags; coin purses; wallets; 

travelling bags; travel pill cases; ditty 

bags; umbrellas; grooming organizers for 

travel; beach bags. 

IC 020: Non-metal fabric hanging 

organizers. 

IC 021: Personal travel dispensers for pills 

or capsules for domestic use. 

5408093 February 20, 

2018 

IC 018: Duffel Bags; handbags; cross body 

bags; tote bags; shoulder bags. 

5740108 Apr. 30, 2019 

IC 018: Luggage including rolling 

luggage; luggage inserts, namely, packing 

cubes; backpacks; sack packs, namely, 

drawstring bags; garment bags for travel; 

leather purses; purses made of other 

fabrications; handbags; cross body bags; 

hipster bags; tote bags; cosmetic and 

toiletry bags sold empty; belt bags; wristlet 

bags; shoulder bags; card cases, namely, 

business card cases, credit card cases, and 

calling card cases; messenger bags; coin 

purses; wallets; travelling bags; travel pill 

cases; grooming organizers for travel; 

beach bags. 

IC 020: Non-metal fabric hanging 

organizers. 

IC 021: Personal travel dispensers for pills 

or capsules for domestic use. 

5908409 Nov. 12, 2019 

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True and accurate copies of the registration certificates for each of the above trademarks are 

attached hereto as Exhibit A.

16. Vera Bradley’s U.S. Trademark Registration Nos. 1745799, 2962647, 3161672, 

and 3138150 are incontestable. Accordingly, these registrations provide conclusive evidence of 

the validity of the VERA BRADLEY® Marks, Vera Bradley’s ownership of the marks, and Vera 

Bradley’s exclusive right to use the marks in connection with the goods specified in the certificates 

of registration. 15 U.S.C. § 1115(b).

17. Through Vera Bradley’s extensive and continuous use and promotion of the VERA 

BRADLEY® Marks for over thirty years, the marks have become associated exclusively with 

Vera Bradley and its goods and services. 

18. In addition, Vera Bradley has registered many of its unique patterns—a staple of 

the VERA BRADLEY® brand—with the United States Copyright Office. Vera Bradley currently 

owns more than 1,000 copyright registrations for its unique patterns and designs. True and accurate 

copies of the registration certificates for each of the copyrighted patterns and designs at issue in 

this proceeding (the “Vera Bradley Works”) are attached hereto as Exhibit B. 

19. Vera Bradley currently employs approximately 2,600 people and earns 

approximately $416 Million in annual net revenue from the sale of its VERA BRADLEY® Goods. 

The Vera Bradley Facebook page has over 1.8 million followers. Vera Bradley sells its products 

in over 150 branded retail stores and on its website, www.verabradley.com. Vera Bradley also 

sells its products through approximately 2,400 specialty gift retailers, more than 400 department 

stores, and other key accounts.

20. A unique attribute of Vera Bradley’s business model is that it tightly controls who 

is authorized to sell VERA BRADLEY® Goods online. For example, Vera Bradley does not allow 

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even its authorized distributors to sell VERA BRADLEY® Goods online. Department stores are 

allowed to sell VERA BRADLEY® Goods only on their own websites, and some specialty 

accounts are allowed to sell on their own websites, but only if they are approved by Vera Bradley. 

Vera Bradley also sells directly through Amazon, and allows Zappos and eBags to sell on Amazon 

as well. However, Vera Bradley does not allow any of its distributors to sell products on eBay.com 

(“eBay”), poshmark.com (“Poshmark”), or mercari.com (“Mercari”), the venues where 

Defendants have sold much of their counterfeit product. 

21. Vera Bradley has taken numerous steps to police its marks and prevent 

counterfeiting of its VERA BRADLEY® Goods. For example, Vera Bradley has worked closely 

with online marketplaces, such as eBay and Amazon, to stop the advertising and sale of counterfeit 

goods. In fact, Amazon and Vera Bradley filed three lawsuits in 2018 in the United States District 

Court for the Western District of Washington against other counterfeiters. 

II. DEFENDANTS 

22. Defendants have imported, advertised, distributed, offered for sale, and sold 

counterfeit VERA BRADLEY® Goods in the United States. 

A. Defendants Sell Counterfeit Goods at Their Retail Store 

23. In 2010, Vera Bradley received a complaint from one of its specialty retailers that 

a nearby store, Mint Boutique, located in Arlington Heights, Illinois, was selling counterfeit VERA 

BRADLEY® Goods imported from China. Upon information and belief, Mint Boutique is owned 

by Defendant Xia Lu. 

24. On or about November 16, 2010, one of Vera Bradley’s sales consultants visited 

Mint Boutique and discovered that it was offering for sale proprietary Vera Bradley designs that 

had not yet been made available to the public. Upon further inquiry, the owner of Mint Boutique 

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told Vera Bradley’s sales consultant that she had more VERA BRADLEY® designs available at 

home. 

25. On or about November 24, 2010, counsel for Vera Bradley sent a cease and desist 

letter to Mint Boutique, demanding that it cease the sale of counterfeit VERA BRADLEY® 

merchandise. 

26. Counsel for Mint Boutique responded stating that Mint Boutique did not use or 

intend to use Vera Bradley’s intellectual property. 

27. After receiving Vera Bradley’s letters, Mint Boutique moved its store location from 

28 South Evergreen Arlington Heights, IL 60005 to 5444 Swan Circle, Hoffman Estates, IL 60192. 

Upon information and belief, 5444 Swan Circle, Hoffman Estates, IL is also the address at which 

Defendants Brian Benson and Xia Lu reside. 

28. In approximately March 2011, Vera Bradley received additional complaints from 

its specialty retailer that, upon information and belief, Mint Boutique was continuing to sell new 

VERA BRADLEY® goods obtained directly from China, which it was not authorized to do.

29. In approximately October 2011, Vera Bradley received further complaints from its 

specialty retailer that Mint Boutique was still selling Vera Bradley-branded products. 

30. Shortly thereafter, the Mint Boutique retail store shut down, and Vera Bradley 

reasonably believed that the sale of counterfeit goods had stopped. 

B. Defendants Also Sell Counterfeit Goods Through Third-Party Online 

Retailers 

31. Defendants have owned and operated under, and continue to own and operate 

under, numerous known and unknown user names on various online marketplaces, including eBay, 

Poshmark, Facebook, and Mercari. Defendants advertise, distribute, offer for sale, and sell both 

genuine and counterfeit VERA BRADLEY® goods through these various online marketplaces. 

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From approximately 2010 to the present, Defendants have sold counterfeit VERA BRADLEY® 

merchandise through numerous seller accounts on third-party websites.

C. Defendants Change Usernames to Avoid Detection 

32. Defendants own and operate a number of third-party online retail seller accounts 

and often change account usernames when detected by Vera Bradley. 

33. Upon information and belief, Defendant Aixin Li owns, or at one time owned, the 

following eBay seller accounts through which Aixin Li has offered for sale and sold counterfeit 

VERA BRADLEY® merchandise: “Hmcraft2011,” “Aixil_2,” “Pothand,” “A10062,” 

“Hotdeal5657,” “Discountfashion2you,” “Ahunters,” “Grandminds,” and “ellemind.”

34. Upon information and belief, Defendant Kevin Lu owns, or at one time owned, the 

following eBay seller accounts through which Kevin Lu has offered for sale and sold counterfeit 

VERA BRADLEY® merchandise: “Ahunters,” “cleanmops,” “cutemops,” “kutemops,” 

“usedmops,” “ellesmop,” “ellesrag,” “ellesrug,” “roundweb,” “richslot,” “richsnot,” “richsrags,” 

and “richsrag.” Upon information and belief, Defendant Kevin Lu also owns, or at one time owned, 

the Poshmark seller accounts “cyberpie658” and “Irobot@usedmop,” and the Mercari seller 

account “selldotcome,” through which he has offered for sale and sold counterfeit VERA 

BRADLEY® merchandise. 

35. Upon information and belief, Defendants Xia Lu and Brian Benson own, or at one 

time owned, the following eBay seller accounts through which they have offered for sale and sold 

counterfeit VERA BRADLEY® merchandise: “Designerswelove,” “rancharqus,” “Aplurose,” 

“DLw80743,” “11300533-660,” “Pricerite-8,” “Imperialprince,” “Fancyincone,” “Tempass,” 

“Aubusson4ever,” “Hotsoxbj,” “608254,” “07160825,” “Unimeijer,” “uverseshop,” 

“Hotwinter777,” and “Snowball2584.” Upon information and belief, Defendants Xia Lu and Brian 

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Benson also own, or at one time owned, the Mercari seller account “Sundayrose” through which 

they have offered for sale and sold counterfeit VERA BRADLEY® merchandise. 

36. Upon information and belief, Defendant Danny Lu owns, or at one time owned, the 

eBay seller account “danu99us” through which Danny Lu has offered for sale and sold counterfeit 

VERA BRADLEY® merchandise.

37. Upon information and belief, one or more Defendants acting under the alias 

“Joanna Benson” own, or at one time owned, the following eBay seller accounts through which 

they have offered for sale and sold counterfeit VERA BRADLEY® merchandise: 

“Divaslittlecorner,” “Booksplusmorebooks,” Summitshop,” “Advantageshop88,” and 

“Windpipe108.” Upon information and belief, Defendants acting under the alias “Joanna Benson” 

also own, or at one time owned, the Poshmark seller account “ladybagcottage” through which they 

have offered for sale and sold counterfeit VERA BRADLEY® merchandise. 

38. Upon information and belief, Defendant Weina Nu owns, or at one time owned, 

the following eBay seller accounts through which Weina Nu has offered for sale and sold 

counterfeit VERA BRADLEY® merchandise: “nutamo,” “yutamo,” and “zutamo.” 

39. Upon information and belief, Defendant Yanxin Yang owns, or at one time 

owned, the following eBay seller accounts through which Yanxin Yang has offered for sale and 

sold counterfeit VERA BRADLEY® merchandise: “cyberpie18,” “dotcomehighflyer,” 

“roundweb,” “squareweb,” “youngyang1,” “yangyoung1,” and “cyberyoung.” 

40. Vera Bradley has taken down hundreds of counterfeit listings under the aboveidentified seller accounts by utilizing eBay’s Verified Rights Owner Program (“VeRO”) and by 

sending takedown notices to Mercari and Poshmark. The seller accounts identified in Paragraphs 

33-39 are hereinafter collectively referred to as the “Defendants’ Seller Accounts.”

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D. Defendant’s Counterfeit Goods Have Been Seized by U.S. Customs and Border 

Control. 

41. Defendants’ counterfeit Vera Bradley merchandise has repeatedly been seized by 

U.S. Customs and Border Control. 

42. On or about October 7, 2015, 119 counterfeit VERA BRADLEY® products 

imported from China by Defendant Aixin Li were seized by U.S. Customs and Border Control. 

The U.S. Customs and Border Control notice that Vera Bradley received states that the products 

were being shipped to 1615 Burning Bush Lane, Hoffman Estates IL 60192, which, upon 

information and belief, is the residence of Aixin Li and Kevin Lu. 

43. On or about December 10, 2015, 114 counterfeit VERA BRADLEY® products 

imported from China by “Kathy Hudson” were seized by U.S. Customs and Border Control. Upon 

information and belief, “Kathy Hudson” is an alias for one or more of the Defendants because at 

the time of the seizure, “Kathy Hudson” lived at 5444 Swan Circle, Hoffman Estates, IL 60192, 

the same address as one or more of the Defendants.

44. On or about February 23, 2016, 100 counterfeit VERA BRADLEY® products 

imported from China by “John Hollander” were seized by U.S. Customs and Border Control. Upon 

information and belief, “John Hollander” is an alias for one or more of the Defendants because at 

the time of the seizure, “John Hollander” lived at 5444 Swan Circle, Hoffman Estates, Illinois 

60192, the same address as one or more of the Defendants. 

45. On or about February 27, 2018, 40 counterfeit VERA BRADLEY® products 

imported from China by Defendant Xia Lu, who, upon information and belief is also known as 

Xia Jliu, were seized by U.S. Customs and Border Control. Upon information and belief, these 

products were being shipped to a UPS store in Streamwood, Illinois. 

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E. Defendants Have Also Been Named as Counterfeit Sellers in a Recent 

Lawsuit Brought by Vera Bradley 

46. On or about January 24, 2019, Jennifer Denny, another seller of counterfeit Vera 

Bradley goods, declared under oath that she received counterfeit VERA BRADLEY® 

merchandise from Chinese suppliers, and was directed to pay Defendant Xia Lu for the counterfeit 

merchandise. Jennifer Denny also identified the email address dalu0169@yahoo.com as a source 

of counterfeit VERA BRADLEY® merchandise. Upon information and belief, the 

dalu0169@yahoo.com email address is owned by, or at one time was owned by, Defendant Danny 

Lu.

F. Defendants Continue to Sell Counterfeit Vera Bradley Merchandise 

47. Vera Bradley purchased a sampling of the goods Defendants listed for sale on eBay 

under Defendants’ Seller Accounts in order to determine whether the goods were authentic or 

counterfeit. 

48. By way of example, Vera Bradley purchased the following counterfeit goods from 

Defendants’ Seller Accounts on eBay that Vera Bradley determined to be counterfeit based on the 

reasons stated:

a. Flutterby-Hipster – Purchased on June 11, 2014 from seller account 

“ahunters.” Vera Bradley determined that this was counterfeit by hangtag inspection. Upon 

information and belief, this counterfeit product was advertised and sold by Defendants Brian 

Benson, Xia Lu, Aixin Li, and Kevin Lu because they each owned and operated the user account 

“ahunters” at one time. 

b. Trifold Wallet Sierra Stream – Purchased on November 20, 2016 from seller 

account “booksplusmorebooks.” Vera Bradley determined this was counterfeit by hangtag 

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inspection. Upon information and belief, this counterfeit product was advertised and sold by one 

or more Defendants under the alias “Joanna Benson” or J. Benson.”

c. Mini Hipster Disney Medallion – Purchased on December 13, 2016 from 

seller account “cutemops.” Vera Bradley determined this product was counterfeit by hangtag and 

country of origin label inspection. Upon information and belief, Defendant Kevin Lu owns and 

operates the user account “cutemops,” and advertised and sold this counterfeit product through the 

same. In addition, the return address for the eBay item was 1566 West Alqonquin Road #108, 

Hoffman Estates, IL 60192, a commercial property affiliated with UPS at which, upon information 

and belief, Kevin Lu owns or rents a PO Box. 

d. Scottie Dogs Triple Zip Hipster – Purchased on December 13, 2016 from 

seller account “hotwinter777.” Vera Bradley determined this product was counterfeit by country 

of origin label inspection. Upon information and belief, Defendants Brian Benson and Xia Lu own 

and operate the user account “hotwinter777” and advertised and sold this counterfeit product 

through the same. In addition, the return address for the eBay item was 5444 Swan Circle, Hoffman 

Estates, IL 60192, the same location where, upon information and belief, Defendants Brian Benson 

and Xia Lu reside. 

e. Magical Blooms Hanging Organizer – Purchased on December 6, 2017 

from seller account “aixil_2.” Vera Bradley determined this product was counterfeit by hangtag 

inspection. Upon information and belief, Defendants Aixin Li, Yanxin Yang, and/or Kevin Lu own 

and operate the “aixil_2” seller account and advertised and sold this counterfeit product through 

the same. Upon information and belief, Aixin Li owns the “aixil_2” user account, and Yanxin 

Yang and/or Kevin Lu owns the P.O. Box identified as the return address for the counterfeit 

product, P.O. Box 95571, Hoffman Estates, IL 60192. 

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f. Zip ID Midnight with Mickey – Purchased on December 14, 2017 from 

seller account “richsrags.” Vera Bradley determined this product was counterfeit by hangtag 

inspection. Upon information and belief, Defendant Kevin Lu owns and operates the user account 

“richsrags” and advertised and sold the counterfeit product through the same. 

g. Large Cosmetic Perfect Petals – Purchased on December 26, 2017 from 

seller account “yutamo.” Very Bradley determined this product was counterfeit by hangtag 

inspection. Upon information and belief, Defendants Weina Nu, Yanxin Yang, and/or Kevin Lu 

own and operate the user account “yutamo,” and advertised and sold the counterfeit product 

through the same. Upon information and belief, Defendant Weina Nu owns and operates the user 

account “yutamo,” and Defendants Yanxin Yang and/or Kevin Lu owns the P.O. Box identified 

as the return address for the counterfeit product, P.O. Box 95571, Hoffman Estates, IL 60192. 

h. Mini Hipster Nomadic Floral – Purchased on December 3, 2018 from seller 

account “zutamo.” Vera Bradley determined this product was counterfeit by hangtag inspection. 

Upon information and belief, Defendants Weina Niu, Aixin Li, Kevin Lu, and/or Danny Lu own 

and operate the “zutamo” account through which Defendants have advertised and sold the 

counterfeit product. Upon information and belief, Weina Nu owns the seller account “zutamo.” In 

addition, the product was shipped from the address at which Vera Bradley believe Aixin Li, Kevin 

Lu, and Danny Lu reside, 1615 Burning Bush Lane, Hoffman Estates, Illinois 60192, and Danny 

Lu was identified as the sender. 

49. Upon information and belief, one or more Defendants have also sold counterfeit 

VERA BRADLEY® merchandise on Poshmark, in violation of Poshmark’s policies. By way of 

example, Vera Bradley purchased the following sample of infringing goods from Defendants that 

Vera Bradley determined to be counterfeit based on the reasons stated:

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a. Triple Zip Hipster Medallion – Purchased on November 27, 2018 from 

seller account “cyberpie658.” Vera Bradley determined this was counterfeit by hangtag and 

country of origin label inspection. Upon information and belief, the user account “cyberpie658” is 

owned by Kevin Lu who advertised and sold the counterfeit product through the same. In addition, 

upon information and belief, the counterfeit product was shipped by Kevin Lu. 

b. Mickey and Friends Iconic Vera Tote – Purchased on June 12, 2019 from 

Poshmark seller account “Irobot@usedmop.” Vera Bradley determined this product was 

counterfeit by hangtag inspection and country of origin label inspection. Upon information and 

belief, the user account “Irobot@usedmop” is owned by Kevin Lu who advertised and sold the 

counterfeit product through the same. In addition, upon information and belief, the counterfeit 

product was shipped by Kevin Lu. 

c. Disney Campus Backpack in Disney Dreaming – Purchased on July 5, 2019 

from Poshmark seller account “ladybagcottage,” Vera Bradley determined this product was 

counterfeit by hangtag inspection. Upon information and belief, the user account “ladybagcottage” 

is owned by the Joanna Benson, which, upon information and belief, is the alias for one or more 

Defendants. 

d. Lunch Bunch in Paisley Celebration-Purchased on October 20, 2019 from 

Mercari seller account “selldotcome,” Vera Bradley determined this product was counterfeit by 

hangtag inspection and country of origin label inspection. Upon information and belief, the user 

account “selldotcome” is owned by Kevin Lu who advertised and sold the counterfeit product 

through the same. In addition, the product was shipped by Kevin Lu.

e. Campus Backpack in Kiev Paisley-Purchased on November 8, 2019 from 

Mercari seller account “selldotcome,” Vera Bradley determined this product was counterfeit by 

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hangtag inspection and country of origin label inspection. Upon information and belief, the user 

account “selldotcome” is owned by Kevin Lu who advertised and sold the counterfeit product 

through the same. In addition, the product was shipped by Kevin Lu.

f. Lunch Bunch in Playful Penguins-Purchased on December 20, 2019 from 

Mercari seller account “Sundayrose,” Vera Bradley determined this product was counterfeit by 

visual inspection, hangtag inspection, and country of origin label inspection. Upon information 

and belief, the user account “sundayrose” is owned by Xia Lu and/or Brian Benson. In addition, 

the product was shipped by Xia Lu and/or Brian Benson.

50. Upon information and belief, one or more Defendants have also sold counterfeit 

Vera Bradley merchandise on Facebook Marketplace, in violation of Facebook’s policies. 

G. Vera Bradley Has Repeatedly Taken Action Against Defendants to Protect 

Its Intellectual Property 

51. Vera Bradley participates in eBay’s VeRO program which allows intellectual 

property owners to report eBay listings that infringe on their rights. Vera Bradley utilized the 

VeRO program to report and request removal of Defendants’ listings that infringed Vera Bradley’s 

trademarks and copyrights.

52. eBay’s VeRO policy explicitly states that “Replicas, counterfeit items and 

unauthorized copies” are not allowed on eBay. Specifically, this includes “counterfeits, fakes, or 

replicas of brand name items (for example, a purse bearing the Chanel name or logo that wasn’t 

made by Chanel)”. eBay sellers must follow these rules, or may be subjected to a range of 

consequences, such as the item being removed from eBay, limits placed on the seller’s buying and 

selling privileges, and suspension of the seller’s account.

53. On multiple occasions from 2010 to Present, Vera Bradley requested that 

counterfeit products listed by Defendants be taken down through eBay’s VeRO program because 

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Vera Bradley believed that the products were counterfeit. The VeRO program allows sellers who 

are the subject of takedown orders to challenge the takedown. Vera Bradley has received such 

challenges from only one of the Defendants, a user named “Tim Morgan.” Upon information and 

belief, “Tim Morgan” is an alias for Kevin Lu, Aixin Li, and/or Danny Lu because Tim Morgan’s 

address is the same as these Defendants: 1615 Burning Bush Lane, Hoffman Estates, Illinois 

60192.

54. In March 2011, Vera Bradley used eBay’s VeRO program to remove counterfeit 

product listings from “Tim Morgan’s” eBay seller account, “discountfashion2you.” 

55. After Vera Bradley submitted its VeRO complaints, “Tim Morgan” contacted Vera 

Bradley asking it to clarify how Vera Bradley determined that the products “Tim Morgan” listed 

on eBay were counterfeit VERA BRADLEY® goods. 

56. Vera Bradley responded that the VERA BRADLEY® goods listed on “Tim 

Morgan’s” eBay seller account were identified as potentially misappropriated or counterfeit 

because they listed for sale products from Vera Bradley’s new Summer 2011 product line which 

had not yet been released to the public for sale. Vera Bradley asked “Tim Morgan” to identify 

where he purchased these products. Instead, “Tim Morgan” provided links to taobao.com, 

discountfabrichandbags.com, and Vera Bradley’s own website, and included an invoice written in 

Chinese as evidence that his products were purportedly authentic VERA BRADLEY® Goods. 

Indeed, they were not. 

57. After “Tim Morgan” admitted in communications to Vera Bradley that he had 

purchased products from China, on or about April 20, 2011, counsel for Vera Bradley sent “Tim 

Morgan” a cease and desist letter at 1615 Burning Bush Lane, Hoffman Estates, IL 60192. The 

demand letter was received and signed for by Defendant Aixin Li on April 28, 2011. 

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58. In 2012, Vera Bradley discovered that eBay seller “ahunters” was selling 

counterfeit Vera Bradley products, which Vera Bradley took action to remove through eBay’s 

VeRO program. Upon information and belief, the “ahunters” account was owned by Aixin Li. 

59. On or about June 9, 2014, a customer of “ahunters” reached out to Vera Bradley 

stating that she believed the bag she purchased “New with Tags” from “ahunters” was counterfeit. 

60. Vera Bradley ordered a Vera Bradley-branded product from “ahunters” and 

determined that the bag was counterfeit. Vera Bradley removed the listing through eBay’s VeRO 

program. 

61. Though at least 2017, Vera Bradley continued to send takedown notices to eBay 

for counterfeit products sold by “ahunters.” 

62. Upon information and belief, the return address for “ahunters” belongs to “Tim 

Morgan,” 1615 Burning Bush Lane, Hoffman Estates, IL 60192 (where, upon information and 

belief, Aixin Li, Kevin Lu, and Danny Lu reside).

63. On or about March 4, 2019, Vera Bradley sent Defendant Danny Lu a letter via 

USPS and email demanding that he cease and desist all use of the Vera Bradley’s intellectual 

property in the sale of counterfeit goods. The letter was delivered on March 6, 2019 and signed for 

by “Lu.” Vera Bradley has not received a response from Danny Lu. 

64. On or about March 5, 2019, Vera Bradley sent Defendant Xia Lu a letter via UPS 

and email demanding that she cease and desist all use of Vera Bradley’s intellectual property. 

UPS attempted to deliver the letter, but it was rerouted to Xia Lu’s local UPS store to be picked 

up. The letter was not picked up and was returned to Vera Bradley. Vera Bradley has not 

received a response to its letter to Xia Lu. 

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H. Vera Bradley Has Been and Will Continue to be Injured by Defendants’ Unlawful 

Acts. 

65. Defendants’ conduct in listing and selling counterfeit VERA BRADLEY® Goods 

through Defendants’ Seller Accounts violates the various policies of eBay, Poshmark, Facebook, 

and Mercari, as well as Vera Bradley’s intellectual property rights.

66. By selling counterfeit and infringing goods bearing the VERA BRADLEY® Marks 

without Vera Bradley’s authorization, Defendants have traded on and received the benefit of the 

goodwill that Vera Bradley has built in its brand at great effort and expense since 1982. 

67. Defendants’ sale of counterfeit and infringing goods unjustly enriched Defendants 

at Vera Bradley’s expense. 

68. Defendants’ sale of counterfeit and infringing goods impedes Vera Bradley’s 

ability to control the nature and quality of products offered for sale and sold under the VERA 

BRADLEY® Marks. 

69. Defendants’ sale of counterfeit and infringing goods bearing the VERA 

BRADLEY® Marks without Vera Bradley’s authorization caused and will continue to cause 

irreparable injury to Vera Bradley’s brand, and to the consuming public, for which there is no 

adequate remedy at law. Unless Defendants are permanently enjoined from selling counterfeit 

goods, Vera Bradley will continue to be harmed by Defendants’ willful acts. 

CLAIM I 

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

70. Paragraphs 1 through 69 are incorporated by reference herein. 

71. Defendants have used spurious designations that are identical with, or substantially 

indistinguishable from, the VERA BRADLEY® Registered Marks, on goods covered by the 

registrations for the VERA BRADLEY® Registered Marks. 

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72. Defendants’ use of the VERA BRADLEY® Registered Marks to advertise, 

promote, offer for sale, distribute, and sell counterfeit and infringing goods was and continues to 

be without the consent of Vera Bradley.

73. Defendants have used the VERA BRADLEY® Registered Marks in interstate 

commerce.

74. Defendants’ unauthorized use of the VERA BRADLEY® Registered Marks as 

outlined above is likely to cause confusion, mistake and deception or to cause the public to believe 

that Defendants’ counterfeit and infringing products are the same as the goods sold legitimately 

under the VERA BRADLEY® Registered Marks, or that Defendants are authorized, sponsored by 

or approved by Vera Bradley, or that Defendants are affiliated with or otherwise associated with 

Vera Bradley.

75. Defendants’ unauthorized use of the VERA BRADLEY® Registered Marks has 

resulted and will continue to result in Defendants unfairly benefitting from the reputation of the 

VERA BRADLEY® Registered Marks, all to the substantial and irreparable injury to the public, 

Vera Bradley, and the substantial goodwill represented by the VERA BRADLEY® Registered 

Marks. 

76. Defendants’ acts constitute trademark counterfeiting in violation of Section 32 of 

the Lanham Act, 15 U.S.C. § 1114. 

77. Defendants’ actions and conduct are knowing, intentional, willful and malicious.

78. As a result of these wrongful acts, Vera Bradley is entitled to injunctive relief 

prohibiting Defendants from using the VERA BRADLEY® Registered Marks, the VERA 

BRADLEY® Marks, or any other marks confusingly similar to these marks, in accordance with 

15 U.S.C. § 1116. 

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79. Vera Bradley is also entitled to statutory damages in the amount of up to $2,000,000 

for each mark counterfeited per type of good sold as provided by 15 U.S.C. § 1117(c), or at Vera 

Bradley’s election, an amount representing three times Vera Bradley’s damage or Defendants’ 

illicit profits, as well as reasonable attorneys’ fees, investigative fees, and pre-judgment interest 

pursuant to 15 U.S.C. § 1117(b). 

COUNT II 

(Infringement of Federally Registered Trademarks, 15 U.S.C. § 1114) 

80. Paragraphs 1 through 79 are incorporated by reference herein. 

81. Defendants’ promotion and sale of infringing goods constitutes trademark 

infringement of the VERA BRADLEY® Registered Marks in violation of the Lanham Act, 

including but not limited to 15 U.S.C. § 1114.

82. Defendants’ promotion, advertising, provision, sale, and offering for sale of 

infringing goods under the VERA BRADLEY® Registered Marks is likely to confuse, mislead, 

or deceive consumers, the public, and the trade as to the origin, source, sponsorship, or affiliation 

of said goods, and is intended and is likely to cause such parties to believe in error that the 

Defendants’ infringing goods have been authorized, sponsored, approved, endorsed, or licensed 

by Vera Bradley, or that Defendants are in some way related to or affiliated with Vera Bradley. 

83. Defendants used the VERA BRADLEY® Registered Marks without Vera 

Bradley’s consent.

84. Defendants’ use of the VERA BRADLEY® Registered Marks as described above 

has damaged and will continue to damage the goodwill Vera Bradley has built in the VERA 

BRADLEY® Registered Marks. 

85. The knowing, intentional and willful nature of Defendants’ unlawful conduct 

renders this an “exceptional case” within the meaning of 15 U.S.C. § 1117(a). 

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86. Pursuant to 15 U.S.C. §§ 1117(a) and (b), Vera Bradley is entitled to recover its 

actual damages, Defendants’ profits attributable to the infringement, and treble damages and 

attorneys’ fees. The amount of money due from Defendants to Vera Bradley is unknown to Vera 

Bradley and cannot be ascertained without a detailed accounting by Defendants of the precise 

number of units of infringing goods that have been advertised, marketed, distributed, offered for 

sale, or sold by Defendants.

87. Vera Bradley is further entitled to injunctive relief, including an order impounding 

all infringing materials because Vera Bradley has no adequate remedy at law for Defendants’ 

wrongful conduct. 

CLAIM III 

(Copyright Infringement—17 U.S.C. § 501) 

88. Paragraphs 1 through 87 are incorporated by reference herein. 

89. Vera Bradley is the sole owner of all right, title, and interest in and to the Vera 

Bradley Works, with the full and exclusive right to bring suit to enforce its copyrights and to 

recover for infringement of the same. 

90. Defendants have infringed the Vera Bradley Works by copying, distributing, 

publicly displaying, and/or selling derivative works of the Vera Bradley Works without Vera 

Bradley’s authorization. 

91. Defendants acted willfully and intentionally in this regard, or at a minimum with 

willful blindness to, or in reckless disregard of, the Vera Bradley Works. 

92. As a result, Vera Bradley is entitled to recover its actual damages and Defendants’ 

profits attributable to the infringement. In the alternative, Vera Bradley is entitled to recover 

statutory damages under 17 U.S.C. § 504(c) as the Vera Bradley Works were registered prior to 

the Defendants’ infringement or within three months of publication. 

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93. Vera Bradley is further entitled to injunctive relief, including an order impounding 

all infringing materials because Vera Bradley has no adequate remedy at law for Defendants’ 

wrongful conduct. 

CLAIM IV 

(False Designation of Origin and Unfair Competition, 15 U.S.C. § 1125(a)) 

94. Paragraphs 1 through 93 are incorporated by reference herein. 

95. Defendants’ unauthorized use in commerce of the VERA BRADLEY® Registered 

Marks is likely to cause confusion, mistake, or to deceive consumers as to the origin, sponsorship, 

or approval of infringing goods by Vera Bradley. 

96. Moreover, Defendants’ unauthorized use and misuse of Vera Bradley’s name 

and/or imitation designs (including displays, logos, icons, graphic designs, and/or packaging 

virtually indistinguishable from genuine VERA BRADLEY® Goods) in connection with 

Defendants’ commercial advertising or promotion, including in connection with the offering for 

sale and sale of infringing goods in interstate commerce, constitutes infringement under 15 U.S.C. 

§ 1125(a). 

97. Defendants have used the VERA BRADLEY® Registered Marks to compete 

unfairly with Vera Bradley and to deceive its customers. 

98. Defendants’ unauthorized use of the VERA BRADLEY® Registered Marks in the 

sale of counterfeit goods is likely to cause confusion among consumers as to the origin of goods 

bearing the VERA BRADLEY® Registered Marks, as well as to create an association between 

Vera Bradley and Defendants when no such connection exists. Such unauthorized use of the VERA 

BRADLEY® Registered Marks constitutes false designation of origin and unfair competition in 

violation of 15 U.S.C. § 1125(a). 

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99. Defendants’ unauthorized use of the VERA BRADLEY® Registered Marks 

negates the goodwill that Vera Bradley has built in its VERA BRADLEY® Registered Marks 

since its first use in 1982. 

100. As a result of Defendants’ actions, Vera Bradley has suffered and is continuing to 

suffer irreparable injury, and has incurred and is continuing to incur monetary damage in an 

amount yet to be determined. 

101. Defendants’ knowing, intentional and willful misconduct renders this an 

“exceptional case” within the meaning of 15 U.S.C. §1117(a). 

102. Pursuant to 15 U.S.C. §§ 1117(a) and (b), Vera Bradley is entitled to recover its 

actual damages, Defendants’ profits attributable to the infringement, and treble damages and 

attorneys’ fees. The amount of money due from Defendants to Vera Bradley is unknown to Vera 

Bradley and cannot be ascertained without a detailed accounting by Defendants of the precise 

number of units of infringing goods that have been advertised, marketed, distributed, offered for 

sale, or sold by Defendants. 

103. As a result of these wrongful acts, Vera Bradley is entitled to injunctive relief 

prohibiting the Defendants from using the VERA BRADLEY® Registered Marks or any other 

marks confusingly similar to these marks, in accordance with 15 U.S.C. § 1116. 

COUNT V 

(Deceptive Trade Practices, 815 ILCS 510) 

104. Paragraphs 1 through 103 are incorporated by reference herein. 

105. Defendants represented that the infringing goods were those of Vera Bradley, or 

sponsored or approved by Vera Bradley, thereby creating a likelihood of confusion or 

misunderstanding as to the source of Defendants infringing products, in violation of Section 2 of 

the Uniform Deceptive Trade Practices Act. 

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106. As a result of Defendants’ actions, Vera Bradley has suffered and is continuing to 

suffer irreparable injury, and has incurred and is continuing to incur monetary damage in an 

amount yet to be determined. 

107. As a result of Defendants’ actions, Vera Bradley is entitled to attorneys’ fees 

pursuant to 815 ILCS 510. 

COUNT VI 

(Common Law Unfair Competition) 

108. Paragraphs 1 through 107 are incorporated by reference herein. 

109. Defendants’ unauthorized use of the VERA BRADLEY® Registered Marks and 

other confusingly similar marks in the sale of infringing goods created an association in the minds 

of consumers between Defendants and Vera Bradley when no such connection exists. 

110. Defendants usurped the goodwill that Vera Bradley has built up in its VERA 

BRADLEY® Registered Marks over the years and benefited therefrom in the sale of counterfeit 

goods. 

111. Defendants’ conduct constitutes unfair competition in violation of Vera Bradley’s 

rights under the common law. 

112. As a result of Defendants’ actions, Vera Bradley has suffered and is continuing to 

suffer irreparable injury, and has incurred and is continuing to incur monetary damage in an 

amount yet to be determined. 

113. Defendants’ acts were taken in willful, knowing, deliberate and/or intentional 

disregard of Vera Bradley’s rights. 

PRAYER FOR RELIEF 

WHEREFORE, Vera Bradley requests that the Court provide the following relief against 

Defendants: 

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A. Enter an order permanently and preliminarily enjoining and restraining Defendants, 

their related companies, their officers, agents, representatives, servants, employees, successors and 

assigns, and immediate family members, and all others acting in active concert or participation 

with them from: 

1. advertising, marketing, distributing, offering for sale, or selling any 

counterfeit goods bearing the VERA BRADLEY® Registered Marks, any 

confusingly similar marks, or otherwise infringe Vera Bradley’s intellectual 

property; 

2. assisting, aiding or abetting any other person or business entity engaged in 

or performing any of the activities referred to in subparagraph 1 above; 

B. Enter judgment in Vera Bradley’s favor on all claims brought by it; 

C. Enter an order pursuant to 15 U.S.C. § 1116 and/or 17 U.S.C. § 503 impounding 

all counterfeit and infringing goods bearing any of the VERA BRADLEY® Registered Marks or 

that otherwise infringe Vera Bradley’s copyright in the Vera Bradley Works, and any related item, 

including business records, that are in Defendants’ possession or under their control; 

D. Enter an order requiring Defendants to provide Vera Bradley a full and complete 

accounting of all infringing, and counterfeit sales of Vera Bradley® Goods made by Defendants 

over the last six years and the amounts due and owed to Vera Bradley as a result of Defendants’ 

unlawful actions; 

E. Enter an order requiring Defendants to pay all general, special, investigative, actual, 

and statutory damages which Vera Bradley has sustained, or will sustain, as a consequence of 

Defendants’ lawful acts, and that such damages be enhanced, doubled, or trebled as provided for 

by 15 U.S.C. §1117(b), or otherwise allowed by law; 

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F. Enter an order awarding Vera Bradley its reasonable attorneys’ fees, costs, and 

disbursements incurred in this action; and 

G. Enter an order awarding Vera Bradley such other and further relief as this Court 

deems just and proper. 

DEMAND FOR JURY TRIAL 

Plaintiff, by counsel, respectfully requests a jury trial for all issues deemed triable. 

Respectfully submitted, 

Dated: April 27, 2020 LATHROP GPM, LLP 

By: s/ Michael R. Gray 

Michael R. Gray (IL Bar # 90785222) 

Molly R. Littman* (MN Bar # 0398449) 

500 IDS Center 

80 South 8th Street 

Minneapolis, MN 55402 

Phone: 612-632-3000 

Fax: 612-632-4444 

michael.gray@lathropgpm.com

molly.littman@lathropgpm.com 

*Pro Hac Vice Application to be Submitted 

JACOVER LAW LLC 

Aric S. Jacover (IL Bar No. 6277709) 

990 Grove, Suite 402 

Evanston, IL 60201 

Phone: 312-569-0434 

aric@jacoverlaw.com

Attorneys for Vera Bradley Designs, Inc.

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