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UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

George & Company LLC, a New 

York limited liability company, 

 ) 

) 

 ) 

 Plaintiff, ) 

 ) Case No. 20-cv-04673 

v. ) 

 ) 

Daniel Bekavac, an individual, 

Bekavac Trading Company, Inc., an 

Illinois corporation, and various 

John Does, Jane Does and ABC 

Companies, 

 ) 

) 

) 

) 

) 

 ) 

 Defendants, ) 

Complaint 

Plaintiff George & Company LLC (“Plaintiff” or “George & Company”), by and through its 

undersigned counsel., hereby brings this Complaint against Defendants Daniel Bekavac, Bekavac 

Trading Company, Inc., and various John Does, Jane Does and ABC Companies (collectively, 

“Defendants”) and alleges as follows: 

Nature of the Action 

1. Plaintiff, a world-renowned game company and the owner and distributor of the award winning 

LCR® and LCR LEFT! CENTER! RIGHT!® dice game, files this Complaint against Defendants 

for trademark infringement, federal false designation of origin, passing off, and unfair 

competition under the Lanham Act, copyright infringement, and violation of the Illinois 

Uniform Deceptive Trade Practices Act. 

Parties 

2. Plaintiff George & Company is a limited liability company which is organized under the laws of 

New York. 

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3. Defendant Daniel Bekavac, President and CEO of Defendant Bekavac Trading, Inc., upon 

information and belief, and is a conscious, active, and dominant force behind the illegal acts of 

the Defendants set forth herein and acted in concert with the other Defendants to cause the 

wrongs which are the subject of this action. 

4. Defendant Bekavac Trading Company, Inc., (“BTC”) d/b/a “Bek Brands” is a corporation 

organized under the laws of the State of Illinois with its principal place of business in Crest Hill, 

Illinois. At all relevant times, Defendant BTC was and is so controlled by Defendant Daniel 

Bekavac that Defendant BTC was a mere instrumentality of Defendant Daniel Bekavac. 

5. Defendants claim to be a “wholesaler phenomena” and operate a website at 

www.bekavactrading.com and bekbrands.com wherein Defendants offer, sell and distribute a 

multitude of products. 

6. Defendants various John Does, Jane Does and ABC Companies, upon information and belief, 

are individuals and/or business entities who, along with the other herein named Defendants, 

have engaged in the unauthorized and illegal acts complained of herein. The identities of these 

unnamed Defendants and the details of their legal associations with the named Defendants 

herein presently are not and cannot be known to Plaintiff, in large part because they have 

concealed their identities from public disclosure. 

7. Upon information and belief, all Defendants, either individually and/or acting by and through 

their principals, officers, agents, employees and other active, conscious and dominant forces 

behind their activities have committed the acts complained of herein in interstate commerce. 

Jurisdiction and Venue 

8. This Court has subject matter jurisdiction over Plaintiff’s claims pursuant to 28 U.S.C. §§ 1331, 

1338 (for claims arising under the Lanham Act and the U.S. Copyright Act). 

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9. This Court has jurisdiction over the claims herein arising under the laws of the State of Illinois 

pursuant to 28 U.S.C. § 1338(b), 28 U.S.C. § 1367(a), because the state law claims are so related 

to the federal claims that they form part of the same case or controversy and derive from a 

common nucleus of operative facts. 

10. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391(b)(1), (b)(2), and 1400(a), and this 

Court may properly exercise personal jurisdiction over Defendants, because: (i) this is a judicial 

district in which at least Defendants BTC and Daniel Bekavac reside; and (ii) this is a judicial 

district in which a substantial part of the events or omissions giving rise to Plaintiff’s claims 

occurred including, without limitation, Defendants’ infringements of Plaintiff’s protected 

trademarks and copyrights within this judicial district. 

Plaintiff and its Popular LCR® and LCR LEFT! CENTER! RIGHT!® Dice Games 

11. Plaintiff George & Company is a highly respected, fourth generation family owned business, and 

the original innovator and maker of the authentic, popular, award-winning LCR® and LCR 

LEFT! CENTER! RIGHT!® dice game. Plaintiff George & Company alone invented and 

created this worldwide best-selling game, known and loved by consumers of all ages and walks 

of life. 

12. Plaintiff George & Company’s products are well known to the public, iconic and highly 

recognizable, including the following familiar examples: 

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13. Plaintiff George & Company has marketed and sold dice, dice games, party games, board games, 

card games, and/or related entertainment products to the public for more than a century, with 

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the LCR® and LCR LEFT! CENTER! RIGHT!® dice game being its most popular and 

successful game. 

14. Plaintiff George & Company’s efforts and accomplishments have made it a well-known and 

recognized name in the game and related entertainment product industries. George & Company 

has earned its enviable reputation as a result of its commitment to providing the highest quality 

goods and products. 

15. Plaintiff George & Company’s LCR® and LCR LEFT! CENTER! RIGHT!® dice game is 

distributed and sold throughout the United States and abroad under one or more of George & 

Company’s Marks including the LCR® and LCR LEFT! CENTER! RIGHT!® brands. 

16. Plaintiff George & Company’s LCR® and LCR LEFT! CENTER! RIGHT!® dice game is a bestselling product, with multiple millions of units of the game having been sold by Plaintiff. 

17. Plaintiff George & Company’s LCR® and LCR LEFT! CENTER! RIGHT!® dice game is 

exceedingly popular and commercially successful. Plaintiff George & Company’s game has been 

featured on, among many others, the “Rachael Ray Show” and televised nationally on the ABC 

television network as well as featured at www.rachaelrayshow.com. The well-known TDmonthly 

Magazine®, a trade magazine for the toy, hobby, game and gift industry, has listed George & 

Company’s game as one of the “Top 10 Most Wanted Games,” and retailers often identify 

George & Company’s dice game as their “No. 1” and “biggest” seller. 

18. As a result of Plaintiff George & Company’s unceasing and wildly successful efforts, the LCR®

and LCR LEFT! CENTER! RIGHT!® dice game has been known and loved throughout the 

world for decades, by people of all ages. For over a century, George & Company is and has been 

a highly respected and family owned business, having invented, created, manufactured, launched 

and continuously supplied one of the most successful games in history. George & Company has 

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done this all within the same, longstanding, family business which dedicates itself to this high 

quality and original and authentic game. 

19. As a result of decades of hard work and dedication, Plaintiff George & Company’s LCR® and 

LCR LEFT! CENTER! RIGHT!® original and authentic dice game has become a classic. 

20. George & Company’s high-quality game remains today, as it has always been, the one and only 

original authentic LCR® and LCR LEFT! CENTER! RIGHT!® dice game. 

Plaintiff’s Trademark Rights 

21. George & Company LLC is the owner of all right, title and interest in and to the trademarks set 

forth below, among many others: 

Reg. No. Trademark Reg. No. Trademark 

2,802,321 4,119,570 

2,989,658 LCR 4,132,929 LCR 

3,801,144 4,201,291 

3,854,443 PLAY LCR WITH CHIPS OR 

WHATEVER MAKES IT 

FUN FOR YOU 

4,229,002 

3,917,337 LCR 4,419,874 LCR WILD 

3,917,401 LCR 4,519,607 LEFT, CENTER, OR RIGHT – 

DON’T 

LOSE YOUR CHIPS! 

3,922,749 PLAY LCR WITH CHIPS OR 

WHATEVER MAKES IT 

FUN FOR YOU 

4,519,608 

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4,002,630 5,091,343 

4,006,384 LCR 5,091,344 LEFT, CENTER, OR RIGHT – 

DON’T 

LOSE YOUR CHIPS! 

4,053,314 

as well as many other related marks, including common law marks, all with longstanding and 

prior use, covering a variety of goods and services, including without limitation dice games, party 

games and board games featuring specially marked dice and chips, and many related goods and 

services (hereinafter, collectively referred to as the “LCR Marks”). True and correct copies of 

the registration certificates of the LCR Marks are attached hereto as Exhibit A. 

22. The LCR Marks are well-known to the public, legally valid, and subsisting, and owned 

exclusively by Plaintiff. 

23. Plaintiff George & Company’s dice game has been widely advertised and extensively offered for 

sale under the LCR Marks. As a result of George & Company’s widespread and extensive use of 

the LCR Marks, and the public’s widespread and favorable acceptance and recognition of them, 

the LCR Marks have become assets of substantial value as a symbol of George & Company, its 

quality goods, goodwill, and reputation. 

24. Plaintiff George & Company enjoys considerable success and an enviable reputation in its 

industry and trade due in large part to its use of, and rights in, the LCR Marks. 

25. Plaintiff George & Company has invested significant resources advertising and promoting its 

dice game using the LCR Marks in order to achieve the success it now enjoys. As a result of 

George & Company’s investment, the LCR Marks have become synonymous with high-quality 

goods in its industry and related fields. George & Company’s dice game has become well known 

and is in great demand throughout the U.S. and the world. 

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26. Plaintiff George & Company’s Marks have been extensively and continuously advertised and 

promoted to the public through various means, including, but not limited to, appearances at toy 

shows, displays in retail stores, and on the internet. Further, George & Company’s game and the 

LCR Marks have received unsolicited third-party recognition and acclaim. 

27. As a result of such advertising and attention, the public has come to recognize Plaintiff George 

& Company’s dice game bearing the LCR Marks as originating solely from George & Company. 

Plaintiff’s Copyrights 

28. George & Company LLC is the owner of all right, title and interest in and to the copyrights in 

the following (the “LCR Works”), among others: 

Reg. No. Title Deposit 

TX 3-437-323 L-C-R- Game Rules 

VA 1-786-004 Chasing Arrows 

VAu 1-358-243 George & Company LLC Four Tubes 

Color Photograph 

VAu 1-365-197 George & Company LLC Color Rendering 

and Line Drawing Four Tubes 

True and correct copies of the registration certificates for the LCR Works are attached hereto as 

Exhibit B. 

Defendants’ Unlawful Conduct 

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29. On or about April 2019, Defendants applied with Plaintiff to become an authorized reseller of 

Plaintiff’s LCR® products. A true and correct copy of that application is attached hereto as 

Exhibit C. Defendants’ application was declined. 

30. Defendants nevertheless and without authorization caused to be produced in China and shipped 

into this judicial district at least 20,000 counterfeit and infringing sets of Plaintiff’s famous LCR 

game which bear counterfeit versions of Plaintiff’s LCR Marks and reproductions of the LCR 

Works. A copy of Defendants’ invoice for this order, predating their reseller application by 

approximately four months, is attached hereto as Exhibit D. Example photographs of a test 

purchase of Defendants’ Counterfeit LCR Product showing the reproduced LCR Works and 

Counterfeit LCR Marks are as follows: 

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31. Defendants sold these Counterfeit LCR Products at least through Defendants’ website 

www.bekavactrading.com, Defendant’s Amazon.com storefront Harbivore Products (Amazon 

Seller ID APMK03F2NY4MO), and, on information and belief, Walmart.com, under and in 

association with Defendants’ “Bek Brands” moniker. 

32. Defendants additionally offered, at least through https://www.bekbrands.com/lcr-bracket., 

accessories for Plaintiff’s famous LCR game, namely, a downloadable and printable tournamentstyle “bracket” to organize competitions. Example photographs of Defendants’ further 

unauthorized use of the LCR marks, again confusingly in association with Defendant’s “Bek 

Brands” moniker, are as follows: 

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33. Defendants’ acts as set forth herein are likely to cause (and do cause) confusion, mistake, and 

deception as to the source or origin of Plaintiff’s goods with Defendants, their activities, and 

their goods, and is likely to falsely suggest (and has already falsely suggested) a sponsorship, 

connection, license, or association between Plaintiff and Defendants. This confusion, mistake, 

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and deception will immediately and irreparably injure and tarnish the goodwill and reputation 

that Plaintiff has diligently labored to establish in its goods and business. 

34. Defendants’ activities have caused and, if not enjoined, will continue to cause irreparable harm 

to Plaintiff and its rights, including, but not limited to, injuring its business reputation and the 

distinctive quality of the LCR Marks. 

35. Defendants’ unauthorized acts are designed to divert, and will have the result of diverting, 

customers from Plaintiff to Defendants. 

36. Defendants have been unjustly enriched as a result of their unauthorized use of the Infringing 

Marks. 

37. Defendants’ activities have caused and, if not enjoined, will continue to cause irreparable harm 

to the public, who has an interest in being free from confusion, mistake, and deception. 

38. Plaintiff has no adequate remedy at law. 

Count I - Trademark Infringement and Counterfeiting, 15 U.S.C. §§ 1114, 1116(d) 

39. Plaintiff’s rights as set forth above in this Complaint are the basis, in part for this Count. 

40. Plaintiff’s trademark infringement claims against Defendants are based on Defendants’ 

unauthorized use in commerce of counterfeit imitations of the federally-registered LCR Marks in 

connection with the advertising, distribution, offering for sale, and sale of infringing goods. 

41. The LCR Marks are distinctive marks, and consumers have come to expect superior quality from 

products advertised, distributed, offered, or sold under the LCR Marks. 

42. Defendants have advertised, distributed, offered to sell, sold, and are still advertising, 

distributing, offering to sell, and selling products using counterfeit reproductions of the LCR 

Marks without Plaintiff’s permission. 

43. Plaintiff is the exclusive owner of the LCR Marks. Plaintiff’s registrations for the LCR Marks 

are in full force and effect. 

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44. Upon information and belief, Defendants are aware and have knowledge of Plaintiff’s rights in 

the LCR Marks and are willfully infringing it and intentionally using counterfeit reproductions 

thereof. 

45. Defendants’ willful, intentional, and unauthorized use of the LCR Marks is likely to cause and is 

causing confusion, mistake, and deception as to the origin and quality of the Counterfeit LCR 

Products among the general public. 

46. Defendants’ activities constitute willful trademark infringement and counterfeiting under 15 

U.S.C. § 1114. 

47. Plaintiff has no adequate remedy at all and will suffer irreparable harm to its reputation and 

goodwill of its well-known LCR Marks if Defendants’ actions are not enjoined. 

48. Defendants’ wrongful advertisement, offering to sell, and sale of Counterfeit LCR Products have 

directly and proximately caused injuries and damage to Plaintiff. 

Count II - False Designation of Origin, Passing Off, and Unfair Competition, 

15 U.S.C. § 1125(a) 

49. Plaintiff’s rights as set forth above in this Complaint are the basis, in part for this Count. 

50. The LCR Marks are distinctive trademarks. 

51. Defendants’ advertising, distribution, offering for sale, and sale of Counterfeit LCR Products has 

created and is creating a likelihood of confusion, mistake, and deception among the general 

public as to the affiliation, connection, and/or association with Plaintiff or the origin, 

sponsorship, or approval of Defendants Counterfeit LCR Products by Plaintiff. 

52. By using the LCR Marks in association with the advertising, distribution, offering for sale, and 

sale of the Counterfeit LCR Products, Defendants create a false designation of origin and a 

misleading representation of fact as to the true origin and sponsorship of the Counterfeit LCR 

Products. 

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53. Defendants’ false designation of origin and misrepresentation of fact as to the origin and/or 

sponsorship of the Counterfeit LCR Products to the general public involves the willful use of 

spurious marks and is a willful violation of 15 U.S.C. § 1125. 

54. Plaintiff has no adequate remedy at all and will suffer irreparable harm to its reputation and 

goodwill of its well-known LCR Marks if Defendants’ actions are not enjoined. 

Count III - Violation of the Illinois Uniform Deceptive Trade 

Practices Act (815 ILCS § 510, et seq.) 

55. Plaintiff’s rights as set forth above in this Complaint are the basis, in part for this Count. 

56. Defendants have engaged in acts which violate Illinois law including, without limitation: passing 

off their Counterfeit LCR Products as those of Plaintiff; causing a likelihood of confusion 

and/or misunderstanding as to the source of their goods; causing a likelihood of confusion 

and/or misunderstanding as to the affiliation, connection, or association with genuine LCR 

Products; representing that their products have Plaintiff’s approval when they do not; and 

engaging in other conduct as described herein which creates a likelihood of confusion or 

misunderstanding among the public. 

57. Defendants’ foregoing acts constitute willful violations of the Illinois Uniform Deceptive 

Trademark Practices Act, 815 ILCS § 510, et seq. 

58. Plaintiff has no adequate remedy at all and will suffer irreparable harm to its reputation and 

goodwill of its well-known LCR Marks if Defendants’ actions are not enjoined. 

Count IV - Copyright Infringement, 17 U.S.C. § 501 

59. Plaintiff’s rights as set forth above in this Complaint are the basis, in part for this Count. 

60. Plaintiff is the owner of the original LCR Works registered and contained in Exhibit B. 

61. The LCR Works have significant value and have been produced and created at considerable 

expense. 

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62. Among the rights granted to Plaintiff is the exclusive right to market and sublicense the right to 

copy, reproduce, and display the LCR Works and make derivative works thereof. 

63. On information and belief, Defendants, who are in the business of distributing toys and other 

consumer products, had access to the works in Exhibit B through, at least, their research of the 

LCR Products in preparation of their application for licensure from Plaintiff in April 2019. 

After accessing the LCR Works, Defendants wrongfully caused to be produced copies of the 

copyrighted LCR Works without Plaintiff’s consent and engaged in acts of widespread 

infringement through the distribution and sale of unauthorized copies of the LCR Works. 

64. Defendant, without the permission or consent of the Plaintiff, has sold and continues to sell 

online infringing derivative works of the copyrighted LCR Works and reproduce, display, and 

distribute the LCR Works without authorization and in violation of Plaintiff’s exclusive rights 

under 17 U.S.C. § 106 

65. As a direct result of their acts of their copyright infringement, Defendants have obtained direct 

and indirect profits they would not otherwise have realized but for their infringement of the 

copyrighted LCR Works. 

66. Defendants knew their acts constituted copyright infringement and Defendants’ conduct was 

willful within the meaning of the Copyright Act. 

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

infringement pursuant to 17 U.S.C. § 501. 

Prayer for Relief 

WHEREFORE, Plaintiff, George & Company LLC, prays for judgment against Defendants as 

follows: 

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1) That Defendants, their affiliates, officers, agents, servants, employees, attorneys, confederates, 

and all persons acting for, with, by, through, under, or in concert with them be temporarily, 

preliminarily, and permanently enjoined and restrained from: 

a. using the LCR Marks or any reproductions, counterfeit copies, or colorable imitations 

thereof in any manner in connection with the distribution, marketing, advertising, 

offering for sale, or sale of any product that is not a genuine LCR Product or is not 

authorized by Plaintiff to be sold in connection with the LCR Marks; 

b. passing off, inducing, or enabling others to sell or pass off any product as a genuine LCR 

Product or any other product produced by Plaintiff that is not Plaintiff’s or is not 

produced under the authorization, control, or supervision of Plaintiff and approved by 

Plaintiff for sale under the LCR Marks; 

c. committing any acts calculated to cause consumers to believe that Defendants’ 

Counterfeit LCR Products are those sold under the authorization, control, or supervision 

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

d. further infringing the LCR Mark and damaging Plaintiff’s goodwill; 

e. manufacturing, shipping, delivering, holding for sale, transferring or otherwise moving, 

storing, distributing, returning, or otherwise 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 which bear any of Plaintiff’s trademarks, including the LCR Marks, 

or any reproductions, counterfeit copies, or colorable imitations thereof, or the LCR 

Work or artifacts are derivative works thereof; 

f. using, linking to, transferring, selling, exercising control over, or otherwise owning a 

business that is being used to sell products or inventory not authorized by Plaintiff 

which bear the LCR Marks or LCR Works or derivative works thereof; 

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g. operating, facilitating and/or hosting websites which are involved with the distribution, 

marketing, advertising, offering for sale, or sell products or inventory not authorized by 

Plaintiff which bear the LCR Marks or LCR Works or derivative works thereof; 

2) Entry of an Order that, upon Plaintiff’s request, those in privity with Defendants and those with 

notice of the injunction, including, without limitation, any online marketplace platforms such as 

Amazon, eBay, Wish, Joom, Vova, Alibaba and AliExpress, sponsored search engine or ad-word 

providers, credit cards, banks, merchant account providers, third party processors and other 

payment processing service providers, and Internet search engines such as Google, Bing and 

Yahoo (collectively, the “Third Party Providers”) shall: 

a. disable and cease providing services being used by Defendants, currently or in the future, 

to engage in the sale of goods using the LCR Marks or bearing the LCR Works or 

derivate works thereof; 

b. disable and cease displaying any advertisements used by or associated with Defendants in 

connection with the sale of goods using without authorization the LCR Marks or LCR 

Works or derivate works thereof; 

3) That Defendants account for and pay to Plaintiff all profits realized by Defendants by reason of 

Defendants’ unlawful acts herein alleged, and that the amount of damages for infringement of 

the LCR Marks be increased by a sum not exceeding three times the amount thereof pursuant to 

15 U.S.C. § 1117(a); 

4) In the alternative, that Plaintiff be awarded statutory damages for willful trademark 

counterfeiting pursuant to 15 U.S.C. § 1117(c)(2) of $2,000,000 for the unauthorized use of each 

LCR Mark for each registered good or service; 

5) For Judgment in favor of Plaintiff against Defendants that they have willfully infringed Plaintiff’s 

rights in its federally registered copyrights pursuant to 17 U.S.C. § 501; 

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6) That Defendants impound or destroy of all copies of the Infringing LCR Works in the 

possession or control of any of the Defendants or their agents, employees, affiliated companies, 

and those acting in concert with them, and provide certification of same, pursuant to 17 U.S.C. § 

503(b); 

7) That Defendants account for and disgorge to Plaintiff all gains, profits, and advantages derived 

by their copyright infringement, pursuant to 17 U.S.C. § 504(b) and other law; 

8) That Plaintiff be awarded such actual damages as it has sustained as a result of Defendants’ 

copyright infringement in an amount to be determined at trial pursuant to 17 U.S.C. § 504(a)(1), 

(b); 

9) In the alternative, that Plaintiff be awarded statutory damages for Defendants’ willful copyright 

infringement of $150,000 per LCR Work infringed pursuant to 17 U.S.C. § 504(c)(2); 

10) That Plaintiff be awarded its reasonable attorneys’ fees and costs as available pursuant to 15 

U.S.C. § 1117, 17 U.S.C. § 505, 815 ILCS § 510/3, and other applicable law; and 

11) Award any and all other relief that this Court deems just and proper. 

Dated: August 7, 2020 

Respectfully submitted, 

/s/Adam E. Urbanczyk 

AU LLC 

564 W. Randolph St. 2nd Floor 

Chicago, IL 60661 

adamu@au-llc.com 

Ph. (312) 715-7312 

Fax (312) 646-2501 

ARDC No. 6301067 

Counsel for Plaintiff George & Company 

LLC 

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