The complaint
Reflex MD, Inc. v. Dynamic Trading Enterprises, LLC, d/b/a Join Layla, and Gabriel Vaturi a/k/a Gabriel Zion Vaturi, No. 1:26-cv-27682-JEM (S.D. Fla., Miami Division), is a complaint filed October 29, 2026, ECF No. 1, with a jury demand. The clerk's notice of judge assignment assigns the case to Judge Jose E. Martinez. Reflex MD, a Delaware corporation, says it sells semaglutide through its telehealth platform at reflexmd.com. Dynamic Trading Enterprises is a Pennsylvania limited liability company that the complaint says has operated a competing semaglutide telehealth platform under the name Join Layla at joinlayla.com since about 2022. The complaint describes Vaturi as a principal of Dynamic Trading Enterprises. (Compl. paras. 1 to 4, 40.)
The trade dress
Count V alleges trade dress infringement and false designation of origin under section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), against Dynamic Trading Enterprises only. Reflex MD alleges it developed and used a distinctive overall visual presentation for its website in advertising and selling its semaglutide product (the "Plaintiff Trade Dress"): the combination and arrangement of the site's color palette; placement and presentation of headings, text, images, and graphics; page composition and visual hierarchy; arrangement and sequencing of content; presentation of product information and purchasing or reordering features; spacing among visual elements; and the consistent overall appearance of the site. It alleges those elements are nonfunctional and identify Reflex MD as the source. (Compl. paras. 85 to 92.)
What the complaint alleges
The complaint alleges that Join Layla's earlier site was in no way similar to Reflex MD's and that Dynamic Trading Enterprises then copied substantial portions of Reflex MD's website text, HTML, and appearance, and it alleges, on information and belief, that the copying of the HTML began in or about September 2023. It says Reflex MD learned of the possible copying on or about November 3, 2023, and that after Reflex MD's demand, made when it discovered the full extent of the copying in early December 2023, Dynamic Trading Enterprises discontinued or removed the copied content. On the trade dress count, it alleges Dynamic Trading Enterprises intentionally adopted a website presentation that copied or closely imitated the Plaintiff Trade Dress, and that the similarity caused confusion, or a likelihood of confusion, among customers, including repeat customers, and risked diverting them. (Compl. paras. 24, 25, 37, 47, 49, 90, 94 to 99.)
Claims and relief requested
On Count V, Reflex MD asks for a judgment of trade dress infringement and false designation of origin, Dynamic Trading Enterprises' profits, its own actual damages, and costs under 15 U.S.C. § 1117(a), and an accounting. Counts VI and VII allege unfair competition against Dynamic Trading Enterprises under the Florida Deceptive and Unfair Trade Practices Act and Florida common law and seek actual damages and, under FDUTPA, attorney's fees. The other counts allege copyright infringement of an HTML literary work and a website compilation (Counts I and II), removal of copyright management information under 17 U.S.C. § 1202 (Count III), and tortious interference (Count IV) against Dynamic Trading Enterprises, and contributory and vicarious copyright infringement against Vaturi, in part on information and belief (Counts VIII and IX). (Compl. Counts I to IX.)
Docket
The docket shows summonses issued to both defendants on October 29, 2026 (ECF No. 4).