The complaint

Agnik, LLC v. Louis L. Ellis and Ellis and Ellis Consulting Group LLC, No. 1:26-cv-04575-JRR (D. Md.), is a 13-page complaint filed November 2, 2026, ECF No. 1, with a jury demand. The docket lists Judge Julie Rebecca Rubin as the assigned judge. Agnik, a Maryland limited liability company based in Columbia, Maryland, says it works in telematics and connected-vehicle hardware and sells Vyncs products through vyncs.com and online channels including Amazon, Walmart, and eBay. The defendants are Louis L. Ellis, of Springfield, Massachusetts, and Ellis and Ellis Consulting Group LLC, a Connecticut limited liability company that the complaint says lists itself on Amazon.com as the seller of Moto Watchdog products. The complaint alleges both control and operate a competing business known as Moto Watchdog, and it states that it pleads on information and belief as to all matters other than Agnik's own acts. (Compl. intro; paras. 2 to 5.)

The mark

Agnik alleges it has owned and used the registered VYNCS mark, Registration No. 5,286,324, since September 12, 2017, and attaches the registration as Exhibit A. (Compl. para. 3.) USPTO TSDR shows VYNCS in standard characters on the Principal Register, registered September 12, 2017, for on-board vehicle diagnostic and monitoring devices and related goods in Class 9, lists Agnik as the owner, and shows that a Section 8 declaration has been accepted.

What the complaint alleges

The complaint alleges the defendants entered the market recently as Moto Watchdog and built multi-page content on the Moto Watchdog domain aimed at "Vyncs" search keywords. It describes four categories: product graphics said to show Vyncs Link hardware that Agnik says bear no resemblance to the real device; pricing matrices that it says falsely showed a monthly fee structure, such as $3,600 over five years for five devices, when Vyncs sells hardware with an annual renewal; statements that Vyncs lacks alerts, driver tracking, and route history or needs professional setup; and page titles such as login and customer service guides that it says routed searchers to Moto Watchdog and its Amazon checkout. It says Agnik sent a cease-and-desist demand on May 28, 2026, and that Ellis replied within an hour that he would take the pages down and did so. Agnik seeks compensation for the conduct since May 15, 2024, alleges the defendants diverted about 29 percent of its prospective organic customers, and puts its total demand above $5 million. (Compl. paras. 9 to 14, 18, 19.)

Claims and relief requested

Count I alleges trademark infringement, Count II false advertising, and Count III unfair competition, each under the Lanham Act and each citing 15 U.S.C. §§ 1114 and 1125(a). Agnik asks for an order that the defendants' conduct infringes its registered mark and is unfair competition, a permanent injunction, the defendants' profits and its damages, trebled, under 15 U.S.C. § 1117, punitive damages, attorneys' fees and costs as an exceptional case, and interest. (Compl. paras. 22 to 41; Request for Relief A to H.)