IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

Halo Acoustic Wear LLC )

)

v. ) Case No. 20-cv-4248

) 

THE PARTNERSHIPS and ) Judge: 

UNINCORPORATED ASSOCIATIONS )

IDENTIFIED ON SCHEDULE “A,” ) Magistrate: 

) 

)

)

COMPLAINT

Plaintiff Halo Acoustic Wear LLC (“Halo”) hereby files this Complaint for, inter alia, 

trademark infringement, counterfeiting, copyright infringement and related claims against 

Defendants, on personal knowledge as to Plaintiffs’ own activities and on information and belief 

as to the activities of others:

The Parties

1. Halo Acoustic Wear LLC is a Delaware Limited Liability Company that maintains its 

principal place of business at 43300-116 Southern Walk Plaza #631, Broadlands, VA 20148.

2. Defendants identified on Schedule “A” are all believed to be individuals and 

unincorporated business associations who, upon information and belief, reside in foreign 

jurisdictions. The true names, identities and addresses of Defendants are currently unknown.

3. Defendants conduct their illegal operations through fully interactive commercial 

websites registered with registrars in the United States and other foreign jurisdictions 

(“Infringing Websites”). Each Defendant targets consumers in the United States, including the 

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State of Illinois, and has offered to sell and, on information and belief, has sold and continues to 

sell infringing products that violate Plaintiff’s intellectual property rights to consumers within the 

United States, including the State of Illinois and Northern District of Illinois. Defendants have 

the capacity to be sued pursuant to Federal Rule of Civil Procedure 17(b).

4. Through their operation of the Infringing Websites, Defendants are directly and 

personally contributing to, inducing and engaging in the sale of infringing products as alleged, 

often times as partners, co-conspirators and/or suppliers. Upon information and belief, 

Defendants are an interrelated group of counterfeiters working in active concert to knowingly 

and willfully manufacture, import, distribute, offer for sale, and sell infringing products. 

Defendants intentionally conceal their identities and the full scope of their counterfeiting 

operations in an effort to deter Plaintiff from learning Defendants’ true identities and the exact 

interworking of Defendants’ illegal counterfeiting operations. The identities of these Defendants 

are presently unknown. If their identities become known, Plaintiff will promptly amend this 

Complaint to identify them.

Jurisdiction and Venue

5. This is an action for trademark counterfeiting and trademark infringement, and unfair 

competition and false designation of origin arising under the Trademark Act of 1946, 15 U.S.C. 

§§ 1051, et seq., as amended by the Trademark Counterfeiting Act of 1984, Public Law 98-473 

(October 12, 1984), the Anti-Counterfeiting Consumer Protection Act of 1996, Pub. L. 104-153 

(July 2, 1996), and the Prioritizing Resources and Organization for Intellectual Property Act of 

2007, H.R. 4279 (October 13, 2008) (the "Lanham Act"), copyright infringement pursuant to the 

Copyright Act of 1976, 17 U.S.C. § 101, et seq. and for unlawful and deceptive acts and 

practices under the laws of the State of Illinois.

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6. This Court has original jurisdiction over this action pursuant to 28 U.S.C. §§ 1331, 

1332 and 1338(a) and (b); and 15 U.S.C. §§ 1116 and 1121. This Court has jurisdiction, pursuant 

to the principles of supplemental jurisdiction and 28 U.S.C. § 1367, over Plaintiffs’ claims for 

unlawful and deceptive acts and practices under the laws of the State of Illinois.

7. This Court has personal jurisdiction over Defendants in that they transact business in 

the State of Illinois and in the Northern District of Illinois.

8. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391 in that the Defendants 

are entities or individuals subject to personal jurisdiction in this District. Venue is also proper in 

this District because a substantial part of the events or omissions giving rise to the claims 

occurred in this District and Defendants directly target business activities towards consumers in 

the State of Illinois.

Background Facts

9. Plaintiff is engaged in the business of manufacturing, distributing and audio products, 

including the CozyPhones headband-earphones for children, including within the Northern 

District of Illinois District (collectively, “CozyPhones”) under the Federally registered 

trademarks identified in Paragraph 10, below. The Plaintiff’s products feature a highly distinctive 

designs for children which are identified with Defendants’ sales of infringing products in 

violation of Plaintiff’s intellectual property rights are irreparably damaging Plaintiff.

10. Plaintiff is the owner of all rights, title and interest in and to, inter alia, the 

COZYPHONES (U.S. Reg. No. 5486943) Mark. The registration is valid, subsisting, unrevoked,

uncancelled, and incontestable pursuant to 15 U.S.C. § 1065. The registration for the CozyPhone 

mark constitutes prima facie evidence of validity and of Plaintiff’s exclusive right to use the 

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CozyPhone mark pursuant to 15 U.S.C. § 1057(b). Plaintiff also owns common law rights in 

these and other marks for use in connection with bridal gowns and formalwear. 

Additionally, the product trade dress features whimsical designs of mystical creatures and 

animals, such as unicorns, frogs, lions, cats, foxs, pirates, sharks, and pandas. A genuine and 

authentic copy of the U.S. federal trademark registration certificate for the COZYPHONE Mark 

and samples of the Plaintiff’s trade dress are attached as Exhibit 1.

11. Plaintiff’s brands, symbolized by the COZYPHONE Mark and distinctive trade dress, 

are recognized symbols of high-quality children’s acoustic products throughout the world. As 

detailed below, Plaintiff has been using the COZYPHONE Mark and trade dress for many years 

in connection with the advertising and sale of CozyPhone Products in interstate and foreign 

commerce, including commerce in the State of Illinois and the Northern District of Illinois.

12. The COZYPHONE Mark has been widely promoted, both in the United States and 

throughout the world, and is a well-known source of quality children’s acoustic products. 

Consumers, potential consumers and other members of the public and not only associate 

CozyPhone products with exceptional materials, style and workmanship, but also recognize that 

CozyPhone products sold in the United States originate exclusively with Plaintiff.

13. Through its widespread use and promotion, Halo has achieved extensive common law 

rights in its trade dress in connection with children’s headphones.

14. Plaintiff maintains quality control standards for all CozyPhone Products. Genuine 

CozyPhone Products are distributed through a worldwide network of distributors and retailers, as 

well as Plaintiff’s primary website located at CozyPhone.com (“Website”). Sales of CozyPhone 

Products via the Website represent a significant portion of Plaintiff’s business. The Website 

features proprietary content, images and designs exclusive to Plaintiff.

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15. The CozyPhone Mark is highly visible and distinctive worldwide symbol of 

excellence in quality and uniquely associated with Plaintiff and, as a result, CozyPhone Products 

bearing the CozyPhone Mark have generated millions of dollars of sales over the years.

16. The CozyPhone Mark and trade dress have never been assigned or licensed to any of 

the Defendants in this matter.

17. The CozyPhone Mark and trade dress are a symbol of Plaintiff’s quality, reputation 

and goodwill and have never been abandoned.

18. Further, Plaintiff has expended substantial time, money and other resources 

developing, advertising and otherwise promoting the CozyPhone Mark and trade dress. 

19. Upon information and belief, at all times relevant hereto, Defendants in this action 

have had full knowledge of Plaintiff’s ownership of the CozyPhone Mark and distinctive trade 

dress, including exclusive right to use and license such intellectual property and the goodwill 

associated therewith.

20. In or around 2019, Plaintiff identified the CozyPhone Mark and/or trade dress on the 

Infringing Websites designed to resemble authorized retail Internet stores selling genuine 

CozyPhone Products that Defendants had reproduced, displayed and distributed without 

authorization or license from Plaintiff in violation of the CozyPhone Mark.

21. Defendants’ use of the CozyPhone Mark and/or trade dress on or in connection with 

the advertising, marketing, distribution, offering for sale and sale of the infringing products is 

likely to cause and has caused confusion, mistake and deception by and among consumers and is 

irreparably harming Plaintiff.

22. Plaintiff is the owner of all right, title and interest in and to United States Copyright 

Registration Nos. VAu- 1-363-557, VAu- 1-353-649, VAu- 1-353-335, VAu- 1-353-729, VAuCase: 1:20-cv-04248 Document #: 1 Filed: 07/19/20 Page 5 of 16 PageID #:5
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1-353-724, VAu- 1-353-718, VAu- 1-353-710, VAu- 1-353-875, VAu- 1-353-343, (“Halo

Copyrights”). The aforementioned registrations are valid, subsisting, unrevoked and uncancelled. 

Plaintiff also owns common law rights in these and other copyrights for use in connection with 

bridal gowns and formalwear. A genuine and authentic copy of the U.S. federal copyright 

registration certificate for the above-listed Halo Copyrights is attached hereto as Exhibit 2.

23. Among the exclusive rights granted to Plaintiff under the Copyright Act are the 

exclusive rights to use and reproduce photographs protected by the Halo Copyright and to 

distribute these photographs to the public.

24. In or around 2019, Plaintiff identified photographic images on the Infringing 

Websites that Defendants had reproduced, displayed and distributed without authorization or 

license from Plaintiff (“Infringing Images”) in violation of the Halo Copyrights.

25. The Infringing Images Defendants reproduced, displayed and distributed on 

Defendants’ Infringing Websites are the subject of the Halo Copyrights.

26. Defendants have manufactured, imported, distributed, offered for sale and sold 

infringing products, including bridal gowns and formalwear using the CozyPhone mark and 

protected images in violation of the Halo Copyrights and continue to do so.

27. Defendants, without authorization or license from Plaintiff, knowingly and willfully 

used and continue to use the CozyPhone Mark and trade dress in connection with the 

advertisement, offer for sale and sale of the infringing products, through, inter alia, the Internet. 

The infringing products are not genuine CozyPhone Products. The Plaintiff did not manufacture, 

inspect or package the infringing products and did not approve the infringing products for sale or 

distribution. Each Infringing Website offers shipping to the United States, including Illinois, and, 

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on information and belief, each Defendant has sold infringing products into the United States, 

including Illinois.

28. Defendants falsely advertise the sale of CozyPhone products through the Infringing 

Websites by stealing and copying Plaintiff’s copyrighted images and photographs of Plaintiff’s 

genuine products in violation of the Halo Copyrights. Furthermore, the Infringing Websites offer 

live online service and display normal indicia of security protection that would appear on 

legitimate websites, including the McAfee® Security, VeriSign®, Visa®, MasterCard®, and 

PayPal® logos. Defendants’ Infringing Websites appear to unknowing consumers to be 

legitimate web stores authorized to sell genuine CozyPhone products.

29. Defendants also deceive unknowing consumers by using the CozyPhone mark

without authorization within the content, text, and/or meta tags of the Infringing Websites in 

order to attract various search engines crawling the Internet looking for websites relevant to 

consumer searches for CozyPhone products. Additionally, upon information and belief, 

Defendants use other unauthorized search engine optimization (SEO) tactics so that listings for 

the Infringing Websites appear at or near the top of relevant search results and misdirect 

consumers searching for genuine CozyPhone products. Furthermore, Defendants utilize similar 

illegitimate SEO tactics to propel new domain names to the top of search results after others are 

disabled. As such, Plaintiff also seeks to disable the Infringing Websites owned and operated by 

Defendants that are the means by which the Defendants could continue to sell infringing 

products.

30. Defendants go to great lengths to conceal their true identities and often use multiple 

fictitious names and addresses to register and operate the Infringing Websites. For example, 

many of Defendants’ names and physical addresses used to register the Infringing Websites are 

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incomplete, contain randomly typed letters, or fail to include cities or states. Other Infringing 

Websites use privacy services that conceal the owners’ identity and contact information. Upon 

information and belief, Defendants regularly create new websites on various platforms using the 

identities listed in Schedule “A” to the Complaint, as well as other unknown fictitious names and 

addresses. 

31. Plaintiff has no adequate remedy at law.

COUNT ONE

FEDERAL TRADEMARK INFRINGEMENT

(15 U.S.C. §1114)

32. The Plaintiff repeats and realleges the foregoing allegations above as if fully set forth 

herein.

33. The Plaintiff’s mark and the goodwill of the business associated with it in the United 

States and throughout the world are of great and incalculable value. The mark is highly 

distinctive and has become universally associated in the public mind with Plaintiffs’ Products 

and related services. Consumers associate the Plaintiff’s mark with the Plaintiff as the source of 

the very highest quality products.

34. Without the Plaintiff’s authorization or consent, and having knowledge of the 

Plaintiff’s well-known and prior rights in the Plaintiff’s mark and the fact that Defendants’

infringing products are sold using marks which is identical or confusingly similar to the 

Plaintiff’s mark, the Defendants have manufactured, distributed, offered for sale and/or sold the 

infringing products to the consuming public in direct competition with Plaintiff’s sale of genuine 

Plaintiff products, in or affecting interstate commerce.

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35. Defendants’ use of copies or approximations of the Plaintiff’s mark in conjunction 

with Defendant’s infringing products is likely to cause and is causing confusion, mistake and 

deception among the general purchasing public as to the origin of the infringing products, and is 

likely to deceive the public into believing the infringing products being sold by Defendants 

originate from, are associated with or are otherwise authorized by the Plaintiff, all to the damage 

and detriment of the Plaintiff’s reputation, goodwill and sales.

36. The Plaintiff has no adequate remedy at law and, if Defendants’ activities are not 

enjoined, the Plaintiff will continue to suffer irreparable harm and injury to its goodwill and 

reputation.

COUNT TWO

TRADEMARK INFRINGEMENT, TRADE DRESS INFRINGEMENT, UNFAIR 

COMPETITION AND FALSE DESIGNATION OF ORIGIN

(15 U.S.C. §1125(a))

37. The Plaintiff repeats and realleges the foregoing allegations above as if fully set forth 

herein.

38. The infringing products sold and offered for sale by Defendants are of the same 

nature and type as the Plaintiff’s products sold and offered for sale by the Plaintiff and, as such, 

Defendants’ use is likely to cause confusion to the general purchasing public.

39. By misappropriating and using the Plaintiff’s marks, trade dress, genuine product 

images and trade names, Defendants misrepresent and falsely describe to the general public the 

origin and source of the infringing products and create a likelihood of confusion by consumers as 

to the source of such merchandise.

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40. Defendants’ unlawful, unauthorized and unlicensed manufacture, distribution, offer 

for sale and/or sale of the infringing products creates express and implied misrepresentations that 

the infringing products were created, authorized or approved by the Plaintiff, all to Defendants’

profit and to the Plainitiff’s great damage and injury.

41. Defendants’ aforesaid acts are in violation of Section 43(a) of the Lanham Act, 15 

U.S.C. § 1125(a), in that Defendants’ use of the Plaintiff’s mark, trade dress, genuine product 

images and trade names, in connection with their goods and services in interstate commerce, 

constitutes a false designation of origin and unfair competition.

42. The Plaintiff has no adequate remedy at law and, if the Defendants’ activities are not 

enjoined, Plaintiffs will continue to suffer irreparable harm and injury to their goodwill and 

reputation.

COUNT THREE

COPYRIGHT INFRINGEMENT (17 U.S.C. § 501)

43. The Plaintiff repeats and realleges the foregoing allegations above as if fully set forth 

herein.

44. Plaintiff has complied with the registration requirements of 17 U.S.C. § 411(a) in 

obtaining the Copyrights.

45. At all times relevant hereto, Plaintiff has been producer and sole owner of the original 

photographic images that are the subject of this action and protected by the Copyrights. Among 

the rights granted to Plaintiff is the exclusive right to market and sublicense the right to copy, 

reproduce and display the image. Additionally, Plaintiff is granted the exclusive right to make 

and control claims related to infringements of copyrights in the image.

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46. Defendants have intentionally reproduced, displayed, distributed and made other 

infringing uses of the protected image, without authorization by Plaintiff.

47. As a result of its conduct, Defendants are liable to Plaintiff for copyright 

infringement.

48. Defendants knew their acts constituted copyright infringement and Defendant's 

conduct was willful within the meaning of the Copyright Act.

49. As a result of their wrongful conduct, Defendants are liable to Plaintiff for copyright 

infringement pursuant to 17 U.S.C. § 501. Plaintiff has suffered, and will continue to suffer, 

substantial losses, including but not limited to damage to its business reputation and goodwill.

50. Plaintiff is entitled to recover damages, which include its losses and any and all 

profits Defendants have made as a result of its wrongful conduct. 17 U.S.C. § 504. Alternatively, 

Plaintiff is entitled to statutory damages under 17 U.S.C. § 504(c).

51. In addition, because Defendants’ infringement was willful, the award of statutory 

damages should be enhanced in accordance with 17 U.S.C. § 504(c)(2).

COUNT FOUR

ILLINOIS UNIFORM DECEPTIVE TRADE PRACTICES (815 ILCS 510)

52. The Plaintiff repeats and realleges the foregoing allegations above as if fully set forth 

herein.

53. The infringing products sold and offered for sale by Defendants are of the same 

nature and type as the Plaintiff’s products sold and offered for sale by the Plaintiff and, as such, 

Defendants’ use is likely to cause confusion to the general purchasing public.

54. By misappropriating and using the Plaintiff’s mark, genuine product images and trade 

names, Defendants misrepresent and falsely describe to the general public the origin and source 

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of the infringing products and create a likelihood of confusion by consumers as to the source of 

such merchandise.

55. Defendants’ unlawful, unauthorized and unlicensed manufacture, distribution, offer 

for sale and/or sale of the infringing products creates express and implied misrepresentations that 

the infringing products were created, authorized or approved by the Plaintiff, all to the 

Defendants’ profit and to the Plaintiff’s great damage and injury.

56. Defendants’ aforesaid acts are in violation of the Illinois Uniform Deceptive Trade 

Practices Act, 815 ILCS 510/2 et seq., in that Defendants’ use of the Plaintiff’s mark, genuine

product images and trade names, in connection with their goods and services in interstate 

commerce, constitutes a false designation of origin and unfair competition.

57. Plaintiffs have no adequate remedy at law and, if the Defendants’ activities are not 

enjoined, the Plaintiff will continue to suffer irreparable harm and injury to its goodwill and 

reputation.

Prayer for Relief

WHEREFORE, the Plaintiff prays for judgment against Defendants in favor of the 

Plaintiff on all counts as follows:

1. That Defendants, their officers, agents, servants, employees, attorneys, confederates,

and all persons in active concert with them be temporarily, preliminarily and permanently 

enjoined and restrained from:

(i) using the Plaintiff’s marks or any reproduction, counterfeit, copy or colorable 

imitation of the Plaintiff’s mark in connection with the distribution, advertising, offer for 

sale and/or sale of merchandise not the genuine products of the Plaintiff; and

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(ii) passing off, inducing or enabling others to sell or pass off any Counterfeit

Products as genuine products made and/or sold by the Plaintiff; and

(iii) committing any acts calculated to cause consumers to believe that Defendants’ 

infringing products are those sold under the authorization, control, or supervision of 

Plaintiff, or are sponsored by, approved by, or otherwise connected with Plaintiff;

(iv) further infringing the Plaintiff's mark and damaging Plaintiff’s goodwill;

(v) competing unfairly with Plaintiff in any manner;

(vi) shipping, delivering, holding for sale, distributing, returning, transferring or 

otherwise moving, storing or disposing of in any manner products or inventory not 

manufactured by or for Plaintiff, nor authorized by Plaintiff to be sold or offered for sale, 

and that bear the CozyPhone mark or any reproductions, counterfeit copies, or colorable 

imitations thereof;

(vii) using, linking to, transferring, selling, exercising control over, or otherwise owning 

or operating the Infringing Websites, or any other domain name that is being used to sell 

or is the means by which Defendants could continue to sell infringing products;

(viii) operating and/or hosting websites at the Infringing Websites and any other domain 

names registered or operated by Defendants that are involved with the distribution, 

marketing, advertising, offering for sale, or sale of any product bearing the Plaintiff's 

mark or any reproduction, counterfeit copy or colorable imitation thereof that is not a 

genuine product or not authorized by Plaintiff to be sold in connection with the Plaintiff's 

mark; and,

(ix) registering any additional domain names that use or incorporate any of the Plaintiff's 

marks; and

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2. That Defendants, their affiliates, officers, agents, servants, employees, attorneys, 

confederates, and all persons acting for, with, by, through, under, or in active concert with them 

be temporarily, preliminarily, and permanently enjoined and restrained from:

(i) displaying images protected by the Plaintiff's Copyright in connection with the 

distribution, advertising, offer for sale and/or sale of any product that is not a genuine 

Plaintiff Product or is not authorized by Plaintiff to be sold in connection with the 

Plaintiff's Copyright; and

(ii) shipping, delivering, holding for sale, distributing, returning, transferring or otherwise 

moving, storing or disposing of in any manner products or inventory not manufactured by 

or for Plaintiff, nor authorized by Plaintiff to be sold or offered for sale, and protected by 

the Plaintiff's Copyright or any reproductions, counterfeit copies, or colorable imitations 

thereof; and,

3. That Defendants, within ten days after service of judgment with notice of entry thereof 

upon them, be required to file with the Court and serve upon the Plaintiff’s a written report under 

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

injunctive relief ordered by this Court.

4. Entry of an order that, upon Plaintiff’s request, those in privity with Defendants and 

those with notice of the injunction, including any Internet search engines, Web hosts, domainname registrars and domain-name registries or their administrators that are provided with notice 

of the injunction, cease facilitating access to any or all domain names and websites through 

which Defendants engage in the sale of infringing products using the Plaintiff's mark;

5. Entry of an order canceling or, at Plaintiff’s election, transferring the Infringing 

Websites and any other domain names used by the Defendants to engage in their counterfeiting 

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of the Plaintiff's mark at issue to Plaintiff’s control so they may no longer be used for illegal 

purposes;

6. That Defendants account for and pay over to Plaintiff any and all profits realized by 

Defendants by reason of Defendants’ unlawful acts herein alleged, and that the amount of 

damages for infringement of the CozyPhone mark be increased by a sum not exceeding three 

times the amount thereof as provided by law as provided by 15 U.S.C. § 1117;

7. In the alternative, that Plaintiff be awarded statutory damages of Five-Hundred 

Thousand Dollars (U.S.) and No Cents ($500,000.00) for each and every use of the Plaintiff's 

mark counterfeited by each Defendant;

8. That the Court enter an order of impoundment pursuant to 17 U.S.C. §§ 503 and 509(a) 

impounding all infringing copies of Plaintiff’s audiovisual works, photographs or other materials 

protected by the Copyright, which are in Defendants’ possession or under its control;

9. That the Court enter an order, pursuant to 17 U.S.C. § 504(b), declaring that 

Defendants hold in trust, as constructive trustees for the benefit of Plaintiff, all profits received 

by defendant from its reproduction, distribution, display or other infringing uses of the 

photographic images protected by the Plaintiff's Copyright, and requiring Defendants to provide 

Plaintiff a full and complete accounting of all profits received by Defendants;

10. That the Court order Defendants to pay damages to Plaintiff, including an award of 

actual damages suffered by Plaintiff, as a result of the infringements and all profits of defendant 

that are attributable to those infringements, pursuant to 17 U.S.C. § 504(b);

11. That Plaintiff be awarded its reasonable attorneys’ fees and costs; and,

12. Grant Plaintiff such other and further legal relief as may be just and proper.

Respectfully submitted,

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By: s/David Gulbransen

David Gulbransen 

Attorney of Record

David Gulbransen (#6296646)

Law Office of David Gulbransen

805 Lake Street, Suite 172

Oak Park, IL 60302

(312) 361-0825 p.

(312) 873-4377 f.

david@gulbransenlaw.com

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