Honest-1 Auto Care franchisor sues Cape Coral shop Honest Auto and Airconditioning over its name, colors, and domain: complaint allegations

What was filed

The complaint is Document 1, filed October 21, 2026, in the U.S. District Court for the Middle District of Florida, Tampa Division. The case is H-1 Auto Care, LLC v. Honest Auto and Airconditioning, LLC, No. 8:26-cv-03210. It runs 18 pages. Counsel is M. Quinn Murphy of Gordon Rees Scully Mansukhani, LLP. Exhibit A, which the complaint describes as the registration certificates, is not freely available on the public docket.

The parties and the marks

The complaint describes the plaintiff, which it calls Honest1, as a Nevada limited liability company based in St. Petersburg, Florida, that franchises auto repair and maintenance centers. It says Honest1 has 58 franchise locations in 17 states, including seven in Florida, and has operated since 2003. It lists eight U.S. registrations, including No. 2,890,154 for HONEST-1 AUTO CARE, and says it first used HONEST-1 AUTO CARE in March 2003. The defendant is described as a Florida limited liability company based in Sarasota, Florida, that operates an auto repair business called Honest Auto and Airconditioning in Cape Coral, Florida.

USPTO records list all eight pleaded registrations as live and list H-1 Auto Care, LLC, the plaintiff, as owner of each. Reg. No. 2,890,154 is the HONEST-1 AUTO CARE word mark, registered September 28, 2004, for retail tire and rim store services in Class 35, and renewed in 2025. Reg. No. 3,764,177 is the H1 HONEST-1 AUTO CARE logo, registered March 23, 2010, for automotive maintenance and repair in Class 37, and renewed in 2019. Six HONEST1 pill logo registrations for automotive maintenance and repair in Class 37 were registered from 2023 to 2024: Nos. 7,158,862, 7,158,863, 7,197,296, 7,197,297, 7,215,065, and 7,388,611. Both older registrations have Section 15 declarations on record.

What the complaint alleges

According to the complaint, Honest1 learned of the Cape Coral shop in or around June 2026 and sent a letter on August 4, 2026, demanding that the defendant stop using the name. It says the defendant's lawyer then contacted Honest1's counsel but gave no substantive response, and that an October 9, 2026 message from a representative of the defendant said it no longer had counsel and refused to stop using the name. The complaint alleges that the name takes the dominant word HONEST and the word AUTO from the Honest1 marks, that the defendant copied Honest1's green and blue color scheme on its signage and online, and that the defendant was organized on July 9, 2025, well after Honest1's first use. It also alleges that the defendant registered honestautoandair.com on or after July 9, 2025, with a bad faith intent to profit from the Honest Marks by diverting customers seeking Honest1's services, and that it has not answered Honest1's request to transfer the domain.

Claims and relief requested

The counts are infringement under 15 U.S.C. § 1114; false designation of origin and unfair competition under 15 U.S.C. § 1125(a); dilution by blurring under 15 U.S.C. § 1125(c), on the allegation that the Honest Marks are famous; cybersquatting under 15 U.S.C. § 1125(d); and violation of the Florida Deceptive and Unfair Trade Practices Act, Fla. Stat. § 501.204. The cybersquatting count asks, in the alternative, for statutory damages of $1,000 to $100,000 per domain name under 15 U.S.C. § 1117(d). The prayer asks for preliminary and permanent injunctions against use of the Honest Marks and any confusingly similar name, forfeiture, cancellation, or transfer of honestautoandair.com, compensatory and punitive damages in amounts to be proven at trial, and costs and attorneys' fees.