American Board of Wound Management sues a physician over CWSP and Certified Wound Specialist Physician marks, alleging his certification was revoked

What was filed

The complaint is Document 1 in American Board of Wound Management, Inc. v. Sarfo, No. 2:26-cv-03546-CDS-NJK (D. Nev.), filed October 27, 2026. It runs 10 pages and includes a jury demand, and the docket lists a civil cover sheet, an appendix of exhibits, and Exhibits A through F as attachments. The docket shows that on October 28, 2026, the case was randomly assigned to Judge Cristina D. Silva and Magistrate Judge Nancy J. Koppe and a summons issued. The plaintiff is American Board of Wound Management, Inc. (ABWM), which the complaint describes as a not-for-profit Florida corporation with its principal place of business in Washington, D.C. The defendant is Kofi Sarfo, M.D., whom the complaint describes as a physician with an office and a residence in Las Vegas, Nevada.

The marks

The complaint says ABWM has used CERTIFIED WOUND SPECIALIST PHYSICIAN and CWSP since 2009 as certification marks for medical professionals who pass its examination and meet its requirements for continuing certification, each for "medical services of physicians, namely, Medical Doctors, Doctors of Osteopathy and Doctors of Podiatry, in the field of wound management." It states that on February 15, 2011, the USPTO issued registration number 3,918,691 for CERTIFIED WOUND SPECIALIST PHYSICIAN, that on March 22, 2011, it issued registration number 3,935,328 for CWSP, and that both registrations are incontestable under Section 15 of the Lanham Act, 15 U.S.C. 1065. USPTO records list Reg. No. 3,935,328 (CWSP) as a live certification-mark registration owned by ABWM. USPTO records list the CERTIFIED WOUND SPECIALIST PHYSICIAN certification mark, registered to ABWM on February 15, 2011 for the same services, as Reg. No. 3,918,601, also live.

What the complaint alleges

The complaint alleges that the defendant applied for certification in or about 2017 and that ABWM awarded him the Certified Wound Specialist Physician credential on February 18, 2018, which authorized him to use the marks. It says continuing certification requires six hours of continuing education in wound management each year and an annual renewal fee, that he missed the March 31, 2024 deadline after reminders by mail, email, and telephone, and that ABWM revoked his certification on April 1, 2024. It alleges that ABWM told him in an April 5, 2024 letter that he could no longer use the CWSP designation, that ABWM's counsel wrote to him on April 23 and May 12, 2026, asking him to remove the statements from his website and stop claiming the certification, and that he has not responded. It alleges that he continues to hold himself out as a "Certified Wound Specialist Physician" and a "CWSP," including as "MD, CWSP" on his website, that the use is likely to cause confusion and falsely claims an ABWM endorsement, and that it is willful.

Claims and relief

Claim One alleges infringement of the registered certification marks under Section 32 of the Lanham Act, 15 U.S.C. 1114, and alleges the conduct was willful and deliberate, making the case exceptional under 15 U.S.C. 1117(a). Claim Two alleges false designation and false advertising under Section 43(a), 15 U.S.C. 1125(a), based on a likelihood of confusion about affiliation with or endorsement by ABWM. Claim Three alleges trademark infringement under Nevada common law, including passing off, misappropriation of goodwill, and deceptive business practices. The complaint asks for a permanent injunction against using the marks or suggesting ABWM certification or affiliation; a sworn compliance report under 15 U.S.C. 1116(a); an accounting of profits and actual damages under 15 U.S.C. 1117(a) and Nevada common law; a declaration that the case is exceptional, with enhanced damages of up to three times actual damages for willfulness; costs, attorneys' fees under 15 U.S.C. 1117(a), and prejudgment interest; and other just and proper relief.