Second Amended Complaint - LegalForce v. LegalZoom & USPTO

Case 3:17-cv-07194-MMC Document 84-1 Filed 03/21/18 Page 1 of 45
RAJ V. ABHYANKER, California SBN 233,284

Email: raj@legalforcelaw.com
WENSHENG MA, California SBN 299,961
Email: vincent@legalforcelaw.com
LEGALFORCE RAPC WORLDWIDE, P.C.

1580 W. El Camino Real, Suite 10
Mountain View, CA 94040
Telephone: (650) 965-8731
Facsimile: (650) 989-2131
Attorneys for Plaintiffs,

LegalForce RAPC Worldwide, P.C. and
LegalForce, Inc.
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
LEGALFORCE RAPC WORLDWIDE, Case No. 3:17-cv-07194-MMC

P.C.; and
LEGALFORCE, INC., Judge: Honorable Maxine M. Chesney
Plaintiffs, SECOND AMENDED COMPLAINT FOR:
v. 1. DECLARATORY JUDGMENT ACT, 28

U.S.C. § 2201;
LEGALZOOM.COM, INC.; 2. LANHAM ACT, 15 U.S.C. § 1125(a);
UNITED STATES PATENT & 3. CALIFORNIA FALSE AND
TRADEMARK OFFICE; MISLEADING ADVERTISING;
and DOES 1-50, INCLUSIVE, 4. CALIFORNIA UNFAIR
COMPETITION;
5. VIOLATION OF SUBSTANTIVE DUE
Defendants. PROCESS; and
6. VIOLATION OF EQUAL
PROTECTION.
JURY TRIAL DEMANDED
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SECOND AMENDED COMPLAINT
CASE NO.: 3:17-CV-07194-MMC
Plaintiffs LegalForce RAPC Worldwide, P.C. (“LegalForce RAPC”) and LegalForce,

Inc. (collectively “Plaintiffs” or “LegalForce”) allege as follows upon actual knowledge with
respect to themselves and their own acts, and upon information and belief as to all other matters.
NATURE OF ACTION
LegalZoom and LegalForce compete to provide small businesses with affordable access
to legal services that allow them to protect their business names, logos, and slogans through
trademark filing with the U.S. Patent and Trademark Office (“USPTO”). Both use technology
and innovation to provide trademark filing services for hundreds of dollars instead of the
thousands of dollars that traditional law firms charge. They are the two biggest competitors for
low-priced trademark filing services.
But while LegalForce has innovated within the existing regulatory framework that
protects consumers from bad legal advice and unscrupulous practices, LegalZoom has
attempted to operate outside of it. LegalZoom’s advertisements deceive consumers into
believing that all they need is LegalZoom’s non-attorney “legal help,” not services of a licensed
U.S. trademark attorney. In the fine print, LegalZoom disclaims any notion that it is providing
legal advice or that it has any of the duties that would otherwise protect its customers.
LegalZoom’s non-attorney trademark filing services regularly require its non-attorney
“specialists” to provide unlawful and sometimes faulty legal advice that harms its customers’
trademark interests. LegalZoom has thus far avoided discipline from the USPTO. By asserting
that it is not practicing law, LegalZoom has convinced the USPTO not to investigate or
challenge their illegal business model.
LegalForce, on the other hand, provides its legal services through a U.S. law firm
(LegalForce RAPC) that performs conflict checks, maintains IOLTA accounts, and involves
licensed U.S. trademark attorneys who provide legal advice and supervision throughout the
process. It is able to offer quality representation at much lower prices than traditional trademark
law firms because of its innovation, technology and volume. For example, it uses technology to
automate its work flow and separate the tasks that require U.S. trademark attorney involvement
from everything else.
2
LegalZoom has a substantial cost advantage over LegalForce because it illegally uses
non-attorneys in the trademark filing process where legal ethic rules set by the USPTO seem to
require attorneys. LegalForce contends that LegalZoom’s entire trademark business is built
upon the foundation of the unauthorized practice of law. If the law were or is otherwise,
LegalForce would and could substantially reduce its costs to compete on a level playing field
with LegalZoom.
The USPTO has not applied its regulations governing lawyers and law firms to
LegalZoom, despite LegalZoom having filed at least 250,000 trademark applications on behalf
of consumers--more than any other filer. The USPTO thus prevents LegalForce from competing
with LegalZoom despite the potential for consumer harm by LegalZoom’s services. The
USPTO thus treats LegalZoom and LegalForce differently under the law in an arbitrary,
capricious, and unreasonable way and deprives LegalForce of its fundamental right to pursue
and compete in its chosen trade or profession.
Resolution of LegalForce’s claims in this second amended complaint require this Court to
first determine “whether LegalZoom is engaged in the unauthorized practice of law with regard
to trademark filings.” If LegalZoom is engaged in the practice of law, its advertisements and
promotions that suggest it can assist with customer trademark filings without following the
ethical requirements of lawyers imposed by USPTO regulations are literally false.
If this Court concludes that LegalZoom is not engaged in the practice of law, then its
advertisements that provide consumers with “legal help” among others, are misleading. They
give the impression that they are receiving qualified advice and representation that affects their
legal rights when, in fact, they are not. Either way, LegalForce has lost significant business as a
result of LegalZoom’s false and misleading promotional statements. Because many LegalZoom
advertisements and promotions would be literally false if this Court were to hold that
LegalZoom is engaged in the unauthorized practice of law, this case will definitively answer the
question of the legality of LegalZoom’s trademark business model.
//
//
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THE PARTIES
The Plaintiffs
1. Plaintiff LegalForce RAPC Worldwide, P.C. (“LegalForce RAPC”) is a law firm wholly
owned by Raj Abhyanker, a member in good standing of the State Bar of California, and the
United States Patent Bar. The firm practices patent and trademark law before the USPTO with a
principal place of business at 1580 W. El Camino Real, Suite 10, Mountain View, CA 94040,
and a law office located at 446 E. Southern Ave., Tempe, AZ 85282.
2. Plaintiff LegalForce, Inc. is a Delaware corporation offering law firm automation and
free trademark search services through its website Trademarkia.com with a principal place of
business at 1580 W. El Camino Real, Suite 9, Mountain View, CA 94040.
The Defendants
3. LegalZoom.com, Inc. is a Delaware corporation (“LegalZoom”) with a principal place
of business at 101 N. Brand Blvd., Glendale, CA 91203. LegalZoom is not a law firm in the
United States and is not authorized to practice law in any state. LegalZoom is not a registered or
bonded legal document assistant under California Business and Professions Code, § 6400 et seq.
4. Defendant, the United States Patent & Trademark Office (“USPTO”), a branch of the
United States Department of Commerce, is being added as a necessary defendant as it governs
the conduct of U.S. state licensed attorneys and registered patent attorneys before the United
States Patent & Trademark Office, with a principal place of business at 600 Dulany Street,
Alexandria, VA 22314. The United States Patent & Trademark Office also maintains a Silicon
Valley office located at 26 S. 4th St., San Jose, California 95112.
JURISDICTION AND VENUE
5. This Court has subject-matter jurisdiction over this action under 28 U.S.C. §§ 2201,
1331, and 1346(a) because this action arises under federal law and because Plaintiffs seek a
declaration of rights to resolve an actual case or controversy arising under federal law. This
Court has supplemental jurisdiction over the state law claims under 28 U.S.C. § 1367 because
they arise from the same nucleus of operative facts as the federal claims.
6. This Court has general personal jurisdiction over LegalZoom because LegalZoom’s
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principal place of business is in California. Alternatively, this Court has specific personal
jurisdiction over LegalZoom because LegalZoom purposefully directed its advertisements or
promotions at consumers in this district and caused harm to Plaintiffs in this district.
LegalZoom thus has minimum contacts with the State of California and those contacts are
related to this lawsuit. Moreover, LegalZoom has waived any objection by filing a responsive
pleading.
7. This Court has general personal jurisdiction over the USPTO because the USPTO is a
federal agency having a satellite office in this district. Alternatively, this Court has specific
personal jurisdiction over USPTO because it has applicants for trademarks in this district as
well as licensed U.S. trademark attorneys to practice before it in this district. The USPTO thus
has minimum contacts with the State of California and those contacts are related to this lawsuit.
8. Venue is proper in the United States District Court for the Northern District of
California under 28 U.S.C. § 1391 because a substantial part of the events or omissions giving
rise to this action occurred in this district.
SUBSTANTIVE ALLEGATIONS
LegalZoom’s False and Misleading Advertisements
9. LegalZoom is the largest filer of trademarks before the U.S. Patent and Trademark
Office. It boasts that it has filed over 250,000 trademark applications, which amounts to over
25,000 applications per year in recent years and represents about 8% of all U.S. brands. It is
also the top purchaser of Google AdWords related to terms involving trademark filing before
the USPTO, spending more than $100,000 per month for such terms as “trademark attorney.”
10. LegalZoom advertisements and other promotional statements are false and misleading to
reasonable consumers. For example:
a. Although LegalZoom represents on its website that it does not practice law, in
context this representation is false and/or misleading.
b. LegalZoom intentionally misleads customers by misdirecting web traffic from
web pages related to its “attorney led” service to its “peace of mind” non-attorney
service.
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c. Endorsements from well-known attorneys such as Robert Shapiro, which misleads

consumers to believe that LegalZoom provides legal advice as these attorneys
provide.
d. Despite the fact that LegalZoom is not a law firm and does not hire any attorneys
representing external clients, LegalZoom purchases advertisements whenever
consumers search terms related to the practice of trademark law, such as
“trademark attorney” and “trademark lawyer”, with copy that misleads consumers
into believing that they will be represented by attorneys. This is misleading to
consumers.
e. Ad copy: “Trademark Search - Avoid Costly Trademark Conflicts,” which
misleads consumers to believe that LegalZoom can provide them with legal
assistance in avoiding trademark conflicts and that conflict checks by law firms
such as LegalForce RAPC are harmful to them and should be avoided.
f. Ad copy: “Trademark Registration - What Can We Help You Protect?,” which
misleads consumers to believe that LegalZoom can represent them and provide
legal advice in connection with a trademark application. It also implies
LegalZoom is selling trademark registration (which is what USPTO does) rather
than a filing service.
g. Ad copy: “Register Your Trademark - Protect What’s Important with a
Trademark,” which misleads in the same way as subparagraph (f) above.
h. Ad copy: “Trademarks & Copyrights - Find the IP Protection For You,” which
misleads consumers to believe that LegalZoom can provide legal advice and
representation in connection with intellectual property.
i. Publicized customer “review”: “Instead of expensive meetings at a law office,
LegalZoom’s website and a few helpful phone calls had me on my way to a
trademark approval,” which misleads consumers to believe that LegalZoom is a
cheaper, internet-based law firm that can provide legal advice and representation
in connection with trademark filing.
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j. Statement on LegalZoom’s website: “[y]our team of attorneys will be there to

answer your questions, monitor the progress of your application, and take action
when necessary” is false and misleading because LegalZoom is not a law firm and
cannot provide legal advice, and “attorneys” referred to here are not LegalZoom’s
employees but rather independent lawyers in independent law firms which may
only be separately retained by subscribers of LegalZoom’s legal plan. This
statement creates a false and misleading impression that LegalZoom is a law firm,
or at least operates like one and can directly provide legal advice.
11. In addition:
a. LegalZoom uses advertising links that appear to be describing an attorney-led
service as a bait to attract consumers to click on them, but then directs these same
consumers to the non-attorney “Peace of Mind” service.
b. In particular, one of LegalZoom's Google ads contains the statement “File Your
Application With The Help Of An Independent Trademark Attorneys” and “$599
+ Gov’t Fees.” A reasonable consumer would think that by clicking this link the
page will go to a LegalZoom web page offering attorney-led service. However,
the landing page is actually a page offering non-attorney service -- “peace of
mind” review. The word “Independent” disappears in the heading, creating an
impression that the licensed attorney with whom the consumer can consult is an
in-house attorney of LegalZoom or that LegalZoom can provide legal services
just as any attorney could. Surreptitiously, the word “independent” is hidden in
the boilerplate disclaimer on the bottom of the page in a much smaller font. The
description of the actual attorney-led service offered at “$599 + Gov’t Fees.” is
shown on another attorney-led service web page, which is not the landing page
and is not directly linked to the advertising link. By employing this sleight of
hand, LegalZoom misleads consumers who click the link into believing that the
“peace of mind” service is an attorney-led service.
c. Another LegalZoom’s ad page has a large orange link at the bottom saying “Learn
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more about attorney-led trademark registration”, which misdirects consumers to a

non-attorney “peace of mind” service landing page instead of the attorney-led
service page. LegalZoom argues that it “has a clear and conspicuous option to
‘speak with an attorney” and that attorneys can be accessed by those customers
which additionally and separately subscribe to its “legal plans.” However, this is
again a trick employed by LegalZoom. First, “speak to an attorney” does not
mean that it is offering an “attorney-led” service. Second, the main focus of the
page is directed to the $199 and $219 non-attorney filing options located at the
center of the web page. The option of “speak to an attorney” is placed at the
bottom of the page where customers must scroll down to find it. Moreover, the
option is not even at the center of the bottom. What is at the center is a
non-attorney specialist hotline. This deliberate arrangement and visual ‘sleight of
hand’ misleads reasonable consumers interested in an attorney-led service into
buying LegalZoom’s non-attorney “peace of mind” service.
12. LegalZoom’s advertising specifically targets its attorney competitors, particularly
LegalForce:
a. LegalForce and LegalZoom are the two largest purchasers of online advertising
(including Google and Bing) for trademark filing-related search terms/keywords.
b. LegalZoom outbid LegalForce on Google and Bing for those keywords during
2017, allowing it to achieve a higher impression share and average position on
search engines.
c. LegalZoom makes false comparisons directly by purchasing Google Adwords
keywords that include Plaintiff LegalForce’s “Trademarkia” term, the website
through which the Plaintiffs perform only attorney-led U.S. trademark preparation
and prosecution services by falsely comparing it with the non-attorney “peace of
mind” trademark services of LegalZoom.
13. LegalZoom’s trademark landing page is particularly deceptive. LegalZoom’s advertised
“trademark specialists” are not licensed attorneys at all. It purports to provide “legal help” and
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boasts that it has “attorneys in all 50 states” on its website, which is one of the first sponsored
results in a Google search for “trademark attorney.” LegalZoom promotes to consumers seeking
to trademark their brand that “we know the ropes,” “we look out for you,” and “we know where
to go.” LegalZoom encourages these prospective clients to sign up for its trademark filing
service by telling them to “ask away” because its “specialists” “have answers.” This “peace of
mind” service comes at a low cost of $199 plus government filing fees.
14. The Merriam-Webster dictionary defines “peace of mind”1 as “a feeling of being safe or
protected.” Google dictionary defines “specialist”2 as “a person who concentrates primarily on a
particular subject or activity; a person highly skilled in a specific and restricted field.” But that
is not what LegalZoom really offers. Trademark specialists at LegalZoom are not licensed to
perform the highly skilled tasks that LegalZoom advertises that they can perform. LegalZoom’s
“peace of mind” service does not involve an attorney at any step of the process. No consumer
would be “safe or protected” when engaging in a service that is conducted by persons not
“highly skilled in a restricted field,” and that engages in illegal acts such as unauthorized
practice of law. Using phrases “peace of mind” and “specialist” to describe LegalZoom’s
services is false and misleading to consumers.
15. Thus, consumers are deceived either way: if they rely on LegalZoom’s advertising alone
to make their purchasing decision, they believe they are “safe and protected” by receiving
qualified advice from “trademark specialists” and “legal help” that furthers their legal
protections, when in fact, they are left vulnerable. If they happen to read the fine print, their
purchasing decision would be based on a belief that LegalZoom’s services are not legal advice
and that such advice or licensing isn’t necessary to provide trademark application services.
16. The aforementioned false and misleading advertising statements have the tendency to
deceive a reasonable consumer because a reasonable consumer (1) is not familiar with the
trademark filing process and does not understand what constitutes the practice of law in the
process; and (2) does not understand that unauthorized practice of law is a serious crime under
laws of both the states of California and Texas where LegalZoom has physical offices (See
1
https://www.merriam-webster.com/dictionary/peace%20of%20mind
2
Go to www.google.com and search “specialist definition”
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misdemeanor punishable by up to one year in a county jail under Cal. Bus. & Prof. Code §
6126; under Texas law, falsely holding oneself out as a lawyer with the intent to obtain an
economic benefit is a felony of the third degree. Tex. Pen. Code § 38.122); and (3) is being led
to mistakenly believe that the service provided by LegalZoom is equivalent to the service
provided by a law firm, but with a price much lower than the law firm’s.
LegalZoom’s Unlawful Acts And Practices
17. Nevertheless, LegalZoom does provide legal advice through its non-attorney specialists.
LegalZoom concedes that its “peace of mind” trademark services are performed by non-attorney
“trademark specialists” instead of licensed attorneys. LegalZoom and its “specialists” in fact,
perform trademark searches; create and review the trademark application; make legal
determinations about classification and other matters; advise clients on problems with their
applications, including by recommending changes to classifications and goods and services
descriptions; and filing the trademark application on the client’s behalf.
18. The USPTO defines the practice of law to include3:
a. Consulting with or giving advice to an applicant or registrant in contemplation of
filing a trademark application or application-related document;
b. Preparing or prosecuting an application, response, post-registration maintenance
document, or other related document;
c. Advising applicants on proper responses to USPTO actions;
d. Conducting pre-filing searches for potentially conflicting trademarks;
e. Analyzing or pre-approving documents before filing; and
f. Advising applicants on substantive examination issues, such as the acceptability
of specimens and classification of goods and services.
19. California courts have defined the practice of law to include, among other things:
a. Providing legal advice and counsel.
3
S ee
https://www.uspto.gov/trademark/trademark-updates-and-announcements/warning-unauthorized
-lawpractice; and
https://www.uspto.gov/learning-and-resources/support-centers/trademark-assistance-center.
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b. Preparing legal instruments and contracts that secure legal rights.

20. LegalZoom admits its non-lawyer “trademark specialists” practice law when it explains:
“Our trademark specialists will develop a detailed and unique search monitoring strategy based
on your needs. In addition, our monitoring service alerts you to more than direct conflicts. Each
trademark specialist is trained to create monitoring strategies designed to catch the following:
a. “Deceptively similar trademarks: Words that sound alike or have the same root,
such as Polk Audio and Poke Audio.
b. Misspellings: Differences in one or two letters, such as Divine and Devine.
c. Different classes: We monitor all classes of goods and services. This means even
if your Advantage Jeans trademark is used for clothing, we will notify you if
someone uses Advantage for jewelry.”4
21. Two recent trademark applications submitted via LegalZoom’s “peace of mind” service
demonstrate that LegalZoom non-attorneys provide legal advice. These are just two examples
that demonstrate these are typical LegalZoom practices:
22. Raj Abhyanker’s DRAWMARKIA “peace of mind” trademark application.
a. Raj Abhyanker signed an intent-to-use trademark for the DRAWMARKIA in his
personal capacity through LegalZoom in November 2017. DRAWMARKIA is
associated with a new website contemplated by Abhyanker with his daughter for
creating animations and artwork for startups.
b. LegalForce, Inc. and LegalForce RAPC do not own any title, ownership, or
beneficial interest, equitable or otherwise in the DRAWMARKIA trademark filed
through LegalZoom.
c. The DRAWMARKIA trademark has no direct connection with any of the services
offered by LegalForce, Inc. or LegalForce RAPC.
d. Abhyanker obligated himself in his personal capacity to arbitrate disputes with
respect to the DRAWMARKIA trademark through LegalZoom through a
non-negotiable contract of adhesion.
4
See www.legalzoom.com/trademark-monitoring/trademark-monitoring-pop-up-process.html
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e. Abhyanker did not intend to, and does not believe that he contractually obligated
LegalForce, Inc. and LegalForce RAPC to any arbitration agreement with
LegalZoom with respect to their separate and unrelated causes of action in this
complaint.
f. A LegalZoom “specialist” named “Will,” who is not an attorney, modified a
template description from the USPTO ID Manual based on his consultation with
Abhyanker.
g. Will advised Abhyanker by narrowing the classification to two potential classes
for purposes of the pre-filing search that would be conducted at the next step.
h. For application purposes, Will advised to leave the class blank because of the
consequences of the USPTO review process.
i. Will advised that additional items be incorporated into the description of goods
and services.
23. Team Messaging Solutions’s PIGGIEBANK “peace of mind” trademark application.
a. Team Messaging Solutions, Inc. owns the website Piggiebank
(www.piggiebank.com), which is an independent artificial intelligence enterprise
software company that helps small businesses stay organized.
b. Ryan Bethell is a shareholder and co-founder of Team Messaging Solutions, Inc.
c. Bethell visited LegalZoom’s website, completed an automated questionnaire
related to a trademark filing for “piggiebank,” on behalf of Team Messaging
Solutions, Inc. and accepted the terms of service on behalf of Team Messaging
Solutions, Inc. in December 2017.
d. Bethell is also a non-owner attorney manager of LegalForce RAPC, a plaintiff in
this case. He is not on the Board of Directors of LegalForce RAPC. Bethell is not
a shareholder or employee of LegalForce, Inc., another plaintiff in this case. Nor
is Bethell an officer of LegalForce, Inc., or on the Board of Directors of
LegalForce, Inc.
e. Bethell obligated Team Messaging Solutions, Inc. to arbitrate disputes with
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respect to the PIGGIEBANK trademark through LegalZoom through a

non-negotiable contract of adhesion.
f. Bethell did not intend to, and does not believe that he contractually obligated
LegalForce, Inc. and LegalForce RAPC to any arbitration agreement with
LegalZoom by filing the PIGGIEBANK trademark through LegalZoom.com on
behalf of Team Messaging Solutions, Inc.
g. A LegalZoom “specialist” identified as “Alex,” who is not an attorney, modified
the template description to match the USPTO ID Manual based on his
consultation with Bethell.
h. Alex advised Bethell that the results of state and federal trademark searches
would not likely prevent registration of the mark.
i. A LegalZoom “specialist” identified as Robert, who is also not an attorney,
erroneously advised5 Bethell that only similar marks within the same international
trademark classification of goods and services would pose a risk to obtaining a
federal trademark registration.
24. In both of the above “peace of mind” applications:
a. LegalZoom staff checked a box on the application that waived the Abhyanker and
Team Messaging Solution Inc.’s confidentiality rights and granted permission for
the USPTO to make each application and ownership information publicly
available.
b. LegalZoom conducted pre-filing searches for potentially conflicting marks.
c. LegalZoom took steps to conceal its legal advice from Abhyanker, Team
5
The USPTO denies applications for marks where they are likely to cause confusion with other
marks (both registered and pending) based upon a search of USPTO records. See USPTO,
Trademark Manual of Examining Procedure § 1207.01. The two primary considerations are (1)
their similarities in appearance, sound, connotation, and commercial impression, and (2) the
similarity or dissimilarity of goods and/or services, which involves looking at coordinated
classes beyond the international trademark classification. See id. at 1207.01, 1207.01(b); In re
E.I. Du Pont Demours & Co., 476 F.2d 1357, 177 USPQ 563 (CCPA 1973). “Any one of these
elements may be sufficient to find the marks confusingly similar.” In re Davia, 110 USPQ2d
1810, 1812 (TTAB 2014).
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Messaging Solutions, and the USPTO by noting “problems with your order” on
its website and robo-calling Abhyanker and Bethell, rather than creating an email
“paper trail” of unauthorized legal advice.
d. LegalZoom deceptively used the corporate designee process to complete the
applications, which is designed for use by employees of corporations who do not
have binding authority. That process allowed LegalZoom to enter Abhyanker and
Team Messaging Solutions as the owners, while it received USPTO confirmation
emails directly from the USPTO and repackaged links in these automated USPTO
emails as their own “LegalZoom” branded emails to give Abhyanker and Bethell
the appearance that LegalZoom is managing a process that is in fact automated by
the USPTO.
25. LegalZoom touts itself as an innovator that increases access to legal services, but the
reality is that it deceives clients about what its services really are -- the unlicensed and
unauthorized practice of law by non-attorney “specialists” who LegalZoom persuades the
clients to trust.
26. Clients are often harmed as a result. For example, knowingly making a fraudulent
statement to the USPTO is a federal crime carrying a maximum penalty of 5 years.6 A
preliminary search of public data reveals that LegalZoom has been submitting directly and
aiding and abetting their customers in submitting dozens of fraudulent specimens to the
USPTO. See infra “Claims for Relief.”
27. LegalForce RAPC’s full time communications and training manager, Heather Sapp, a
11-year veteran USPTO trademark examining attorney who reviewed approximately 13,000
trademark applications over the course of more than a decade at the USPTO, explained that she
would receive applications that appeared to be pro se but were really LegalZoom applications:
a. The applications were typically rife with problems, and the applicant was often
6
1 8 U.S.C. § 1001; Nationstar Mortg. LLC v. Mujahid Ahmad, 2014 TTAB LEXIS 350, *9
See
(Trademark Trial & App. Bd. Sep. 30, 2014) (“Fraud in procuring a trademark registration
occurs when an applicant knowingly makes false, material representations of fact in connection
with its application with intent to deceive the USPTO.”).
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“floored” to learn of it;

b. Many applicants would say “LegalZoom didn’t tell us this”;
c. Many applicants relied on faulty advice by “specialists” that actually harmed their
application such that they would have been more likely to successfully prosecute
their application by themselves through the USPTO website;
d. Mistakes resulting from faulty advice given by non-lawyer “trademark
specialists” often diminished the scope of potential protection for successful
applications because they were too specific.
28. LegalZoom has submitted numerous clearly fraudulent specimens7 including ones
listing Adam M. Thomas, non-attorney investor in LegalZoom, former member of the “senior
leadership” at LegalZoom, and former Vice President of Fulfillment Operations - Intellectual
Property Division at LegalZoom. These fraudulent specimens include fabricated proofs of use
submitted to the USPTO on behalf of customers of LegalZoom. Despite submitting fraudulent
specimens, Mr. Thomas was regularly promoted at LegalZoom and endorsed by corporate
officers at LegalZoom on Mr. Thomas’s Linkedin profile, including Chas Rampenthal,General
Counsel of LegalZoom, and Ken Friedman, Vice President of Legal and Government Affairs at
LegalZoom. As a result, upon reason and belief, LegalZoom, knowingly permits their staff to
submit fraudulent specimens by aiding and abetting customers to knowingly commit a federal
crime.
29. In short, consumers unwittingly gravitate to LegalZoom because LegalZoom represents
that they “know the ropes” and can provide “legal help” through legal means. LegalZoom
trumpets their “peace of mind” trademark service through an endorsement by famous criminal
defense attorney Robert Shapiro, of O.J. Simpson murder case infamy, at only a fraction of the
7
For example, see fake specimens on U.S. trademark serial numbers 86237568, 85211418,
85131032, 85638020, and 85014088, all listing Adam M. Thomas, a former Vice President of
LegalZoom. While Adam Thomas’s resume indicates that he went to Whittier Law School and
received a Juris Doctorate degree, it does not appear that he is a licensed attorney in the State of
California or in any state. Mr. Thomas lists among his duties through his 12 years at LegalZoom
between 2002 and 2014 on his resume as including “Directly accountable for Intellectual
Property division operations management and product fulfillment, a department of over 85
employees across two U.S. and international locations.”
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cost of a traditional trademark law firm. In realty, LegalZoom is a federal racket that employs
a fraudulent scheme to deceptively practice U.S. trademark law.
30. In contrast, LegalForce RAPC offers legal help through U.S. trademark attorneys who
know the ropes (i.e., are trained and experienced, often with big law or USPTO experience) and
can provide peace of mind (i.e., represent their clients interests using their experience and
training) for the same low price as LegalZoom. But LegalZoom has a lot of capital--capital it
raised in ways law firms can’t--and it uses that capital to flood the marketplace with false and
misleading representations about its services.
LegalForce’s Lawful and Innovative Practice
31. LegalForce RAPC also offers trademark filing services for $199 plus government filing
fees through LegalForce, Inc.’s Trademarkia.com website. Unlike LegalZoom, LegalForce
RAPC is a law firm. Indeed, it is the largest law firm filer of trademarks before the USPTO and
has been for each of the past five years.
32. Like LegalZoom, LegalForce’s $199 service provides clients with legal advice and
representation in the prosecution of a trademark application. But unlike LegalZoom,
LegalForce’s service is attorney-supervised. A U.S. trademark attorney is involved at all
critical steps of the application process and the same licensed attorney personally signs off prior
to each filing.
33. Raj Abhyanker is CEO and co-founder of LegalForce, Inc. and the founder and sole
shareholder of LegalForce RAPC. Raj Abhyanker is an accomplished Silicon Valley electrical
and software engineer, innovator, and inventor. He is a former founder and Chief Executive of
an internet neighborhood social networking startup that raised more than $5.5M in venture
funding prior to its acquisition by Google, Inc. in 2011. Abhyanker is the inventor of thirty (30)
granted U.S. utility and design patents, including five (5) owned by Google, Inc. in the fields of
software technology, neighborhood social networking, robotics, drones, autonomous vehicles,
and communications engineering.
34. Beyond being an engineer, Abhyanker is also a California licensed attorney who
practices patent and trademark law before the USPTO. He was named as a 2013 Legal Rebel by
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the ABA Journal, a distinction reserved for “change leaders of the legal profession,” and was on
the Fastcase 50, an annual award recognizing 50 of the “smartest, most courageous innovators,
techies, visionaries, and leaders in the law”, because of his success in his mission to increase
small businesses’ access to trademark services without a loss of quality.
35. LegalForce has accomplished that mission by innovating within the bounds of the
regulations governing the legal profession:
a. Docketing system. Trademarkia has aggregated trademark data from nearly a
dozen countries and indexes tens of millions of trademarks daily for updates. It
has become a “docketing system” for the world, enabling, for free, thousands of
entrepreneurs to be kept up to date on deadlines for trademarks, oppositions,
renewals and more. Previously, access to such tools were reserved for wealthy
corporations with access to sophisticated tools from LexisNexis, Thomson
Reuters, and others. Trademarkia has made these tools free to the world.
b. Search Technology. Trademarkia has helped to answer the basic question that
many entrepreneurs have, which is “is my business name available to trademark”,
by making a knockout search from its databases of millions of trademarks,
refreshed daily, freely accessible from its home page, through a search engine-like
search box with little commercial advertising on its home page. As a result,
Trademarkia now attracts over 23.2 million page views and approximately 9.4
million visitors to Trademarkia.com each year, making it one of the Internet’s
largest legal-oriented websites.
c. Competitive and Breaking News. Trademarkia automatically publishes free alerts
for millions of trademarks in various countries making it a leading and primary
news source for breaking business news whenever new products are soon to be
released and whenever new marketing campaigns launch across the world.
d. Catalog of American ingenuity and corporate history. Trademarkia was the first
to publicly index trademark data as old as the year 1872, making it a deep and
rich repository of American history and corporate evolution. As a result,
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Trademarkia is cited as a trusted source for corporate history and branding in at

least 598 Wikipedia pages for leading brands including Coca Cola, Budweiser,
Kellogg, and hundreds of iconic brands.
e. Innovative logo search engine. Trademarkia has built what is the Internet’s largest
logo search engine based on design code identification of trademarks, spanning
over 4 million logos that can be deeply searched by “what is inside” each logo for
creative inspiration and brand development, free of charge. As a result, thousands
of branding agencies and entrepreneurs use Trademarkia.com each month to find
and discover new inspiration for their brands.
f. Keeping trademark bullies accountable. Trademarkia has built what is the
Internet’s first catalog of large company trademark bullies, hecklers, and their
victims based on the number of trademarks they oppose, threaten to oppose, and
are challenged by, through its annual rankings of those companies that actively
overextend their trademark rights. This data is offered for free through automated
annual rankings based on government data and published annually by
Trademarkia.
g. Reducing infringement of trademarks when registering domains. Trademarkia has
built the world’s first domain registration service for small businesses that
automatically checks for availability of trademark rights when registering
domains, to assist in reducing cyber-piracy claims and reducing wasteful federal
litigation, free of charge.
h. Global automated trademark docketing reports. Trademarkia has built automated
and semi-automated trademark reports for most of the 100+ countries through
which Trademarkia offers trademark filings. As a result, companies and
entrepreneurs around the world can uniquely and centrally harmonize trademark
portfolio management and access global trademark protection markets through a
single website.
i. Trademark opposition window tracking. Trademarkia has enabled small
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businesses to easily track their 30-day opposition window for trademarks filed
with the USPTO in real time through its free opposition watch service. Prior to
Trademarkia, such tools were reserved for rich corporations using expensive
enterprise software by companies such as Thomson Reuters, Wolters Kluwer, and
LexisNexis.
j. Client/Matter Management Technology. LegalForce RAPC has developed its own
platform for client and matter management that automates many processes,
detects and corrects errors through artificial intelligence, streamlines the work
flow, and focuses attorney attention on only attorney tasks. The USPTO uses
similar but perhaps even less advanced technology to manage its process.
k. Volume. With over 400 new trademark clients a month, LegalForce attorneys
spend most of their time consulting clients over the phone or via email and giving
legal advice--which not only develops their expertise, but makes them more
efficient. Five of the top ten most successful filers, ranked by the 2017 World
Trademark Review industry publication, are LegalForce attorneys.
l. Bifurcated Supply Chain Management. LegalForce applied best manufacturing
practices to legal services by taking all non-attorney work off of attorneys’ plates
and globalizing it to improve quality while reducing costs.
m. Training. LegalForce attorneys undergo a three-month intensive training process
modeled after the USPTO trademark examining attorney training program to
ensure they are proficient and efficient trademark attorneys. Heather Sapp, a
11-year veteran USPTO trademark examining attorney, who reviewed
approximately 13,000 trademark applications over the course of more than a
decade at the USPTO, is the full-time communications and training manager of
LegalForce RAPC.
36. The results demonstrate its success: LegalForce RAPC has a higher allowance rate than
any other law firm in the country that charges less than $1,000 per trademark filing, and files
more than 100 trademark applications per year.
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An Uneven Playing Field And The Unfair Competition

37. As explained above, LegalForce provides superior technology, is more innovative, and
provides more qualified, higher quality services than LegalZoom at the same price. But it is
losing the battle because it is being fought on an uneven playing field. LegalForce and its
attorneys are bound by the rules of conduct governing the legal profession. LegalZoom has
eschewed those rules by thus far falsely claiming it operates outside of existing regulatory
requirements because it merely offers “self-help” services. Many of those rules protect
consumers. They ensure competence and loyalty and provide remedies when those duties are
violated.
38. LegalZoom purports to operate outside those duties and disclaims them in its terms of
use and other fine-print disclaimers on its site. Consumers are worse off because they don’t get
the protections they expect from the legal profession, including:
a. “Communications between you and LegalZoom are protected by our Privacy Policy but
not by the attorney-client privilege or as work product.”
b. “We are not a law firm or a substitute for an attorney or law firm. We cannot provide
any kind of advice, explanation, opinion, or recommendation about possible legal rights,
remedies, defenses, options, selection of forms or strategies.”
c. “LegalZoom is not a law firm and may not perform services performed by an attorney.”
d. “LegalZoom, its Services, and its forms or templates are not a substitute for the advice
or services of an attorney.”
e. The information that LegalZoom provides is “not guaranteed to be correct, complete or
up-to-date.”
f. These Terms require the use of arbitration on an individual basis to resolve disputes,
rather than jury trials or class actions, and also limit the remedies available to you in the
event of a dispute.
39. By renouncing the attorney-client relationship and purporting to provide “legal help”
rather than legal advice, LegalZoom achieves two business advantages at the expense of
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consumers: (1) sidestepping professional responsibilities governing the legal profession, and (2)
avoiding liability. At the same time, LegalZoom unfairly captures market share from its primary
competitor, LegalForce RAPC.
40. In short, LegalZoom touts its experience and expertise in helping people with legal
problems. But in the fine print, LegalZoom seeks to avoid the responsibilities of law practice by
characterizing its services as self help and maintaining that LegalZoom cannot substitute for an
attorney, regardless of the contrary assumptions of consumers that are reinforced by
LegalZoom’s promotional statements. If taken at face value, LegalZoom’s disclaimer and terms
of use allow it to operate free from the confines of ethical rules enforceable upon attorneys
while denying consumers redress that they would otherwise have for the faulty legal advice it
provides.
41. LegalZoom’s false and misleading promotional statements deceive consumers into
purchasing inferior services, but its success in exploiting advantages by not operating as a law
firm--despite practicing law--have also given it a broader competitive advantage:
a. LegalZoom “specialists” are cheaper labor. They make a starting salary of around
$33,000 per year compared with a $67,000 median starting salary for a licensed
attorney at a law firm with fewer than 25 employees (larger firms have even
higher starting salaries), including at LegalForce RAPC.
b. LegalZoom does not expend time or money on conflict checks, does not forego
clients with conflicts, and as a result can simultaneously assist direct competitors
and adversaries in litigation, with filing trademarks for the same or confusingly
similar trademarks at any time.
c. LegalZoom does not have the limitations, expense, and administrative burden of
trust accounts, reporting, continuing legal education, bar fees, malpractice
insurance, and other regulatory burdens imposed on lawyers and law firms. As a
result, they are able to better regulate their cash flow cycles to meet short term
expenses by not having client funds for trademark filings for which work has not
started, locked away in an IOLTA trust account.
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d. LegalZoom does not have the limitations, expense, and administrative burden of
ethics compliance audits, regular consultation with outside ethics counsel, and
vigilant adherence to rules governing lawyers.
e. LegalZoom is able incentivize non-lawyer staff through commissions, bonuses,
and incentives for performing legal services related to U.S. trademark filing and
prosecution services. Such incentives cannot legally be offered by lawyers and
law firms including LegalForce RAPC.
f. LegalZoom does not have the limitations, expense, and administrative burden of
supervising non-attorney work using licensed lawyers. As a result, its legal staff
are able to have unregulated reign on counseling customers on U.S. trademark
filing and prosecution matters without oversight by a regulated professional.
Law firms including LegalForce RAPC have these burdens.
g. LegalZoom does not face the expense and burden of responding to regular
inquiries, requests for information, and investigations from the Bar and USPTO’s
OED (even where no action has ultimately been taken), or face exclusion and
reciprocal discipline. Law firms including LegalForce RAPC have these burdens.
h. LegalZoom is not disciplined for violating the USPTO prohibition on non-lawyer
ownership of law firms. It thus has such advantages as successfully raising $300
million in venture capital from non-lawyers, the ability to recruit and retain talent
with stock options and RSUs, and the ability of its founding attorneys to sell their
ownership shares to institutional investors. Law firms including LegalForce
RAPC cannot legally raise venture capital from non-lawyers, and can only sell
their ownership shares to other licensed lawyers.
i. Institutional investors are able to purchase equity in LegalZoom giving the
company capital required to grow and invest in capital assets at a rate faster than
LegalForce, making it difficult to compete. Law firms including LegalForce
RAPC cannot legally raise institutional capital.
j. LegalZoom disclaims responsibility for the consequences of the “legal help” it
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gives, while lawyers must maintain malpractice insurance and exercise caution
and diligence to avoid even the appearance of impropriety or incompetence that
could lead to a malpractice action or a bar/OED investigation.
42. The California State Bar and USPTO have investigated, disciplined and excluded
lawyers for conduct less egregious than that engaged in by LegalZoom.
43. Indeed, LegalZoom’s business model, which relies upon mixed and misleading
messages to consumers and the USPTO alike, is a very real threat for law firms. Recently,
Matthew Swyers, a former USPTO trademark examining attorney in private practice and
founder of The Trademark Company, was excluded for practice by the USPTO for conduct
similar to LegalZoom’s. In addition, another attorney Tracy W. Druce was suspended for failure
to supervise assistants even though the lawyer did not know of the conduct of his assistants
signing documents on his behalf. Moreover, the USPTO also excluded from practice Leonard
Tachner, who, like LegalZoom’s Brian S. Lee, was a suspended attorney whose corporation
prepared and filed trademark applications while he was suspended on the grounds of
unauthorized practice of law.
44. LegalForce RAPC is the most prolific trademark filing law firm in the United States, so
it is regularly scrutinized. To date, LegalForce has not been found to have engaged in any
unethical conduct. LegalForce has continually improved its practices from feedback from the
USPTO OED and the California State Bar based on informal inquiries, formal requests for
information, and investigations concerning the firm or its attorneys.
45. The USPTO and the California State Bar have taken no similar regulatory measures or
oversight against LegalZoom and its co-founders, upon reason and belief. As a result,
LegalZoom has not benefited from improving and enhancing its practices through constructive
regulatory scrutiny.
46. LegalForce has lost revenue due to LegalZoom’s conduct in at least two ways: First,
LegalZoom’s false advertising and unfair competition have caused consumers to purchase
LegalZoom’s services instead of LegalForce’s services. Second, LegalZoom’s unlawful
business practices have enabled it to have a significantly lower cost of services rendered. As a
23
result, LegalForce lost significant competitive bidding opportunities on approximately $1.4

million dollars of advertising spent in the year 2017 alone to LegalZoom. Plaintiffs have
reduced their attorney led service prices to $199 and lower to meet the unfair competition of
LegalZoom.
47. But for the misleading advertisements and unfair competition with respect to the
comparability of LegalZoom’s services with those of the Plaintiffs, a good percentage of
consumers likely would not have purchased LegalZoom’s “peace of mind” trademark filing
services and opted for those of LegalForce instead. In total, LegalForce’s lost sales
opportunities exceed $20,000,000 based on the lifetime value per customer in the past five years
alone.
48. LegalForce has also lost asset value. Given that Plaintiffs are the largest filer of U.S.
trademarks in the United States for at least the last 5 years, it has seen its market share decline
from nearly 3% of all U.S. trademarks filed in the United States in 2011 to approximately 1.8%
in 2017, as a direct consequence of LegalZoom’s unfair competition. LegalForce has lost
market share of approximately 1.1% of the overall trademark market since 2011 (approximately
5000 trademarks filings per year) in the relevant market for U.S. trademark filing and
prosecution as direct result of LegalZoom false and misleading business practices and
representations. Tellingly, LegalForce RAPC ceased making the INC5000 list of the fastest
growing companies in America in 2015 after 4 consecutive years of making the list. (see:
https://www.inc.com/profile/legalforce-rapc). Plaintiffs value of their business has been directly
reduced and negotiations with potential acquirers have stalled.
49. Moreover, LegalForce’s advertising costs have increased. LegalForce’s cost per click
and total advertising attract trademark clients has gone up by approximately 30% as a direct
consequence of LegalZoom’s conduct. In addition, Plaintiffs have reduced their attorney led
service prices from $499 to $159 and then $199 to match that of LegalZoom.
FIRST CLAIM FOR RELIEF
DECLARATORY JUDGMENT
(Against LegalZoom, the USPTO and DOES 1-50)
50. Plaintiffs repeat each and every allegations contained in the paragraphs above and
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incorporate by reference each preceding paragraph as though fully set forth herein.
51. An actual controversy has arisen and now exists between Plaintiffs and Defendant
LegalZoom regarding LegalZoom’s false advertising and unfair business practices, which
necessarily requires a foundational determination as to whether LegalZoom is engaged in the
unauthorized practice of law.
52. An actual controversy has arisen and now exists between Plaintiffs and Defendant
USPTO regarding USPTO’s deprivation of Plaintiffs’ constitutional rights by its disparate
enforcement of USPTO regulations on the practice of law.
53. Plaintiffs seek a declaration as to whether LegalZoom is engaged in the unauthorized
practice of law as defined by USPTO regulations by providing a service through which
non-attorney employees of LegalZoom assist clients with filing trademark registration
applications before the USPTO, during which they perform some or all of the following actions
without attorney supervision:
a. Conduct pre-filing searches;
b. Advise applicants on substantive examination issues, such as acceptability of
specimens and the classification of goods and services;
c. Identify problems with applications and advise applicants on how to address those
problems to avoid rejection or office action;
d. Analyze or pre-approve documents before filing;
e. Control and monitor the application process by registering as the applicant’s
corporate representative; and
f. Otherwise consult with or give advice to a client in contemplation of filing a
trademark application or other document with the USPTO.
SECOND CLAIM FOR RELIEF
FALSE ADVERTISING AND UNFAIR COMPETITION
THE LANHAM ACT, 15 U.S.C. § 1125(a)
(Against LegalZoom and DOES 1-50)
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55. Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), provides:

(1) Any person who, on or in connection with any goods or services, . . . uses in
commerce any word, term, name, symbol, or device, or any combination thereof, or any
false designation of origin, false or misleading description of fact, or false or misleading
representation of fact, which--...
(B) in commercial advertising or promotion, misrepresents the nature,
characteristics, qualities, or geographic origin of his or her or another person’s
goods, services, or commercial activities,
shall be liable in a civil action by any person who believes that he or she is likely
to be damaged by such act.
56. LegalZoom made false and misleading descriptions and representations of fact in
commerce:
a. Although LegalZoom represents on its website that it does not practice law, this
representation is false and/or misleading.
landing pages related to its “attorney led” service to its “peace of mind”
non-attorney service.
provide.
d. Despite the fact that LegalZoom is not a law firm and not hiring any attorneys
consumers search terms related to the practice of trademark law, including
“trademark attorney” and “trademark lawyer” with copy that misleads consumers
consumers.
26
Trademark,” which misleads in the same way as subparagraph (c) above.
j. Statement on LegalZoom’s website “[y]our team of attorneys will be there to
or at least operates like one, and can provide legal advice.
57. The statements are commercial advertisements or promotions because:
a. They were designed to promote the services of LegalZoom;
b. They propose commercial transactions, including but not limited to the purchase
27
of LegalZoom’s $199 “peace of mind” trademark filing service;

c. They promote LegalZoom’s commercial activities;
d. They were motivated by LegalZoom’s economic interests;
e. The statements were sufficiently disseminated to the relevant purchasing public,
namely consumers seeking trademark protection assistance; and
f. Most, but not all, of the statements were made in a traditional advertising format
(in an internet advertisement or on a promotional pre-purchase webpage at
LegalZoom.com).
58. Some of LegalZoom’s statements are literally false. For example, LegalZoom disclaims
in its fine print that it does not provide legal advice or “provide any kind of advice, explanation,
opinion, or recommendation about possible legal rights, remedies, defenses, options, selection
of forms or strategies” when, in fact, it regularly does.
59. LegalZoom’s statements that are not literally false are misleading, as described
throughout this complaint.
60. The statements were made in connection with services offered by LegalZoom and, in the
case of its advertisements targeting LegalForce, in connection with services offered by
LegalForce.
61. The statements relate to descriptions or representations of fact that misrepresent the
nature, characteristics, and quality of LegalZoom’s services, as well as the nature,
characteristics, and quality of LegalForce’s services.
62. A substantial segment of consumers are likely to be and actually have been deceived by
LegalZoom’s statements as explained throughout this complaint.
63. LegalZoom’s false and misleading advertisements have caused and, unless enjoined,
will continue to cause immediate and irreparable harm to LegalForce for which there is no
adequate remedy at law. In addition, as a result of LegalZoom’s false and misleading
advertisements, LegalForce has been injured, including but not limited to, decline in sales and
market share, loss of goodwill, and additional losses and damages. Furthermore, LegalZoom has
been unjustly enriched at the expense of Plaintiffs as a consequence of LegalZoom’s false and
28
misleading advertising. Accordingly, Plaintiffs are entitled to injunctive relief and to recover up
to three times the damages sustained by Plaintiffs, enhanced profits and costs, as well as
LegalZoom’s profits, and reasonable attorneys’ fees under 15 U.S.C. §§ 1114, 1116, and 1117.
THIRD CLAIM FOR RELIEF

CALIFORNIA FALSE & MISLEADING ADVERTISING
CAL. BUS. & PROF. CODE § 17500 ET SEQ.
65. Plaintiffs have standing because they have suffered injury in fact and lost money,
including diverted sales to Defendants, lost revenue, loss of market share, reduced asset value,
and increased advertising costs.
66. LegalZoom publicly disseminated internet advertisements with the intent to perform
services to consumers in the State of California, as further described in Paragraphs of this
complaint.
67. LegalZoom’s advertisements were false, misleading, and untrue:
a. Although LegalZoom represents on its website that it does not practice law, this
representation is false and/or misleading.
landing pages related to its “attorney led” service to its “peace of mind”
non-attorney service.
provide.
d. Despite the fact that LegalZoom is not a law firm and not hiring any attorneys
consumers search terms related to the practice of trademark law, including
“trademark attorney” and “trademark lawyer” with copy that misleads consumers
29
consumers.
Trademark,” which misleads in the same way as subparagraph (c) above.
j. Statement on LegalZoom’s website “[y]our team of attorneys will be there to
or at least operates like one, and can provide legal advice.
30
68. LegalZoom’s advertisements are likely to and actually have deceived consumers.
Consumers have purchased LegalZoom’s services instead of LegalForce’s services as a result of
their deception.
69. LegalForce therefore sustained damages in the form of lost business as a direct and
proximate result of LegalZoom’s advertisements.
70. LegalZoom has been unjustly enriched through its false and misleading advertising.
71. Unless restrained by this court, LegalZoom will continue with its untrue and misleading
advertising and will cause additional injury to LegalForce for which LegalForce has no
adequate remedy at law.
72. LegalForce seeks an order of this Court under California Business & Professions Code §
17500 that preliminarily and permanently enjoins LegalZoom from continuing to engage in the
false and misleading advertising described in this complaint, as well as compensatory damages
and restitution.
FOURTH CLAIM FOR RELIEF
CALIFORNIA UNFAIR COMPETITION IN VIOLATION OF
CAL. BUS. & PROF. CODE § 17200 ET SEQ.
73. Plaintiffs repeat each and every allegation contained in the paragraphs above and
74. Plaintiffs have standing because they have suffered injury in fact and lost money,
including diverted sales to Defendants, lost revenue, loss of market share, reduced asset value,
and increased advertising costs.
75. LegalZoom’s conduct violates all three prongs of the California Unfair Competition law
in § 17200 et. seq., in that the practices alleged are unlawful, unfair and fraudulent.
76. LegalZoom has violated the unlawful prong of UCL because they have been engaging in
the unlawful practice of law as alleged in this complaint insofar as LegalZoom goes well
beyond “assisting a customer with routine form-filling exercises”, including the following:
a. Failing to make reasonable efforts to ensuring that LegalZoom has in effect
measures giving reasonable assurance that non-practitioner assistant’s conduct is
31
compatible with the professional obligations of licensed attorneys as defined in 37

C.F.R. §11.503(a).
b. Engaging in conduct involving dishonesty, fraud, deceit and misrepresentation as
defined 37 C.F.R. §11.804(c) because Adam M. Thomas, non-attorney investor in
LegalZoom, former member of the “senior leadership” at LegalZoom, and former
Vice President of Fulfillment Operations - Intellectual Property Division at
LegalZoom has himself submitted and, upon reason and belief, knowingly
permitted staff at LegalZoom to submit fraudulent specimens by aiding and
abetting customers to knowingly commit crimes against the United States of
America in violation of 18 U.S.C. § 1001.
c. Failing to reasonably consult with trademark customers about the means by which
a customer’s objectives are to be accomplished as defined in 37 C.F.R. §104(a)(2)
at least because LegalZoom uses non-attorneys to sign off on privacy rights
without their consent.
d. Failing to exercise reasonable efforts to ensure that LegalZoom has in effect
measures giving reasonable assurance that non-practitioner assistant’s conduct is
compatible with the professional obligations of licensed trademark attorneys as
defined in 37 C.F.R. §11.503(b) at least because LegalZoom fails to maintain an
IOLTA account for customers of LegalZoom, fails to conduct conflict checks, and
fails to take reasonable measures to avoid aiding and abetting customers with
submitting fraudulent specimens to the USPTO in violation of 18 U.S.C. § 1001.
e. Failing to self-regulate conduct of a non-practitioner assistant that would be a
violation of the USPTO Rules of Professional Conduct if engaged in a licensed
attorney because LegalZoom orders, or with the knowledge of the specific
conduct, ratifies the conduct involved as defined in 37 C.F.R. §11.503(c) at least
because a licensed would be disbarred or imprisoned for knowingly engaging in
the crime of unauthorized practice of law.
77. In addition,
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a. Engaging in conduct that is prejudicial to the administration of justice as defined

in 37 C.F.R. §11.804(d) because LegalZoom believes they are not answerable to
USPTO or the State Bar to follow their rules because LegalZoom is not organized
as a law firm in the United States.
b. Engaging in conduct that is prejudicial to the administration of justice as defined
in 37 C.F.R. §11.804(d) by falsely asserting that LegalZoom merely provides “do
it yourself trademark registration services” rather than practicing law.
c. Engaging in conduct that is prejudicial to the administration of justice as defined
in 37 C.F.R. §11.804(d) by falsely asserting that LegalZoom’s “Peace of Mind”
review merely includes a document review specialist check applications for
“complete information,” “spelling and punctuation,” and “proper pagination”
rather than practicing law.
d. Utilizing non-lawyer legal assistants to modify goods and services descriptions of
trademarks, and thereby going well beyond mere “form filling” because such
activities require unique application of legal rules to specific unique sets of facts.
e. Utilizing non-lawyer legal assistants to recommend and select classifications of
trademarks, and thereby going well beyond mere “form filling” because such
activities require unique application of legal rules to specific unique sets of facts.
f. Performing trademark searches and delivering results from the searches of
potentially conflicting trademarks directly to customers without attorney review
and without advance approval from an attorney, and thereby going well beyond
mere “form filling” because such activities require unique application of legal
rules to specific unique sets of facts.
g. Waiving privacy and confidentiality of each customer when paying government
fees associated with filing trademark using non-attorney staff, which are not
supervised by an attorney, which goes well beyond “self-help” because a
reasonable purchaser would not believe that LegalZoom is helping them in any
way by waiving privacy and confidentiality” subscription.
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h. Listing lawyers and non-lawyers employed full time at LegalZoom as an attorney

or “correspondents” on some U.S. trademark filings when in-house attorneys of a
corporation are not authorized to practice law on behalf of customers for the
corporation they work for as opposed to the corporation itself under the state bar
and USPTO conflict of interest rules.
i. Assisting clients in their “legal plans” that offer $599 attorney led trademark
filing services by sometimes listing non-attorney staff at LegalZoom including
one LegalZoom employee with a Bachelors of Arts degree in Criminology from
California State University and no law degree as an “attorney” on at least one
filing with the USPTO.
j. Listing founder and suspended attorney Brian Lee as a legal correspondent on
numerous U.S. trademark filings while he was suspended from practice in the
State of California.
k. Knowingly aiding and abetting customers to knowingly commit crimes against
the United States of America by submitting fraudulent proofs of use in violation
of 18 U.S.C. § 1001.
78. At a bare minimum, LegalZoom’s conduct of assisting customers to submit fraudulent
proofs of use in commerce to the USPTO and unscrupulously engaging in the unauthorized
practice of law does not conform to the ethical conducts of the profession of trademark
prosecution that a reasonable consumer would understand as exercising ordinary care.
79. LegalZoom has violated the unfair prong of UCL because of, and not limited to, the
following:
a. Using the phrase “peace of mind” review when LegalZoom rightly knows that
there is a substantial risk their customers face with waiving attorney client
privilege when submitting a “peace of mind” trademark through LegalZoom.
b. Comparing their services as being virtually equivalent to U.S. licensed attorneys
based on an overall commercial impression in the minds of reasonable customers
of LegalZoom’s trademark services through LegalZoom’s deceptive advertising
34
utilizing phrases such as “peace of mind”, “let us help you”, “avoid costly
conflicts” and other terms as described herein.
c. Submitting numerous fraudulent specimens each year on behalf of customers.
These fraudulent specimens include fabricated proofs of use submitted to the
USPTO on behalf of customers of LegalZoom.
d. Substantially causing injury to consumers through waiving privacy rights when
paying government fees for trademark applications filed before the USPTO
without an appointed attorney and without adequate disclosure.
e. Substantially causing injury to consumers because when customers use
LegalZoom’s “peace of mind” trademark filing services they have surrendered
attorney-client privilege and work product confidentiality.
f. Providing no countervailing benefits to consumers by engaging in unauthorized
practice of law.
g. Knowingly aiding and abetting customers to knowingly commit crimes against
the United States of America by submitting fraudulent proofs of use in violation
of 18 U.S.C. § 1001.
h. Misdirecting traffic in paid search advertising on Google and Bing from its
advertising copy for attorney-led trademark services to its non-attorney “peace of
mind” trademark filing services through which a separate “subscription” to a legal
plan is required.
i. Making it impossible for consumers to reasonably avoid being misled based on
the deceptive advertising of LegalZoom which, upon total commercial impression
on the mind of a reasonable consumer, leads them to believe that LegalZoom’s
services are comparable to those offered by comparably priced attorney led
services at LegalForce.
80. LegalZoom’s false comparisons with Plaintiffs’ attorney-managed U.S. trademark
service as being comparable to LegalZoom’s non-attorney “peace of mind” service through
misleading advertising, as alleged above, constitute unfair competition in violation of Section §
35
17200 et seq. of the California Business and Professions Code. For example, LegalZoom makes
false comparisons directly by purchasing Google Adwords keywords that include Plaintiff
LegalForce’s “Trademarkia” term, the website through which the Plaintiffs perform only
attorney-led U.S. trademark preparation and prosecution services by falsely comparing it with
non-attorney unauthorized practice of law services of Defendants.
81. LegalZoom intentionally uses the search terms “LegalForce” and “Trademarkia” to
trigger sponsored links and to redirect customers to LegalZoom’s false and misleading
advertisements, which deceptively advertise among other things, “Avoid Costly Conflicts”,
“File Your Application With the Help Of An Independent Trademark Attorneys”, and “Speak to
an Attorney.”
82. LegalZoom has violated the fraudulent prong of UCL because of, and not limited to, the
following:
a. Who - LegalZoom.
b. What - Practicing the crime of the unauthorized practice of law and knowingly
aiding and abetting customers in knowingly committing crimes against the United
States of America by submitting fraudulent proofs of in violation of 18 U.S.C. §
1001.
c. When - between approximately January 1, 2001 and continuing through today
Monday March 19, 2018.
d. Where - across the United States and the world through their Internet website
LegalZoom for more than 250,000 customers to date from a headquarter location
in Glendale, California, believed to be at 101 N. Brand Blvd., Glendale CA
91203.
e. How - By making false and misleading statements as alleged in this Amended
Complaint including (1) misrepresenting material facts because they represent
that LegalZoom provides “self-help trademark filing service” but instead the
services are provided by illegal means. (2) submitting fraudulent proofs of use
specimen to the USPTO. (3) waiving privacy rights of consumers without
36
informed consent.
f. These fraudulent business acts and practices are likely to deceive reasonable
consumers.
83. Plaintiffs are informed and believe that LegalZoom, as a competitor to Plaintiffs,
performed the acts alleged herein for the purpose of injuring Plaintiffs. The acts alleged herein
continue to this day and present a threat to Plaintiffs, the general public, the trade and
consumers.
84. As a result of LegalZoom’s wrongful acts, Plaintiffs have suffered and will continue to
suffer loss of millions of dollars of income, profits and valuable business opportunities and if
not preliminarily or permanently enjoined, LegalZoom will have unfairly derived and will
continue to derive income, profits and business opportunities as a result of its wrongful acts
including harm to the market for trademark applications by California applicants.
85. Plaintiffs seek an order of this Court under California Business & Professions Code §
17200 that preliminarily and permanently enjoins LegalZoom from continuing to engage in the
unlawful, unfair and fraudulent acts or practices set forth herein, as well as restitution.
FIFTH CLAIM FOR RELIEF
VIOLATION OF SUBSTANTIVE DUE PROCESS
U.S. Constitution amend. V
(Against the USPTO)
86. Plaintiffs repeat each and every allegation contained in the paragraphs above and
87. The Due Process Clause of the Fifth Amendment of the U.S. Constitution provides that
“No person shall . . . be deprived of life, liberty, or property without due process of law . . . .”
Among the fundamental rights protected by the amendment are the right to pursue and compete
in a trade or profession subject only to rationally related government regulation that is not
arbitrary or capricious.
88. USPTO’s conduct violates Plaintiff LegalForce RAPC’s right to due process of law
under the Fifth Amendment to the U.S. Constitution on its face and as-applied, to the extent
USPTO deprives Plaintiff LegalForce RAPC of this fundamental liberty interest by disparately
37
enforcing the following USPTO’s regulations governing how to practice before the USPTO
with respect to filing trademarks:
a. 37 C.F.R. § 11.101 – Duty to competence. A practitioner shall provide
competent representation to a client. Competent representation requires the legal,
scientific, and technical knowledge, skill, thoroughness and preparation
reasonably necessary for the representation.
b. 37 C.F.R. § 11.503 – Duty to supervise non-lawyers. With respect to a
non-practitioner assistant employed or retained by or associated with a
practitioner: (b) A practitioner having direct supervisory authority over the
non-practitioner assistant shall make reasonable efforts to ensure that the person's
conduct is compatible with the professional obligations of the practitioner; and (c)
A practitioner shall be responsible for conduct of such a person that would be a
violation of the USPTO Rules of Professional Conduct if engaged in by a
practitioner if: (1) The practitioner orders or, with the knowledge of the specific
conduct, ratifies the conduct involved.
c. 37 C.F.R. § 11.504 – A Law Firm Cannot Raise Venture Capital from
Non-Attorneys. With respect to a non-practitioner (d) A practitioner shall not
practice with or in the form of a professional corporation or association authorized
to practice law for a profit, if: (1) A non-practitioner owns any interest therein,
except that a fiduciary representative of the estate of a practitioner may hold the
stock or interest of the practitioner for a reasonable time during administration.
d. 37 C.F.R. § 11.505 – Unauthorized Practice of Law. A practitioner shall not
practice law in a jurisdiction in violation of the regulation of the legal profession
in that jurisdiction, or assist another in doing so.
e. 37 C.F.R. § 11.107 – Conflict of interest. (a) Except as provided in paragraph
(b) of this section, a practitioner shall not represent a client if the representation
involves a concurrent conflict of interest. A concurrent conflict of interest exists
if: (1) The representation of one client will be directly adverse to another client; or
38
(2) There is a significant risk that the representation of one or more clients will be
materially limited by the practitioner's responsibilities to another client, a former
client or a third person or by a personal interest of the practitioner.
f. 37 C.F.R. § 11.106 – Confidentiality of information. (a) A practitioner shall
not reveal information relating to the representation of a client unless the client
gives informed consent, the disclosure is impliedly authorized in order to carry
out the representation, the disclosure is permitted ...(5) To establish a claim or
defense on behalf of the practitioner in a controversy between the practitioner and
the client, to establish a defense to a criminal charge or civil claim against the
practitioner based upon conduct in which the client was involved, or to respond to
allegations in any proceeding concerning the practitioner's representation of the
client
g. 37 C.F.R. § 11.115 - IOLTA trust account. A practitioner shall hold property of
clients or third persons that is in a practitioner's possession in connection with a
representation separate from the practitioner's own property. Funds shall be kept
in a separate account maintained in the state where the practitioner's office is
situated, or elsewhere with the consent of the client or third person.
h. 37 C.F.R. § 11.18 – Signature and certification for correspondence filed in
the Office. (a) For all documents filed in the Office in patent, trademark, and
other non-patent matters, and all documents filed with a hearing officer in a
disciplinary proceeding, except for correspondence that is required to be signed
by the applicant or party, each piece of correspondence filed by a practitioner in
the Office must bear a signature, personally signed or inserted by such
practitioner, in compliance with § 1.4(d) or § 2.193(a) of this chapter.
89. These USPTO regulations apply to everyone who practices before the USPTO, but have
not been applied to non-attorney representatives such as LegalZoom, even though they
represent others in trademark registration actions before the USPTO and provide legal advice.
90. As a result of the USPTO’s disparate enforcement, Plaintiff LegalForce RAPC have
39
been deprived of their fundamental right to engage in their chosen occupation; and they are
unable to compete with LegalZoom as a result of these regulations.
91. Plaintiff LegalForce RAPC’s constitutional right to pursue an occupation in practicing
trademark law has been deprived by USPTO because of repeated and harrassing acts by the
USPTO including asking for “names and home contact information for all non-practitioner legal
assistants employed by LegalForce.”
92. Moreover, since 2017, the USPTO OED has continually asked LegalForce RAPC to
comply with its onerous and excessive requests with regards to rules 37 C.F.R. § 11.101 – Duty
to competence, 37 C.F.R. §11.503 – Duty to supervise non-lawyers, 37 C.F.R. § 11.505 –
Unauthorized Practice of Law, 37 C.F.R. §11.106 – Confidentiality of information, and 37
C.F.R. § 11.107 – Conflict of interest in particular for threadbare or unsupportable reasons. As a
result of this added scrutiny imposed on it, LegalForce RAPC has spent over $100,000 on
external ethics counsel as well as diverted over 80 of hours of internal management working
time solely to preparing responses in the year 2017 alone. These include prolonged and not yet
closed investigations including:
a. Despite the fact that a legal assistant at LegalForce RAPC expressly told a client
that she was not an attorney in writing, the USPTO send OED letters and opened
an investigation;
b. When a USPTO patent examining attorney who was romantically dating an
associate at LegalForce RAPC while working for the USPTO sought to hire
LegalForce RAPC in his personal capacity for a patent application and
LegalForce RAPC rightly turned him down because of a potential violation of 35
U.S.C. § 4, but revealed his name in self defense to a retaliation and gender
discrimination claim by the fired associate at LegalForce RAPC, the USPTO sent
OED letters and opened an investigation;
c. When a competing trademark lawyer to LegalForce RAPC spuriously claimed
that LegalForce RAPC was being adverse to a non-client corporate entity in
which an individual personal client of LegalForce RAPC owned stock was akin to
40
being adverse to the individual client in his personal capacity, the USPTO sent
OED letters and opened an investigation;
d. One recent OED letter received recently as “names and home contact
information for all non-practitioner legal assistants employed by
LegalForce.” When LegalForce RAPC responded to the USPTO saying they “are
concerned that the USPTO requesting private home information from our
assistants will cause irreparable harm to clients of LegalForce and it would
impose undue fear on legal assistants who have done nothing wrong. We are
concerned that this undue fear may cause them to resign, and thereby rendering
the Firm unable to provide quality legal support to its attorneys and its clients,”
and saying “correspondence between attorneys and staff at the firm are subject to
attorney/client privileged and/or subject to work product privilege,” the USPTO
did not withdraw its request or agree to meet and confer as requested by the
Plaintiff LegalForce RAPC, and left open the investigation.
93. Yet USPTO does not apply these same requirements to LegalZoom. Indeed, it allows
LegalZoom to give legal advice and file trademark applications on behalf of others many times
per hour of each day. USPTO’s regulations are arbitrary, capricious, and not rationally related
to legitimate government interests because they (1) increase the cost of legal services from bona
fide licensed attorneys, (2) substantially undermine legitimate business models like
LegalForce’s and disadvantage their ability to compete with LegalZoom, and (3) increase the
likelihood that consumers will use lower quality, unqualified providers like LegalZoom with
few consumer protections in place when they do.
94. Unless USPTO is enjoined from committing the above-described violations of the Fifth
Amendment, Plaintiff LegalForce RAPC will continue to suffer great and irreparable harm.
SIXTH CLAIM FOR RELIEF
VIOLATION OF EQUAL PROTECTION
U.S. Constitution amend. V
(Against the USPTO)
41
96. The Equal Protection Clause of the 14th Amendment to the U.S. Constitution provides
that “No state shall make or enforce any law which shall . . . deny to any person within its
jurisdiction the equal protection of the laws.” The Equal Protection Clause, by its terms, applies
to state actors, but the U.S. Supreme Court has held that the same principle applies with full
force through the Due Process Clause of the Fifth Amendment. See, e.g., Bowling v. Sharpe,
347 U.S. 497 (1954).
97. Under the Equal Protection Clause, when government restricts a person’s economic
liberty, its exemptions for other persons and businesses must be rationally related to a legitimate
governmental purpose.
98. USPTO’s action violates Plaintiff LegalForce RAPC’s right to equal protection of law
under the Fifth Amendment to the U.S. Constitution on its face and as-applied, to the extent
USPTO enacted, enforced, and threatened to enforce, regulations governing how to practice
before the USPTO with respect to filing trademarks, while at the same time exempting
LegalZoom from these regulations in so far as:
a. LegalZoom continues to receive emails with signature links from the USPTO
whenever it has prepared a USPTO trademark form on behalf of its customers.
b. LegalZoom continues to have its IP address not blocked by the USPTO for filling
out and submitting trademarks to the USPTO on behalf of its customers, which is
a departure from USPTO practice of blocking the IP addresses of filers engaged
in the unauthorized practice of law.
c. LegalZoom continues to receive “confirmation emails” when each of its
trademark filing customers have signed declaration form to now pay government
fees to the USPTO on behalf of LegalZoom’s customers.
d. LegalZoom continues to be able to have a deposit account or pay government fees
for USPTO trademark applications using its corporate credit without being
blocked by the USPTO, which is a departure from USPTO practice of blocking
deposition accounts and credit cards of filers engaged in the unauthorized practice
42
of law.
e. Until this date, none of the LegalZoom’s attorney employees or LegalZoom itself
have been disciplined by the USPTO for violations of the USPTO rules under 37
C.F.R. § 11 or any other rules described herein based on what is published on the
FOIA reading room website of the USPTO.8
99. Any legitimate rationale to impose USPTO rules upon Plaintiff LegalForce RAPC is
rendered irrational by virtue of the exemptions for other online trademark filers of the same
regulation.
100. Other online trademark filers such as LegalZoom provide the same type of services
as LegalForce RAPC, and have the potential to cause the same consumer harm.
101. The USPTO’s regulations are arbitrary, capricious, and unreasonable, because they
create two classes of USPTO practitioners but apply these restrictions only to one such class
(LegalForce RAPC and other attorneys/law firms), and not the other (LegalZoom and other
non-attorney/non law firms). The result is that the better trained, more qualified provider is
competitively disadvantaged, while the untrained, undertrained and less qualified provider can
provide the same services unhindered.
102. Protecting LegalZoom from consequences of the unauthorized practice of law and
other USPTO regulations mentioned herein at the expense of Plaintiff LegalForce RAPC’s
business and constitutional right to pursue its occupation in practicing trademark law is not a
valid exercise of USPTO’s governmental power to protect consumers and the public health and
safety.
103. Unless USPTO is enjoined from committing the above-described violations of the
Equal Protection Clause, applied to the federal government through the Fifth Amendment,
Plaintiff LegalForce RAPC will continue to suffer great and irreparable harm.
REQUEST FOR RELIEF
WHEREFORE, Plaintiffs request that this Court:
A. Declare that LegalZoom’s conduct violates Section 43(a) of the Lanham Act, 15
8
https://e-foia.uspto.gov/Foia/OEDReadingRoom.jsp
43
U.S.C. § 1125(a) because either:

a. LegalZoom is engaged in the unauthorized practice of law by providing a
service through which non-attorney employees of LegalZoom assist
clients with filing trademark registration applications before the USPTO,
and thus LegalZoom cannot legally provide the service it advertises.
b. LegalZoom is not engaged in the unauthorized practice of law by
providing a service through which non-attorney employees of LegalZoom
assist clients with filing trademark registration applications before the
USPTO, and thus LegalZoom’s promotional and advertising statements
give consumers the false impression that they are receiving legal advice
and representation in connection with trademark registration applications
before the USPTO.
B. Enter judgment against LegalZoom;
C. Award Plaintiffs compensatory damages against LegalZoom in an amount to be
proven at trial;
D. Award Plaintiffs their costs and expenses of this action against LegalZoom,
including their reasonable attorneys’ fees necessarily incurred in bringing and
pressing this case, as provided in 15 U.S.C. § 1117(a). Declare that USPTO’s
conduct violates Plaintiff LegalForce RAPC’s constitutional rights;
E. Award Plaintiffs’ pre- and post-judgment interest at the applicable rates on all
amounts awarded;
F. Grant permanent injunctive relief to prevent the recurrence of the violations for
which redress is sought in this complaint; and
G. Order any other such relief as the Court deems appropriate.
Respectfully submitted this Wednesday March 21, 2018.
LEGALFORCE RAPC WORLDWIDE P.C.
44
By__/s/ Raj V. Abhyanker______

Raj V. Abhyanker
California State Bar No. 233,284
Attorney for Plaintiffs:
LegalForce, Inc.
JURY TRIAL DEMAND
Plaintiffs hereby request a bench trial for the declaratory judgement and injunction causes
of action, and a jury trial for all other causes of action alleged in this Second Amended
Complaint.
Respectfully submitted this Wednesday March 21, 2018.
LEGALFORCE RAPC WORLDWIDE P.C.
By__/s/ Raj V. Abhyanker______

Raj V. Abhyanker
California State Bar No. 233,284
Attorney for Plaintiffs:
LegalForce, Inc.
45

Second Amended Complaint - LegalForce v. LegalZoom &amp; USPTO

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Case 3:17-cv-07194-MMC Document 84-1 Filed 03/21/18 Page 1 of 45

RAJ V. ABHYANKER, California SBN 233,284

LEGALFORCE RAPC WORLDWIDE, P.C.

Attorneys for Plaintiffs,

UNITED STATES DISTRICT COURT

LEGALFORCE RAPC WORLDWIDE, Case No. 3:17-cv-07194-MMC

Plaintiffs, SECOND AMENDED COMPLAINT FOR:

v. 1. DECLARATORY JUDGMENT ACT, 28

JURY TRIAL DEMANDED

Plaintiffs LegalForce RAPC Worldwide, P.C. (“LegalForce RAPC”) and LegalForce,

c. Endorsements from well-known attorneys such as Robert Shapiro, which misleads

j. Statement on LegalZoom’s website: “[y]our team of attorneys will be there to

more about attorney-led trademark registration”, which misdirects consumers to a

b. Preparing legal instruments and contracts that secure legal rights.

respect to the PIGGIEBANK trademark through LegalZoom through a

“floored” to learn of it;

Trademarkia is cited as a trusted source for corporate history and branding in at

An Uneven Playing Field And The Unfair Competition

result, LegalForce lost significant competitive bidding opportunities on approximately $1.4

55. Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), provides:

of LegalZoom’s $199 “peace of mind” trademark filing service;

THIRD CLAIM FOR RELIEF

compatible with the professional obligations of licensed attorneys as defined in 37

a. Engaging in conduct that is prejudicial to the administration of justice as defined

h. Listing lawyers and non-lawyers employed full time at LegalZoom as an attorney

U.S.C. § 1125(a) because either:

Respectfully submitted this Wednesday March 21, 2018.

LEGALFORCE RAPC WORLDWIDE P.C.

By__​/s/ Raj V. Abhyanker​______

Respectfully submitted this Wednesday March 21, 2018.

LEGALFORCE RAPC WORLDWIDE P.C.

By__​/s/ Raj V. Abhyanker​______

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