Fish Window Cleaning sues a former Quincy franchisee over royalties, noncompete, and continued use of the FISH marks: complaint allegations

What was filed

The complaint is Document 1, filed October 14, 2026, in the U.S. District Court for the Northern District of Illinois. The case is Fish Window Cleaning Services, Inc. v. Alex Stinnett, COL 323 Inc., Lacy Stinnett, and River City Window Cleaning LLC, No. 1:26-cv-12612. It pleads seven counts: breach of franchise agreement and personal guarantee for failure to report and pay fees (Franchisee Parties); breach for failure to comply with post-termination obligations (Franchisee Parties); fraud (Franchisee Parties); tortious interference with contract (Lacy Stinnett and River City); civil conspiracy (all defendants); trademark infringement under Sections 32 and 43(a) of the Lanham Act, 15 U.S.C. §§ 1114 and 1125(a) (all defendants); and false designation of origin / unfair competition under 15 U.S.C. § 1125(a) and common law (all defendants). Counsel are Bryan E. Minier and Craig P. Miller of Lathrop GPM LLP.

What the complaint alleges

Fish says it franchises Fish Window Cleaning Services and owns registrations including U.S. Reg. Nos. 2,244,693 and 2,631,518, which it describes as incontestable, with continuous use of the marks in interstate commerce since at least 1999. It alleges Alex Stinnett was a franchisee (possibly through COL 323) and personal guarantor in Quincy, Illinois, that in April 2026 Fish learned the Franchisee Parties had falsified gross sales and failed to pay royalties and brand fees, and that the Franchise Agreement expired without renewal on September 20, 2026.

It alleges that before and after expiration the Franchisee Parties, with Lacy Stinnett, operated competing businesses River City Window Cleaning and Made New Quincy from the same Quincy location and phone number as the former franchise, diverted customers, used Fish confidential and customer information, and used the Fish Window Cleaning tradename and trademarks in online advertisements on platforms including Mapquest and Manta. The prayer asks for preliminary and permanent injunctive relief enforcing post-termination and noncompete terms and stopping mark use, damages exceeding $75,000 on the fee claims with further amounts to be proven, treble damages and fees under 15 U.S.C. § 1117, and other relief.