The complaint
Sierra Zagarri LLC v. Carolyn's Creative Classroom LLC, No. 4:26-cv-01935 (E.D. Mo.), is a 19-page complaint filed November 10, 2026. Sierra Zagarri is a Missouri limited liability company with its principal place of business in St. Louis, Missouri, and the complaint says it operates under the trade name Grandma's Playroom, a children's indoor play facility. Carolyn's Creative Classroom LLC is a Florida limited liability company. The complaint says that, although Sierra Zagarri acquired Grandma's Playroom in June 2020, the business had used the phrase "yuck bucket" since at least 2019 under its predecessor in interest, and that Sierra Zagarri continued that use after the acquisition.
The dispute
The complaint alleges that, since at least May 8, 2019, Sierra Zagarri has used the phrase "yuck bucket" to describe a physical bucket at its facility into which dirty, mouthed, contaminated, or otherwise unsanitary toys are placed pending cleaning and sanitization, and that the use is ordinary descriptive language rather than trademark use. It alleges that Carolyn's Creative Classroom claims ownership of U.S. Registration No. 6,770,397 for YUCK BUCKET, asserted that the registration prohibits Sierra Zagarri's use, demanded that it cease or restrict that use, and demanded payment of $75,000. It also alleges that trademark infringement complaints were then submitted to TikTok concerning Sierra Zagarri's original videos depicting or discussing its own bucket and sanitization procedures, that TikTok removed at least one video and issued strikes or warnings affecting the account, and, on information and belief, that the defendant's manager submitted the complaints on the defendant's behalf. United States Patent and Trademark Office records list Registration No. 6,770,397 as a live Principal Register standard-character registration for YUCK BUCKET, owned by Carolyn's Creative Classroom, LLC, a Florida limited liability company. The registration issued June 28, 2022, from a use-based application filed May 13, 2020, Serial No. 88,914,222, with a claimed first-use date of May 13, 2020, and it covers downloadable educational course materials in the field of health, wellness, cleanliness and personal hygiene in International Class 9, and educational publications, namely, educational learning cards, flash cards, activity cards, workbooks, textbooks, activity books, story books, puzzle books, printed puzzles, teacher guides, manuals, posters and educational booklets in the fields of health, wellness, cleanliness and personal hygiene, in International Class 16. The complaint disputes the validity, scope, and enforceability of the registration, says the registration's prosecution history raises questions about whether YUCK BUCKET functioned as a trademark for the identified goods and whether qualifying use in commerce existed when the application was filed, says Sierra Zagarri intends to challenge the registration in a separate Trademark Trial and Appeal Board proceeding, and states that it does not presently request cancellation in this action.
Counts and relief
The complaint pleads two counts against Carolyn's Creative Classroom LLC. Count I seeks a declaratory judgment of trademark non-infringement and descriptive fair use under the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202, and the Lanham Act, 15 U.S.C. §§ 1114, 1115(b)(4), and 1125(a). Count II seeks supplemental declaratory and equitable relief under 28 U.S.C. §§ 2201 and 2202, including, to the extent authorized, narrowly tailored relief preventing the defendant from knowingly submitting materially false trademark infringement complaints concerning uses the court determines to be lawful, and permission to provide any resulting judgment to TikTok and other platforms. The prayer asks the court to declare that Sierra Zagarri's use of the phrase to identify a physical container for dirty, contaminated, or mouthed toys awaiting cleaning does not infringe the defendant's asserted trademark rights, that the use is descriptive, made otherwise than as a trademark, made fairly and in good faith, and constitutes descriptive fair use under 15 U.S.C. § 1115(b)(4), that the use, including in original social media videos depicting its cleaning procedures, is not likely to cause confusion as to affiliation, sponsorship, or approval, and that the registration does not confer exclusive rights to prohibit those identified descriptive uses. It also asks for supplemental relief under 28 U.S.C. § 2202, including relief identifying the adjudicated uses with enough specificity to support restoration requests to TikTok and other platforms, a narrowly tailored injunction against knowingly submitting materially false complaints concerning those uses, an order requiring the defendant to withdraw or correct identified complaints, reasonable attorneys' fees under 15 U.S.C. § 1117(a) if the court finds the case exceptional, taxable costs under 28 U.S.C. § 1920 and Federal Rule of Civil Procedure 54(d), and other relief.