Coach Relief sues two individual defendants over online sales through coachrelief.com: complaint allegations

What was filed

The complaint is Document 1, filed October 19, 2026, in the U.S. District Court for the Middle District of Florida, Tampa Division. The case is Coach Relief, LLC v. Wayne Farmer and Deborah Disney, No. 8:26-cv-03169. It pleads three counts against both defendants: service-mark infringement under 15 U.S.C. § 1114(1)(a), false designation of origin and unfair competition under 15 U.S.C. § 1125(a)(1)(A), and cybersquatting under 15 U.S.C. § 1125(d)(1). The complaint says no state-law claim is asserted, and Coach Relief demands a jury trial. Counsel is Gil Sanchez of Black Rock Trial Lawyers. The complaint runs 13 pages.

The parties and the mark

The complaint says Coach Relief, LLC is a Florida limited liability company with its principal place of business in Clearwater, Florida, and that both defendants are Florida residents living in the Middle District of Florida.

The complaint says Coach Relief owns COACHRELIEF, U.S. Reg. No. 8,148,869, a standard-character mark on the Principal Register issued February 24, 2026, for Class 35 online retail store services featuring dietary supplements and jewelry, and promoting the goods and services of others, with September 1, 2022 listed as the date of first use. USPTO records match those details, list Coachrelief, LLC of Florida as the owner, and show the registration as live. The registration also records that COACHRELIEF identifies a living individual whose consent is of record, and the complaint says that person is the plaintiff's principal.

What the complaint alleges

Coach Relief alleges that the defendants used Coach Relief or coachrelief without authorization for commercial activity through coachrelief.com, a domain that takes the whole mark and adds only .com. It alleges, on information and belief, that Farmer has continued to run or direct product sales under the coachrelief brand through people handling his business operations, that at least one defendant exercises or has exercised control over the site's commercial use, and that at least one defendant is its registrant or an authorized licensee of the registrant.

The complaint says Coach Relief's counsel sent the defendants a cease-and-desist email on April 20, 2026, and the defendants responded. It alleges that sales through coachrelief.com continued after May 2026, that the site was actively changed during 2026, and that as of about September 10, 2026 the operation had at least 200 active monthly autoship subscriptions while lacking inventory, and that charges continued while orders went unfilled. It alleges, on information and belief, that consumers could blame those failures on Coach Relief, and it describes an August 2026 exchange in which a customer contacted the plaintiff's principal about an order, and he replied that he had no record of it and that coachrelief.com was not his website.

Relief requested

The prayer asks for a declaration of infringement under 15 U.S.C. § 1114(1)(a) and 1125(a)(1)(A), preliminary and permanent injunctions, removal of infringing uses of the mark from websites, advertising, social media profiles, customer communications, and other channels the defendants control, and on Count III transfer of coachrelief.com to Coach Relief or cancellation of the domain under 15 U.S.C. § 1125(d)(1)(C). It also seeks profits, damages, and costs under 15 U.S.C. § 1117(a), statutory damages under 15 U.S.C. § 1117(d) as an alternative on Count III, attorneys' fees if the case is found exceptional, and interest. The complaint states no damages figure.