Fear of God alleges Citoyen Import Corp. and an individual imported counterfeit FEAR OF GOD streetwear seized by CBP

What was filed

The complaint is Document 1 in Fear of God, LLC v. Citoyen Import Corp., No. 1:26-cv-09472 (S.D.N.Y.), filed October 29, 2026. It runs 23 pages and requests a jury trial. The defendants are Citoyen Import Corp. and Amsonyn Eduardo Penaloza Almanza d/b/a Citoyen Import Corp. Fear of God, LLC is described as a California limited liability company based in Los Angeles. Upon information and belief, the complaint says Citoyen is a New York domestic business corporation based in New York, New York, and that Almanza is an individual who operates Citoyen and is its owner and sole operator.

The marks

The complaint lists four registrations as the FEAR OF GOD Trademarks: U.S. Reg. No. 5,696,924 (FEAR OF GOD), 6,380,624 (FEAR OF GOD ESSENTIALS), 6,380,625 (FEAR OF GOD ESSENTIALS), and 6,810,494 (ESSENTIALS FEAR OF GOD). It says certificates are attached as Exhibit B and that the registrations are valid and in full force. USPTO TSDR lists each registration as live and owned by Fear of God, LLC: Reg. No. 5,696,924 for Class 25 clothing, footwear, and headwear (Sections 8 and 15 accepted); Reg. No. 6,380,624 for Class 18 backpacks; Reg. No. 6,380,625 for Class 25 clothing; and Reg. No. 6,810,494 for Class 25 clothing and headwear. The complaint describes Fear of God Products as clothing and accessories sold through authorized retailers and fearofgod.com.

What the complaint alleges

The complaint alleges that the defendants manufacture, import, advertise, distribute, offer for sale, and/or sell Counterfeit Products bearing one or more of the FEAR OF GOD Trademarks or confusingly similar marks to U.S. consumers, including in New York. It alleges the defendants are active importers with import records identifying over 100 shipments of consumer products to the United States from China, including to New York. It alleges that on July 1, 2026, U.S. Customs and Border Protection seized thousands of Counterfeit Products arriving at the Port of Los Angeles that were being imported by the defendants, and that a notice attached as Exhibit C identifies Citoyen as the importer of record. It alleges the seized goods have been confirmed as counterfeit and are virtually indistinguishable from genuine Fear of God Products. Upon information and belief, it alleges Almanza formed Citoyen and at least four other shell entities in New York, California, Wyoming, and Kentucky in or about 2025 and 2026 to import counterfeit goods while obscuring the operator and evading CBP detection, and that he directed Citoyen's operations and overseas supply chain.

Claims and relief

First Cause of Action alleges trademark counterfeiting under 15 U.S.C. 1114(1)(b), 1116(d), and 1117(b)-(c). Second Cause of Action alleges infringement of registered trademarks under 15 U.S.C. 1114. Third Cause of Action alleges false designation of origin and unfair competition under 15 U.S.C. 1125(a). Fourth Cause of Action alleges unfair competition under New York common law. The complaint alleges the conduct was willful. It asks for profits and damages under 15 U.S.C. 1117(a) with treble damages under 1117(b) for willful counterfeiting or, in the alternative, statutory damages under 1117(c) of not more than $2,000,000 per counterfeit mark per type of goods; preliminary and permanent injunctions; recall and delivery up of Counterfeit Products for destruction, including under 15 U.S.C. 1118; an accounting; an asset freeze or constructive trust over the defendants' profits; exemplary or punitive damages; attorneys' fees and costs; and other relief.