What was filed

The complaint is Document 1 in NIC Industries, Inc. v. Elio Keller d/b/a Ceracoat and the Unknown Individuals and Entities Operating ceracoat.me, No. 1:26-cv-11463 (N.D. Ill., Eastern Division), filed September 18, 2026. It runs 13 pages and demands a jury trial. The docket shows the case randomly assigned to Judge John Robert Blakey, with Magistrate Judge Laura K. McNally designated.

The marks

The complaint relies on Reg. No. 4,068,382 for CERAKOTE, which it says is incontestable, and Reg. No. 7,348,021 for CERAKOTE RAPID CERAMIC. USPTO TSDR lists both as owned by NIC Industries, Inc.: Reg. No. 4,068,382 in Classes 1 and 2, including ceramic based sealants and coatings for firearms, and renewed; and Reg. No. 7,348,021, registered April 2, 2024, for sealer coatings in Class 2.

What the complaint alleges

The complaint alleges that the defendants run an interactive website at ceracoat.me selling protectant, ceramic coating, and automotive products bearing CERACOAT and CERACOAT CERAMICS, and that a purchase by the plaintiff's investigator was shipped to Illinois. It alleges CERACOAT is confusingly similar to CERAKOTE because it shares the same opening letters and ends in the same sounding KOTE or COAT, and that CERACOAT CERAMICS also shares the term ceramic with CERAKOTE RAPID CERAMIC. On information and belief, it alleges the defendants know of the fame and strength of the CERAKOTE marks, and it alleges the infringement was willful.

Claims and relief

The three counts are trademark infringement of the CERAKOTE Trademarks, false designation of origin under 15 U.S.C. § 1125(a), and violation of the Illinois Uniform Deceptive Trade Practices Act. The complaint seeks injunctive and monetary relief.