Admar International sues over alleged unauthorized use of NUBY marks in social media posts

The complaint

The complaint is Document 1, filed November 12, 2026, in Admar International, Inc. v. Hakim, No. 3:26-cv-04761 (W.D. La., Monroe Division). It runs 14 pages and includes a jury demand. Admar International, Inc. is a Delaware corporation with its principal place of business in Monroe, Louisiana. The complaint names two individual defendants who, it alleges on information and belief, reside in Florida. (Compl. paras. 1-3, 63.)

The marks

The complaint says Admar owns U.S. Trademark Registration No. 2,335,700 for the mark NUBY, issued March 28, 2000, for infant pacifiers in International Class 10, from an application filed April 20, 1999, and that the registration is incontestable. (Compl. paras. 8-9, 40.) It alleges that Admar also owns fifteen other U.S. trademark registrations for the NUBY word mark in various classes, identified in a chart attached as Exhibit B, and a distinctive NUBY Logo consisting of the stylized word NUBY in red with white outlining and an inverted heart over the letter “u,” used since at least 1998. (Compl. paras. 11-12.) It further alleges that Admar owns Louisiana trademark registrations for the NUBY word mark and the NUBY Logo, including Registration (Book) No. 66-9913 in Class 21 (baby products), registered January 12, 2017. (Compl. para. 13.) The complaint alleges that ownership of the marks and registrations was transferred to Admar on July 11, 2006, that Admar has licensed the marks in interstate commerce continuously since January 1, 1998, and that since 1998 Admar and its licensees have promoted, sold, and distributed baby products under them throughout the United States. (Compl. paras. 10, 15-16.) USPTO records list U.S. Reg. No. 2,335,700 as a live standard-character registration of NUBY on the Principal Register, owned by Admar International, Inc., a Delaware corporation with an address in Monroe, Louisiana, registered March 28, 2000, from an application filed April 20, 1999, for "Infant Pacifier(s)" in International Class 10, with first use and use in commerce claimed from January 1, 1998, and the registration has been renewed.

What the complaint alleges

The complaint alleges, on information and belief, that one defendant operates an Instagram account and that the other operates several Instagram accounts. (Compl. paras. 23-25.) It alleges that on October 22, 2026, one or both defendants posted to those accounts an AI-generated image advertising and promoting a "documentary" about one defendant's life, using the NUBY word mark and an adulterated version of the NUBY Logo without authorization, and that the post had not been removed as of the date of the complaint. (Compl. para. 27.) It alleges that comments to the post tag the NUBY U.S.A. account and other NUBY regional accounts, and that the conduct, including presenting one defendant as connected and associated with the NUBY marks and with Admar, is likely to cause confusion about whether Admar is the source or sponsor of, endorses, or approves the post and the "documentary." (Compl. paras. 28, 31.) It alleges that the NUBY designation in the post is a spurious mark identical with, or substantially indistinguishable from, the registered NUBY word mark, and so a counterfeit of it. (Compl. para. 46.) It alleges that the defendants acted willfully, with knowledge of Admar's rights and with intent to trade on the goodwill of the marks, and that the use is likely to dilute the marks by blurring and by tarnishment. (Compl. paras. 32, 52.) The complaint also says one defendant holds ownership interests in companies based in Monroe, Louisiana, some of which it describes as substantial licensees of the NUBY marks. (Compl. para. 21.)

Claims and relief

The complaint pleads six counts: false designation of origin and false association under section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a) (Count I); federal trademark infringement under section 32(1), 15 U.S.C. § 1114(1) (Count II); federal trademark counterfeiting under 15 U.S.C. §§ 1114(1), 1116(d), and 1117(b)-(c) (Count III); federal trademark dilution under section 43(c), 15 U.S.C. § 1125(c) (Count IV); Louisiana trademark infringement under La. R.S. § 51:222 (Count V); and injury to business and reputation and dilution under La. R.S. § 51:223.1 (Count VI). The prayer asks the court to adjudge that the defendants violated Sections 32(1), 43(a), and 43(c) of the Lanham Act, including through use of a counterfeit mark, and La. R.S. § 51:222 et seq.; to order the defendants to remove the posts depicting the NUBY marks and to enjoin them, preliminarily and permanently, from any further use of the NUBY marks or any confusingly similar mark and from any further acts of infringement, counterfeiting, false designation of origin, false association, dilution, or unfair competition; to require a sworn compliance report within 30 days after entry of any injunction under 15 U.S.C. § 1116(a); to order an accounting and award of the defendants' profits under 15 U.S.C. § 1117(a); to award actual damages and up to three times that amount; for willful use of a counterfeit mark, to award three times Admar's damages or the defendants' profits, whichever is greater, with reasonable attorneys' fees under 15 U.S.C. § 1117(b), or, at Admar's election, statutory damages under 15 U.S.C. § 1117(c); to award damages and profits under La. R.S. § 51:223; to declare the case exceptional and award attorneys' fees; and to award costs, prejudgment and post-judgment interest, and other relief. (Prayer.)