SharkNinja v. Spray and Pray: the complaint's warranty theory and alleged refund scheme

Snapshot

The case is SharkNinja Operating LLC v. Spray and Pray LLC, No. 1:26-cv-14351 (D. Mass.), assigned to Chief District Judge Denise J. Casper. The complaint is Document 1, filed September 23, 2026, 21 pages, with a jury demand. SharkNinja Operating LLC alleges it is a Delaware limited liability company with its principal place of business in Needham, Massachusetts. It alleges, on information and belief, that Spray and Pray LLC is a Wyoming limited liability company, also known as Omega Distributions Co and 13007332 Canada Inc., that sells on Amazon.com under the seller name Spray and Pray LLC. Subject-matter jurisdiction is pleaded under 15 U.S.C. 1121 and 28 U.S.C. 1331 and 1338(a) and (b).

The SharkNinja marks

The complaint lists federal registrations among the SharkNinja Marks used with household and cleaning products and accessories: SHARK, Registration No. 4,329,299 (April 30, 2013); SHARK, Registration No. 2,771,850 (October 7, 2003); SHARK IQ ROBOT, Registration No. 6,131,311 (August 18, 2020); and NINJA, Registration No. 5,453,690 (April 24, 2018). It alleges the marks have been in continuous use since at least those registration dates and that the registrations are valid and subsisting.

What the complaint alleges

SharkNinja alleges that Spray and Pray advertises and offers one product and then fulfills the order with a different SharkNinja product. It describes a test buy in which it ordered model NC601 from Spray and Pray's Amazon storefront and received model CN601CO. It also alleges that Spray and Pray falsely advertises SharkNinja products as "new" and as protected by SharkNinja warranties when, SharkNinja says, the products are used and are not protected by those warranties. The complaint alleges that only products bought from SharkNinja directly or from one of its Authorized Internet Resellers qualify for the warranties, and that Spray and Pray is not an authorized reseller.

The complaint further alleges a refund-without-return scheme: Spray and Pray purchases SharkNinja products directly from SharkNinja, including through direct-to-consumer channels and TikTok Shop, obtains refunds by representing that the products are being returned, does not return them, and resells those unreturned products on Amazon.com. It alleges that separate test buys of a Shark FlexStyle and a Shark MessMaster from Spray and Pray's storefront produced new units shipped from SharkNinja's own warehouse, labeled as originally bought through SharkNinja's direct-to-consumer channel, and that SharkNinja's records show that of 39 orders of model NC601 placed through one sales channel, only one unit came back while refunds were sought and obtained for a far greater number. It alleges, on information and belief, that the inventory includes more than 600 units of new product launches and that the scheme has enabled Spray and Pray to obtain the Amazon Buy Box on multiple SharkNinja listings. It also alleges, on information and belief, that Spray and Pray is selling stolen SharkNinja products.

The counts and the relief sought

Count I is headed unfair competition and false advertising in violation of 15 U.S.C. 1125(a), and the complaint also calls it a claim for federal trademark infringement under that section. Count II alleges common-law conversion. Count III alleges common-law fraud. Count IV alleges unfair competition under Massachusetts General Laws chapter 93A. The prayer asks the court to enjoin Spray and Pray, preliminarily and permanently, from using SharkNinja intellectual property and from acquiring or selling any SharkNinja products, and to require an accounting of its SharkNinja purchase, refund, and resale records, the return of SharkNinja products in its possession, and repayment of refunds for products never returned. It also seeks actual damages and profits, trebled under 15 U.S.C. 1117 and chapter 93A, attorneys' fees, interest, and costs.

How the complaint builds the Lanham Act claim

The complaint describes the goods throughout as SharkNinja products, some of them allegedly bought from SharkNinja itself. Its Lanham Act count is built on what the listings say about those products: that a unit sold as "new" carries the SharkNinja warranties, and that the buyer will receive the model ordered. The warranty theory depends on the complaint's allegation that only products bought from SharkNinja or an Authorized Internet Reseller qualify for the warranties. The refund-without-return allegations carry the fraud count and the conversion count, which asserts SharkNinja's right to possess products it refunded, and the chapter 93A count draws on both the refund allegations and the false advertising.

Where the docket stands

The docket shows a notice of appearance, a motion for an extension of time to answer, and an affidavit of service, all filed October 20, 2026, and an order on the extension motion entered October 21, 2026.