The complaint

Marriott International, Inc. v. HBB Hospitality LLC, No. 3:26-cv-00409 (S.D. Tex.), is a 22-page complaint filed November 10, 2026, in the Galveston Division, ECF No. 1, with a jury demand. The complaint says its allegations are based on Marriott's knowledge, information, and belief. Marriott is a Delaware corporation based in Bethesda, Maryland. HBB Hospitality LLC is described as a Texas limited liability company that owns and operates a hotel in Galveston, Texas. The complaint pleads jurisdiction under 15 U.S.C. § 1121 and 28 U.S.C. §§ 1331, 1338(a), 1338(b), and 1367, and venue under 28 U.S.C. § 1391.

The marks

The complaint lists five registrations in Class 43 as Marriott's Registrations and calls them valid, subsisting, and incontestable. USPTO status records show each registered to Marriott International, Inc.: Reg. No. 1,305,416 (RESIDENCE INN, standard characters, hotel services), registered November 13, 1984; Reg. No. 1,439,596 (RESIDENCE INN, typed word mark, hotel and motel services), registered May 12, 1987; Reg. No. 3,635,354 (RESIDENCE INN BY MARRIOTT, standard characters), registered June 9, 2009; Reg. No. 5,618,981 (RESIDENCE INN BY MARRIOTT in a stylized font), registered November 27, 2018; and Reg. No. 5,880,482 (RESIDENCE INN MARRIOTT in stylized fonts), registered October 8, 2019. The first three show as renewed, and the last two show accepted combined Section 8 and 15 declarations. The complaint says the RESIDENCE INN brand covers more than 900 hotel properties worldwide and that Marriott has used its RESIDENCE INN marks for over 40 years.

What the complaint alleges

The complaint alleges that the hotel formerly operated under another hotel brand, that HBB Hospitality filed for the assumed name “The Residency Inn” on May 16, 2023, and that it rebranded the hotel under that name in or before July 2023. It says a RESIDENCE INN hotel opened in Galveston in March 2024, about three miles away. According to the complaint, Marriott learned of the name in 2026 after receiving a December 12, 2025 letter about an incident at the hotel that referred to it as a Residence Inn.

The complaint alleges that consumer reviews show guests booked the hotel believing it was a RESIDENCE INN property, quoting one guest who reported being “fooled by the NAME,” and that the hotel has drawn very poor reviews, which Marriott says harms its marks by association. It alleges that Marriott sent a demand letter on March 23, 2026, to the hotel and to a company it then believed owned it, and a second letter on September 10, 2026, to HBB Hospitality and two people it is informed and believes are the company's managing members, and that it received no response to either. Marriott says it is informed and believes the company still uses the name.

The claims

  • Federal trademark infringement under 15 U.S.C. § 1114(1).
  • Federal unfair competition under 15 U.S.C. § 1125(a).
  • Federal trademark dilution under 15 U.S.C. § 1125(c).
  • Trademark infringement and unfair competition under Texas common law.
  • Trademark infringement under Tex. Bus. & Com. Code § 16.102(b).
  • Unfair competition by misappropriation under Texas common law.
  • Trademark dilution under Tex. Bus. & Com. Code § 16.103.

Relief requested

Marriott asks for judgment on each claim; a permanent injunction against offering services under “The Residency Inn” or other confusingly similar imitations of its marks, using its marks, and passing off; an order, within 30 days of judgment, to remove interior and exterior signage referring to “The Residency Inn” or “Residency Inn,” deliver up promotional materials for impoundment and destruction, transfer to Marriott domain names containing those terms, including theresidencyinngalveston.site, and file a sworn compliance report; damages; an accounting of profits; trebled damages and enhanced profits under 15 U.S.C. § 1117(a); attorneys' fees and costs under 15 U.S.C. § 1117(a), Federal Rule of Civil Procedure 54(d)(1), and the state statutes and common law cited; exemplary damages; prejudgment and post-judgment interest; and other relief the court deems just and proper.