The complaint
Amazon.com, Inc. v. Aleksandrov, No. 2:26-cv-04292 (W.D. Wash.), is a 32-page Complaint for Damages and Injunctive Relief filed November 5, 2026 in Seattle. The plaintiffs are Amazon.com, Inc. and Amazon.com Services LLC, both Delaware entities, and Amazon Technologies, Inc., a Nevada corporation, all based in Seattle. The defendants are Denis Aleksandrov, an individual the complaint alleges, on information and belief, lives in Plovdiv, Bulgaria, and Does 1-10, unknown parties doing business as Olympus Refunds.
What Amazon alleges
According to the complaint, Olympus Refunds advertises a refund service on Telegram channels that had more than 2,290 combined subscribers as of July 2026. A user orders a product from Amazon and gives Olympus the account login and order details. Olympus then seeks a refund, for example by posing as the user and giving customer service false information, by claiming the package arrived empty, by returning empty packages, or by filing chargeback claims, and it charges a 15% fee while the user keeps the product. Amazon alleges that Olympus has posted testimonials since at least May 2024 referencing more than $450,000 in Amazon refunds, and describes a test order by an investigator working for its outside counsel that, it says, was refunded without the item being returned.
Amazon alleges, on information and belief and based on the investigation the complaint describes, that Denis Aleksandrov is a primary operator of Olympus and the administrator of its Telegram channel.
The marks
The complaint lists 18 U.S. registrations as the Amazon Trademarks. USPTO TSDR shows eleven of them, including Reg. No. 2,657,226, as registrations of the AMAZON word mark, and the other seven, including Reg. Nos. 3,904,646, 4,067,393 and 5,129,530, as design marks consisting of a letter "A" or "a" above a smile or curved arrow, all live and owned by Amazon Technologies, Inc. Amazon alleges that Olympus's Telegram posts and three websites advertising Amazon return services featured these marks without authorization, drawing users in under the false impression that Olympus offered legitimate Amazon return services.
Claims and relief
The complaint pleads trademark infringement under 15 U.S.C. § 1114, false designation of origin, sponsorship, approval, or association and false advertising under 15 U.S.C. § 1125(a), and civil conspiracy, fraudulent misrepresentation, negligent misrepresentation, conversion, and unjust enrichment. It asks for permanent injunctions barring the defendants from claiming an affiliation with Amazon, using Amazon accounts or seeking refunds, using the Telegram channels tied to the scheme, and using the Amazon Trademarks, along with an accounting, disgorgement of profits under 15 U.S.C. § 1117(a), a constructive trust, the value of the refunded products, damages enhanced as allowed by 15 U.S.C. § 1117, restitution, and attorneys' fees and costs.
Docket
The case is assigned to Magistrate Judge Grady J. Leupold, who was added to the docket on November 6, 2026. The docket also shows a corporate disclosure statement filed with the complaint, and on November 6 a summons issued to Denis Aleksandrov and the trademark report sent to the USPTO.