The complaint

ZSPEC Design LLC v. Titanium LLC, No. 1:26-cv-02335 (N.D. Ohio), is a nine-page complaint filed September 17, 2026, ECF No. 1. The case is assigned to Judge J. Philip Calabrese. ZSPEC, an Ohio limited liability company based in Chardon, Ohio, says it has sold automobile fasteners and hardware since 2008 and has used DRESS UP BOLTS for its hardware products since then. It describes Titanium, on information and belief, as a Virginia limited liability company. (Compl. paras. 3 to 7.)

The mark and the earlier cancellation proceeding

ZSPEC pleads Registration No. 5,868,348 for DRESS UP BOLTS, issued September 24, 2019 for "Metal bolts; Metal hardware, namely, washers." According to the complaint, Titanium petitioned the Trademark Trial and Appeal Board to cancel the registration on February 11, 2022, in Proceeding No. 92079042; the Board ruled for ZSPEC in a decision dated August 12, 2024; and the Federal Circuit affirmed in Appeal No. 25-1071 by a judgment dated March 11, 2026 and issued its mandate on April 17, 2026. (Compl. paras. 14, 15, 27 to 32.) USPTO TSDR lists ZSPEC Design LLC as the owner and shows that the Board terminated a cancellation proceeding on June 25, 2026.

What the complaint alleges

The complaint alleges that Titanium uses DRESS UP BOLTS on its website, packaging, advertising, and promotional materials for metal bolts and hardware for automobiles, including washers, marketed nationwide to automotive enthusiasts, and that the use creates a likelihood of confusion. It alleges, on information and belief, that Titanium acted in bad faith, including by registering ZSPEC's business name as a domain name, and it says Titanium kept promoting the mark after losing the cancellation proceeding and the appeal. (Compl. paras. 16 to 26, 37, 38.)

Claim and relief requested

The single count, brought by ZSPEC against Titanium, is trademark infringement under the Lanham Act, 15 U.S.C. § 1051 et seq. ZSPEC asks for a judgment that its registered mark has been infringed, a permanent injunction against use of the mark and confusingly similar marks in the United States, an accounting of profits, damages, costs under 15 U.S.C. § 1117(a), and trebled damages and reasonable attorneys' fees under § 1117(b) for what it calls willful infringement. (Compl. paras. 35, 36, 39 to 47 and prayer.)