What was filed

The complaint is Document 1, filed October 16, 2026, in the U.S. District Court for the Western District of Washington at Seattle. The case is Amazon.com, Inc. v. Khong, No. 2:26-cv-03954. It pleads four claims: trademark counterfeiting and infringement under 15 U.S.C. § 1114 (by Kendra Scott); false designation of origin under 15 U.S.C. § 1125(a)(1)(A) (by all plaintiffs); violation of the Washington Consumer Protection Act, RCW 19.86.020 (by all plaintiffs); and breach of Amazon's Business Solutions Agreement (by Amazon.com Services LLC). Counsel is Scott Commerson of Davis Wright Tremaine LLP. The complaint runs 30 pages with Attachment 1; Exhibit A and the other exhibits were not reviewed.

What the complaint alleges

The complaint lists three Kendra Scott, LLC design registrations (Reg. Nos. 5,399,800, 7,170,774, and 4,838,307) and three word-mark registrations owned by Kendra Scott individually and exclusively licensed to Kendra Scott, LLC (Reg. Nos. 7,311,085, 3,125,314, and 4,927,238), all in Class 14. The defendants, as the complaint identifies them, are Vivien Khong of North Carolina (d/b/a Ideal Retail LLC and Jeanius LLC), tied to the Gaggle of Geese account; Jeremiah Strawn of Oregon and Jeremiah Boutique LLC, tied to the Jeremiah Boutique account; and Peter Newton of New Hampshire, Paul Newton of California, and Truck N Shadez LLC, tied to the TruckNShadez account. Most of those identifications are made on information and belief.

It alleges Kendra Scott made test purchases or reviewed samples from each account and confirmed the goods were counterfeit, that the accounts submitted invoices and letters of authorization that Kendra Scott says were falsified, and, on information and belief, that the defendants acted in concert. Attachment 1 lists known sales of the accused products from August 11, 2025 to April 22, 2026 (Gaggle of Geese), November 6, 2024 to June 26, 2026 (Jeremiah Boutique), and October 3, 2024 to November 25, 2025 (TruckNShadez). It says Amazon blocked the accounts and refunded customers and was not reimbursed. The prayer seeks an injunction, records identifying suppliers, impoundment under 15 U.S.C. § 1118, profits and damages, statutory damages under 15 U.S.C. § 1117(c), enhancement under 15 U.S.C. § 1117 and RCW 19.86, fees, and an order that financial institutions restrain and transfer funds. No damages figure is stated.