The complaint

Verduin v. Bowman, No. 3:26-cv-03076 (M.D. Fla.), is a 25-page Consolidated Complaint for Trademark Infringement, Unfair Competition, Declaratory Relief, and Related State and Federal Claims, filed November 6, 2026 in the Jacksonville Division by Terry Verduin, who represents herself and verified the complaint. The defendants are Marina J. Bowman, an individual the complaint says lives in Florida and writes under the pen name M.K. Radican; Code Pineapple LLC, a Florida limited liability company the complaint calls her alter ego; Amazon.com, Inc.; and Amazon.com Services LLC.

The marks

Verduin asserts two registrations. USPTO TSDR shows GOOPY GHOST in standard characters, Reg. No. 4,018,083, registered August 30, 2011 and renewed, for a series of fiction books in Class 16, and V. R. DUIN, Reg. No. 7,103,418, registered July 11, 2023, for a series of printed children's books in Class 16, both owned by Terry Verduin. The complaint says she granted a nonprofit a non-exclusive distribution license and kept full ownership and enforcement rights.

What Verduin alleges

Against the author and Code Pineapple, the complaint alleges that in February 2026 Verduin found their children's book "Zombie Reconstruction Squad - Book 1: The Goopy Ghosts" occupying her GOOPY GHOST slot in online listings, that the title causes source confusion and tarnishes her mark, and that she sent them a desist notice on September 30, 2026 without a response.

Against Amazon, the complaint alleges that after Verduin closed her Kindle Direct Publishing account in June 2025 and later revoked her licenses, Amazon kept detail pages and author pages for her titles, displayed listings without inventory and at inflated prices, generated listings for titles she says she never released on Amazon, split her author name into several variants, and kept the competing book listed after her written notices, and that Amazon's crawlers burdened her own websites. It says Amazon referred her to its Brand Registry process.

The claims

Count I alleges trademark infringement and unfair competition under 15 U.S.C. § 1125(a) against the author and Code Pineapple. Count II alleges contributory trademark infringement under 15 U.S.C. §§ 1114 and 1125(a) against the two Amazon entities. The other counts seek a declaratory judgment that her publishing agreements with Amazon are void as unconscionable, and allege violation of the Florida Deceptive and Unfair Trade Practices Act and Fla. Stat. § 495.151, noncompliance with Florida's fictitious name statute, an accounting, defamation, false attribution and misappropriation of name and likeness under Fla. Stat. § 540.08, and trespass to chattels, unfair competition, and conversion.

Relief

Verduin asks for declarations, emergency, preliminary, and permanent injunctions under 15 U.S.C. § 1116(a) barring Amazon.com Services LLC from displaying, selling, indexing, or using GOOPY GHOST in connection with the competing title, orders requiring Amazon to remove listings, author pages, and search keywords tied to her marks and to block new ones, impoundment of inventory, an accounting, profits and treble damages under 15 U.S.C. § 1117, out-of-pocket losses the complaint puts at $224,850, interest, and costs.

Docket

With the complaint, Verduin filed an emergency motion for a preliminary injunction and declaratory relief, a motion for leave to file an exhibit group, and a motion for leave to file electronically. Summonses were issued to all four defendants and a trademark report was sent to the USPTO on November 6, 2026. The case is assigned to Judge Jordan Emery Pratt. The docket shows an order and a notice to counsel of the local rules entered November 9, 2026.