Universal Services of America and Universal Protection Service sue an LLC and three individuals, alleging Allied Universal marks appear in social media videos

What was filed

The complaint is Document 1, filed October 26, 2026, in the U.S. District Court for the Central District of California, Western Division. The case is Universal Services of America, LP et al. v. Lebaron et al., No. 2:26-cv-12526. It runs 34 pages. The plaintiffs are Universal Services of America, LP, which the complaint describes as a Delaware limited partnership with its principal place of business in Santa Ana, California, and Universal Protection Service, LP, described as a California limited partnership with its principal place of business in Conshohocken, Pennsylvania. The defendants are Chad LeBaron, Jimmy Sundays, Kyle Eddie, and Cherdleys, LLC. The complaint alleges, on information and belief, that the three individuals are California residents, that Chad LeBaron is known online as "Cherdleys," and that Cherdleys, LLC is a California limited liability company based in North Hollywood, California. The complaint is signed by Megan A. Chacon of Fish & Richardson P.C. in Newport Beach, California, and also lists Cynthia J. Walden, Katie Roche, and Anne Hartnett, each with a pro hac vice application forthcoming. The plaintiffs demand a jury.

The marks and the patch

The complaint says the plaintiffs assert the ALLIED UNIVERSAL Marks and lists U.S. Reg. Nos. 7,307,884, 6,630,054, 7,159,787, and 7,877,285 for ALLIED UNIVERSAL, plus Reg. No. 5,302,678 for an ALLIED UNIVERSAL design and Reg. No. 5,150,269 for an ALLIED UNIVERSAL SECURITY SERVICES patch design. Count I cites Reg. Nos. 6,630,054, 7,159,787, 5,302,678, and 5,150,269. USPTO TSDR lists Universal Services of America, LP as owner of all six and shows each as live on the Principal Register: 6,630,054 registered January 25, 2022; 7,159,787 registered September 12, 2023; 7,307,884 registered February 20, 2024; 7,877,285 registered August 5, 2025; 5,302,678 registered October 3, 2017, with Sections 8 and 15 accepted; and 5,150,269 registered February 28, 2017, with Sections 8 and 15 accepted. The complaint also asserts U.S. Copyright Registration No. TX 8-857-267 for the Allied Universal Security Services Patch Design, registered effective October 1, 2019.

What the complaint alleges

The complaint alleges that, since at least March 2025, the defendants have created, published, promoted, distributed, and monetized videos under the Cherdleys brand that feature the ALLIED UNIVERSAL Marks, the Allied Patch Design, and Allied Universal security uniforms and related identifiers without authorization. It alleges that the videos portray an apparent Allied Universal security officer engaging in sexually inappropriate, predatory, and offensive conduct directed at a skateboarder portrayed by Jimmy Sundays, and that Chad LeBaron appears as the officer in at least one Instagram video. It alleges, on information and belief, that viewers associated the depicted conduct with Allied Universal and tagged the company in comments. It says Allied Universal sent a March 14, 2025, notice of copyright and trademark infringement and an April 25, 2025, follow-up demand, submitted platform complaints, and that some videos were removed, but that the defendants continued posting, including Instagram videos on or about October 4 and 5, 2026, with hundreds of thousands to more than 1.8 million views as of October 21, 2026, and Facebook videos on or about October 12, 2026. It alleges, on information and belief, that each defendant had the right and ability to supervise, direct, or control the conduct, and it alleges that the infringement was knowing, intentional, and willful.

Claims and relief requested

The plaintiffs bring seven counts against all defendants: trademark infringement and counterfeiting under 15 U.S.C. §§ 1114 and 1117 (Count I); false designation of origin under 15 U.S.C. § 1125(a) (Count II); trademark dilution by tarnishment under 15 U.S.C. § 1125(c) (Count III); copyright infringement under 17 U.S.C. §§ 101 et seq. (Count IV); trademark dilution under California Business and Professions Code § 14247 (Count V); common law trademark infringement (Count VI); and common law trade libel (Count VII). The prayer asks for a judgment on all claims; a preliminary injunction, temporary restraining order if appropriate, and permanent injunction against using the marks, the patch design, and related content; removal and permanent deletion of the accused videos and related materials from sites and platforms within the defendants' custody or control; delivery or destruction of Allied Universal uniforms, patches, badges, and credentials in the defendants' possession; an accounting of how those items were obtained; an accounting of profits and a constructive trust; actual damages and profits; statutory damages for willful copyright infringement under 17 U.S.C. § 504; enhanced or trebled Lanham Act relief for willful conduct; exemplary and punitive damages; pre-judgment interest; and attorneys' fees and costs.