Kindras Group, owner of the MIRSTORES knitwear brand, sues Mother LLC over a sheep design on a cardigan: complaint allegations

What was filed

The complaint is Document 1, filed October 19, 2026, in the U.S. District Court for the Southern District of New York. The case is Kindras Group LLC v. Mother LLC, No. 1:26-cv-09150. It pleads two causes of action: copyright infringement under 17 U.S.C. § 101 et seq., and federal trademark infringement, false designation of origin and passing off, and unfair competition under 15 U.S.C. § 1125(a). Kindras demands a jury trial. Counsel are Francesca Witzburg and Cassidy Moon of ESCA Legal LLC. The complaint runs 21 pages and lists three exhibits: the copyright registration materials, the trademark records, and listings for the accused product.

The parties and the design

The complaint says Kindras Group LLC is organized under the laws of Sharjah, United Arab Emirates, with its principal place of business in Sharjah, and operates MIRSTORES, a knitwear brand founded in 2015 by a predecessor. It describes Mother LLC as a Delaware limited liability company that, on information and belief, has its principal place of business in Vernon, California, and as an apparel brand that sells through motherdenim.com and third-party retailers.

According to the complaint, Kindras adopted the Sheep Design in 2023 as a secondary source identifier for MIRSTORES, has used it on sweaters, cardigans, socks, scarves, mittens, and hats, and has used it in U.S. commerce on clothing since at least November 2025. It says Kindras owns International Registration No. 1926282, registered with WIPO on April 14, 2026, and the pending U.S. extension, Application No. 79453553, for goods in Classes 24 and 25. USPTO records list the application as under examination, with a non-final Office action (a refusal sent to the International Bureau) issued on October 5, 2026. On the copyright side, the complaint says Kindras obtained by assignment U.S. Copyright Registration No. VA 2-505-241, effective February 18, 2026, and that its request to record the assignment was pending when it filed. Copyright Office records list the registration, titled Sheep Character Artwork and Textile Surface Design, with the individual author as claimant and a first publication date of October 11, 2023 in Russia, and now show the assignment to Kindras Group LLC as recorded, with a recordation date of October 5, 2026.

What the complaint alleges

The complaint says Kindras pleads matters about itself on personal knowledge and all other matters on information and belief. Kindras alleges that since as early as January 2026 Mother has sold the Crop Raquette cardigan with a sheep figure that copies the specific combination of elements in its design: a side profile, a rounded cloud-like body with a scalloped top edge and a continuous black outline, a raised wool-like fill, an open-loop head, small curled ears or horns, four thin legs, and no facial features. It alleges access through overlapping U.S. retail channels and online publicity, and similar price points ranging between $330 and $535.

For actual confusion, the complaint points, on information and belief, to an online commenter who identified as an employee of a retailer and mistook a MIRSTORES sheep product for the Mother cardigan. It says Kindras sent a demand letter on July 17, 2026, that Mother refused to comply, that the cardigan was available for purchase at least as recently as September 23, 2026, and that as of filing Mother still displays the design in content on its website and social media.

Relief requested

The prayer asks for a declaration of willful infringement under the Copyright Act and the Lanham Act, damages including treble, punitive, or statutory damages where authorized, an accounting and disgorgement of profits, an injunction under 15 U.S.C. § 1116 and 17 U.S.C. § 502, destruction of infringing materials under 15 U.S.C. § 1118 and 17 U.S.C. § 503, interest, and attorneys' fees and costs. The complaint states no damages figure.