RAJ V.

ABHYANKER, California SBN 233284

Email: ​raj@legalforcelaw.com
WENSHENG MA, California SBN 299961
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 Claimant,

LegalForce RAPC Worldwide, P.C.

AMERICAN ARBITRATION ASSOCIATION

LEGALFORCE RAPC WORLDWIDE, P.C., Case No.: 01-18-0001-5162-GT

Claimant, STATEMENT OF CLAIM FOR:

v. 1. LANHAM ACT, 15 U.S.C. § 1125(a);

2. CONSPIRACY TO RESTRAIN
LEGALZOOM.COM, INC. TRADE, SHERMAN ACT, 15 U.S.C.
§1;
Respondent. 3. MONOPOLY TO RESTRAIN TRADE,
SHERMAN ACT, 15 U.S.C. §2;
4. CALIFORNIA FALSE &
MISLEADING ADVERTISING;
5. CALIFORNIA UNFAIR
COMPETITION;
6. CONSUMER LEGAL REMEDIES
ACT (Cal. Civ. Code § 1750, ​et seq.​);
7. LEGAL DOCUMENT ASSISTANT
LAW (CAL B&P § 6400, ​et seq.​).;
8. UNJUST ENRICHMENT; and
9. DECLARATORY RELIEF.

1. LegalForce RAPC Worldwide, P.C. (“Claimant” or “RAPC”) complains and alleges

against LegalZoom.com, Inc. (“Respondent” or “LZ”) as follows:

1
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 BACKGROUND
2. There is no question technology changes faster than the law can accommodate. While this
is for good reason, it results in periods of adjustment where someone must take the lead
spearheading changes to help the law evolve and catch up with emerging technology to either
close new loopholes or create new opportunities for efficiency and access to law in the age of
the Internet. The current case is a result of that gap in the evolutionary rate between law and
technology.
3. As technology advances and opens up new opportunities for efficiency and cost-savings,
legal professionals must work within the existing professional framework until necessary
precautions and changes are made to facilitate change that protects consumers that rely on the
legal services. ​In America where few average citizens can afford the hourly rates of
lawyers, it is a noble and worthwhile cause to improve access to justice and access to law
through the web and through the Internet.​ ​That is what RAPC has precisely done.
4. However, opening up access to law and justice should not mean abandoning fundamental
principles of law, ethics, and equal access that are the bedrock of the American legal system.
While RAPC has served this higher purpose within the current regulatory framework, some are
willing to take unscrupulous advantage of innocent small businesses and handicapped persons,
using technology to ignore current ethical rules and exploit the disadvantaged in pursuit of
outsized profits.
5. For example, owning a business can be a challenge for anyone, but there are many more
difficulties with owning a business when you are disabled. In addition to normal business
expenses, disabled business owners experience other financial hardships due to their disabilities,
which can make operating a small business even more challenging. Perhaps most disturbing of
LZ’s conduct is that LZ exploits people with disabilities looking to start a business to support
themselves by lying to them. When a blind person visits LZ’s non-attorney trademark filing
page, LZ will ​surreptitiously play them a hidden message “​A trademark attorney will navigate
the trademark process for you.​ ” This message is not visible in text form on the web page

2
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
without looking at the source code or hovering over a random, unrelated image on the page.
Rather, it just plays whenever assisted screen readers are used by handicapped persons.
6. Out of respect for the law and the ethical obligations of attorneys, RAPC attempts to
utilize the latest technology advancements to provide better services while still abiding within
the current legal framework. Unfortunately, RAPC has seen its financial losses increase recently
as LZ violates the law and deceives the public in the chase of larger market share and more
revenue.
7. As a result, consumers and competition in the trademark space is restrained by LZ’s
anti-competitive conduct. LZ falsely represents to customers that attorneys work on
trademarks when they do not, and surreptitiously utilizes “phone consultations” with
non-attorney staff to dish out often faulty legal advice in the classification of trademarks,
evaluation of specimens of use, and appropriateness of descriptions. As a result, customers are
steered away from lawful competition from law firms and lawyers to LZ. More importantly,
consumers are greatly harmed by LZ’s conduct. In fact, approximately 27.2% of the
approximately 76,392 trademarks that LZ has filed in the last three years were abandoned
for avoidable mistakes - abandonment for failure to respond or late response to an office
action. In contrast, most law firms, including RAPC have virtually 0% in the category for
abandonment for failure to respond or late response to an office action.
8. Adding to this is an an additional 13.2% of LZ’s trademarks that were abandoned for the
failure to submit a proof of use. In total, a dismal 45% of all the filed trademarks by LZ in
the last 3 years ever made it to “registered” status. In contrast, 51% (in the last 3 years the
same time frame) of all trademarks filed by applicants before the United States Patent &
Trademark Office (“USPTO”), including by ​pro se filers directly on the USPTO website
without any help, move from filing stage to registration.1
9. Rather than sacrifice its professional responsibilities on the altar of corporate profits or
sit by waiting for the law to catch up to these technological advances, RAPC is leading the

1
See USPTO’s Performance & Accountability Report, FY2017 - TABLE 15: Summary of
Trademark Examining Activities (FY 2013–FY 2017).
​https://www.uspto.gov/sites/default/files/documents/USPTOFY17PAR.pdf
3
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
charge to close the gap so all can compete equally without potential detriment to the quality of
legal services provided to consumers. RAPC has initiated the present case to stop the
anti-competitive restraint on trade and unfair business practices of LZ with respect to state and
federal trademark and intellectual property matters.
APPEAL TO THE 9TH CIRCUIT
10. RAPC respectfully makes this Statement of Claim under protest, as RAPC continues to
believe that the instant arbitration is improper given the public policy implications of this
statement of claim as well as the rationale under which arbitration was ordered by the District
Court. RAPC believes the instant arbitration should be stayed pending appeal to the 9th
Circuit.
NATURE OF CLAIM
11. Trademarks are often the most valuable asset for a small business. Mistakes in trademark
filings can be costly and result in seizure of goods, loss of goodwill, and business failure. It is
not a simple document that just gets filed and rights conferred. Rather, the process is inherently
adversarial through a formal review process by the USPTO and third parties who can challenge
filings on the basis of priority, fraud, and likelihood of confusion.
12. In addition, mistakes to trademark classifications in initial filings cannot easily be
subsequently corrected without incurring new government filing fees. It takes years of practice
by attorneys to become adept at navigating the dozens of variations of rejections and issues that
might occur if trademark applications are not properly filed. Moreover, there are often multiple
strategies and alternative approaches to trademark filings that can sometimes address a client’s
business goals more effectively. For this reason, considerable legal skill and experience is
required to fill out trademark applications. Therefore, counseling and preparing trademark
applications is practicing law. Echoing California law, the USPTO further defines the practice
of law to include, among other things, the following: (1) Consulting with or giving advice to an
applicant or registrant in contemplation of filing a trademark application or application-related
document (​Exhibit 5​) and (2) Advising applicants on substantive examination issues, such as
the acceptability of specimens and classification of goods and services (​Exhibit 6​).

4
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 13. LZ, although a non-legal entity, has been illegally practicing law when providing its
non-attorney-led trademark filing services.
14. LZ and RAPC compete in the preparation and filing of trademark applications before the
United States Patent & Trademark Office (USPTO). While RAPC innovated within the existing
legal framework that protects consumers from getting bad legal advice, LZ does not.
15. An actual controversy has arisen and now exists between RAPC and LZ because of LZ’s
violation of California statutory laws related to the unauthorized practice of law and prohibition
of acting as a runner and capper for legal services (for its foreign law firm subsidiary,
LegalZoom Legal Services Ltd. (“LZK”) in the United Kingdom). There are two threshold
questions that the Arbitrator must first answer to adjudicate the claims made herein :
16. 1st Question for Arbitrator: ​Does LZ violate Cal Bus. & Prof. Code § 6125 for its
non-attorney trademark filing service.
17. To answer the question of whether LZ unfairly competes with RAPC, the Arbitrator must
first answer a fundamental question: whether LZ’s non-attorney trademark filing services
constitute the unauthorized practice of law in violation of Cal Bus. & Prof. Code § 6125.
(​Exhibit 1​.)
18. If the answer to this question is affirmative, then LZ can no longer unfairly compete and
restrain trade by offering its non-attorney trademark filing service in the manner it does, and
RAPC and other licensed trademark attorneys will be able to effectively compete with LZ in the
preparation and filing services on a level playing field. RAPC’s injury is traceable to LZ’s
conduct of providing legal advice with respect to determination of goods and services
classifications and amendments of descriptions of trademark applications using non-attorney
staff prior to filing before the USPTO. RAPC’s injury will be redressed by the arbitrator's
declaration addressing the question of whether LZ’s non-attorney trademark filing services
violate Cal Bus. & Prof. Code § 6125.
19. 2nd Question for Arbitrator : ​Does LZ violate Cal. Bus. & Prof. Code § 6152(a) by
acting as a runner and capper for its captive subsidiary and foreign law firm LZK for its
attorney led U.S. trademark filing service.

5
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 THE PARTIES
The Claimant
20. RAPC is a law firm wholly owned by Raj Abhyanker (“Abhyanker”), a patent and
trademark attorney in good standing of the State Bar of California (Bar #233,284), and the
United States Patent Bar. RAPC practices state corporate law and state and federal intellectual
property laws 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. RAPC
has helped nearly 100,000 clients for intellectual property services including clients all 50 states
and more than 300 cities and towns across America. It is the largest law firm filer of trademarks
in the United States, filing over 8,000 trademarks before the USPTO each year. It has had
revenues of over $20,202,000 from trademark filing and related services between the years 2015
and 2017 excluding USPTO government fees.
The Respondent
21. LZ is a Delaware corporation having its principal place of business at 101 N. Brand
Blvd., Glendale, CA 91203. LZ offers Trademark filing services through its website
LegalZoom.com. LZ is not a law firm and is not authorized to practice law in any state. LZ has
raised more than $811,000,000 dollars (eight-hundred and eleven million dollars) in venture
capital, including $500,000,000 (five-hundred million dollars) in a latest round on July 31,
2018.
FACTUAL ALLEGATIONS
I. ​LZ’s False And Misleading Statements
22. The Lanham Act, 15 U.S.C. § 1125(a)(1)(B), prohibits any person from using false or
misleading statements to misrepresent the nature or qualities of his services in commercial
advertising or promotion. LZ violated the Lanham Act by making the following false and/or
misleading statements on its website.
A. CUSTOMERS SEEKING TRADEMARK ATTORNEYS ARE MISDIRECTED
TO LZ’s NON-ATTORNEY TRADEMARK SERVICE PAGE THROUGH
MISLEADING SEARCH RESULTS AND BUTTONS

23. LZ has two main service categories for trademark service—non-attorney trademark

6
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 service and attorney-led trademark service. LZ charges $199 or $219 for its non-attorney
​ xhibit 58 ( describing non-attorney trademark service description); and
trademark service. ​See E
Exhibit 61 ​(describing non-attorney intellectual property service description)2. LZ charges $599
​ xhibit 62​ for attorney-led service description page.
for its attorney-led trademark service. ​See E
24. LZ purposely designed an advertising scheme (through the use of Google Adwords, web
pages, buttons, links, etc.) in a way that misdirects customers seeking trademark attorney
services to its non-attorney trademark service page.
25. When a customer searches for “trademark attorney” on Google, LZ’s web page titled “Do
​ xhibit 67
I Need a Trademark Attorney? | LegalZoom” will show up in the search result. ​See E
at 2. Clicking on this link will lead to LZ’s promotional article “Do I Need a Trademark
Attorney?” ​Exhibit 57​. At the end of the article the following statements are shown along with
an orange button containing the misleading statement “Learn more about attorney-led trademark
registration” and a blue button containing the misleading statement “START MY
REGISTRATION” as shown below :
If you're ready to register a trademark, LegalZoom can help. LegalZoom
attorney-led trademark registration services will put you in touch with an attorney
who can assist you with the trademark registration process.

26. However, clicking on the orange button labeled “Learn more about attorney-led
trademark registration” leads ​not t​ o the attorney-led service description page of ​Exhibit 62​, but
the non-attorney service description page of ​Exhibit 58​. Similarly, clicking on the blue button
labeled “START MY REGISTRATION” leads to the non-attorney intellectual property service
description page of ​Exhibit 61​, ​not​ ​Exhibit 62​.
27. To make the non-attorney service description page of ​Exhibit 58 look more like

2
Clicking on the first picture of ​Exhibit 61 titled “Trademark Registration” will lead to ​Exhibit
58​.
7
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
describing an attorney-led service, LZ injects statements with the word “attorney” into multiple
locations of this page. For example, in section “Speak with an attorney”, the statement “Get
legal advice from an independent attorney at a price you can afford” is shown, which suggests
that the trademark filing service which the page is describing will be led by independent
​ xhibit 58​ a​ t 3-4.
attorneys. ​See E
28. However, clicking on the “Find out more” button below the statement leads to another
page describing LZ’s Business Advisory Plan (offered at $31.25 per month for 12 months),
​ Z’s $599 attorney-led trademark registration service. See ​Exhibit 66​. As the page
which is ​not L
itself explains, the plan mainly offers 30-minute consultation on non-trademark matters. See
below.
When you become a legal plan member, you have access to 30-minute
consultations with an independent attorney and a wide array of other benefits.
Many plan members use the plan to get help with estate planning (financial power
of attorney, living trust, or last will), business formations (LLC, Corporation,
501c3), legal document reviews (contracts, employee agreements), tax advice
(through our business partner 1800Accountant), personal legal matters
(bankruptcy, finance, and lawsuits), and family matters (marriage, divorce, and
child support).
Exhibit 66 ​at 3.
29. Other statements in ​Exhibit 58 also suggest that the trademark filing service which the
page is describing is provided by attorneys. These statements clearly state that although LZ is
​ xhibit 58
not a law firm, LZ provides access to independent attorneys to customers. ​See, e.g., E
at 5 (“LegalZoom provides access to independent attorneys and self-help services at your
specific direction.”).
30. Therefore, when viewing ​Exhibit 58 as a whole, taking into account the multiple
references to services by attorneys, the page gradually builds up a false impression that the
service which the page is describing will be led by attorneys. This is especially true when the
customer was led to this page by clicking on the orange button labeled “[l]earn more about
attorney-led trademark registration”, thinking that they will find out more information about the
attorney-led service.
​ xhibit 59 (“8
31. Other LZ’s web pages operate the same way to mislead customers. ​See E

8
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
Questions to Ask a Trademark Attorney”); ​Exhibit 13 ​(printed December 1, 2017) and ​Exhibit
60​ (printed September 18, 2018) (“Do You Need a Trademark Attorney”).
32. These statements provide a false impression that there are attorneys behind the trademark
registration service described therein and customers can talk to those attorneys before making
the purchase. (Of course, most customers do not talk to the attorneys and directly sign up for the
service). In this way, LZ misdirects potential customers seeking for trademark attorney service,
a service provided by RAPC attorneys, to LZ’s low-priced non-attorney service in order to
attract more unwitting customers.
33. Therefore, LZ’s unscrupulous advertising scheme steers away potential customers
seeking attorney service from RAPC and other law firms, thereby giving LZ an unfair
advantage by affording it a lower cost of services rendered (e.g., by hiring lower waged
workers) than that of licensed attorneys and law firms such as RAPC.
34. Many LZ’s customers have been actually misled by these statements and LZ’s deceptive
advertising scheme. A few examples are shown below:
a. Customer A.B. in Ashburn, Virginia requested a filing of trademark application for
through LZ on or about December 2017. A.B. was tricked by LZ’s paid search
advertising into believing that he would be represented by a team of trademark
attorneys. Instead, he was directed to a non-attorney landing page and workflow.
b. Customer D.H. in Willow Park, Texas requested filing of a trademark application
through LZ on or about December 2017. D.H. was tricked by LZ’s paid search
advertising into believing that he would be represented by a team of trademark
attorneys with experience preparing and filing trademark applications. Instead, he was
directed to a non-attorney landing page and workflow.
c. Customer B.S. in Hagerstown, Maryland requested filing of a trademark application
for the brand through LZ on or about July 2017. B.S. was acting in his capacity as
Chief Executive Officer for his company. B.S. was tricked by LZ’s paid search
advertising into believing that he would be represented by a team of trademark
attorneys with experience preparing and filing trademark applications. Instead, he was

9
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 directed to a non-attorney landing page and workflow. B.S. wrote to RAPC that “​I
was lead to believe that legal zoom was paid a premium because they had attorneys
specifically filing my trademark.​ [sic].​”
d. Customer D.H. in Texas requested filing of several trademark applications through
LZ on or about December 2017. D.H. chose LZ because the advertising led him to
believe he would be represented by a team of trademark lawyers. As a result, he was
misled into purchasing the non-attorney trademark filing service. The advice he
received from LZ’s non-attorney staff was faulty because his mark that LZ filed
received an Office Action for specimen issues. D.H. wrote to RAPC that “​The
individuals I spoke with on the phone seemed very confident however the results were
obviously lackluster.”​
e. Customer B.S. in Maryland requested filing of a trademark application through LZ on
or about July 2017. He was misled by LZ’s advertising to believe that LZ had
attorneys to file his trademark. As a result, he purchased the non-attorney trademark
filing service. B.S. wrote to RAPC that “ I was lead to believe that legal zoom was
paid a premium because they had attorneys specifically filing my trademark.​ [sic].​”
f. Customer J.C. in Illinois requested filing of a trademark application through LZ on or
about July 2017. J.C. chose LZ because he was led by its advertisement to believe
that a lawyer would be managing the process. As a result, he purchased the
non-attorney trademark filing service. J.C. wrote to the RAPC that “​We were under
the impression that a lawyer would be managing the process.”​ and “​The application
was unsuccessful and ultimately a waste of money and our trademark is not
protected.​ ” [sic]
35. Before RAPC filed the initial complaint in the federal district court
(3:17-cv-07194-MMC) on December 19, 2017, LZ had been directing Google Adwords search
result for trademark attorneys titled “LegalZoom (Official Website) - Trademarks: $599 + Gov’t
Fees”, with the description of “File Your Application With The Help Of An [sic] Independent
Trademark Attorneys”, to its non-attorney service description page. ​See ​Exhibit 10 at 1 (Google

10
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
search result recorded on December 1, 2017); ​see also Case No. 3:17-cv-07194-MMC, Dkt. 1
¶¶ 70, 71; Dkt. 1 Exhibits R, S. Clicking on the link ​www.legalzoom.com/trademark/attorney
will lead to the non-attorney trademark service description page.
36. In addition, LZ had also been showing the non-attorney service description page when
customer clicks on the orange buttons labeled “Learn more about attorney-led trademark
​ ase No. 3:17-cv-07194-MMC, Dkt. 1 ¶ 72; Dkt. 1
registration” in various web pages. ​See C
Exhibit T.
37. Immediately after the initial complaint was filed, LZ changed its Google search link and
orange button link to the attorney-led service page. On December 21, 2017, RAPC wrote the
following email to Chas Rampenthal, the General Counsel of LZ at 7:15 p.m:
Chas,

We are gravely concerned about evidence spoliation and destruction given our
observations today. Specifically, we are extremely concerned evidence is not
properly being preserved by LegalZoom Entities (all defendants parties you have
indicated you represent collectively referred to as LegalZoom Entities) despite our
litigation hold request when I emailed you the Complaint two days ago on
December 19, 2017.

We would like to Meet & Confer about this at your earliest opportunity. I am
available all day tomorrow. Please let me know a time when you are free to Meet
& Confer.

Today, we were shocked to discover that LegalZoom Entities have fixed the
previously misdirected text copy and embedded links in Exhibit T. Upon reason
and belief, this and other changes made after we filed our Complaint and
provided you a preservation demand.

Moreover, we also noticed changes in AdWords copy text in Exhibits N to Q in

misdirected text copy and hyperlinks for Google and Bing AdWord add related to
keywords “trademark filing attorney”, “trademark lawyer”, and Plaintiffs’
trademark business and personal names including “LegalForce” and/or “Raj
Abhyanker”.

As you likely know, Google AdWords and Bing Ads offer a feature to generate a
Log file of any and all changes to an advertising account. We demand that these
Log files be forensically preserved with all meta data in tact.

Moreover, we demand that any and all server and database logs related to
updating of hyperlinks and Content through on page content in Exhibits A to Z of

11
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 our complaint be preserved forensically with all meta data in tact.

More completely, we hereby demand active steps be taken to prevent spoliation of

evidence their hiring or a third party forensics company for any and all
documents, emails, log files, server files, communications, chats, and other
electronic evidence that may lead to admissible evidence.

It seems the LegalZoom Entities may be illegally editing hyperlinks and

advertising content on pages in response to our Complaint despite our
preservation demand.

Please let us know the following:

1. Whether LegalZoom Entities will agree to hire an independent forensics and

data preservation company to preserve all electronic evidence with any and all
meta data in tact for on page content, AdWords changes, server log files, internal
emails to/from anyone involved in web page modification, AdWords, all officers,
or co-founder defendants of LegalZoom named in our Complaint.

2. What LegalZoom Entities will be doing to ensure there is no further spoliation

of evidence.

If we do not reach a satisfactory resolution to our concerns, we intend to file a

Motion with Judge Cousins compelling forensics preservation given the changes
today.

Kind regards,

Raj Abhyanker

See ​Exhibit 8​.

38. Despite RAPC’s requests to Meet & Confer and seek forensics preservation, LZ did not
agree. Instead, LZ admitted through its silence that they did alter the evidence and wrote
vaguely in an email to RAPC that “LegalZoom has and will comply with applicable laws and
regulations, including those regarding records preservation.” ​See ​Exhibit 9​.
39. Months later, prior to the filing of this statement of claim, LZ partially complied with the
laws of preserving evidence and reverted the orange button link back to the non-attorney service
description page. However, LZ removed the Google Adwords titled “LegalZoom (Official
Website) - Trademarks: $599 + Gov’t Fees” seen in ​Exhibit 10 and fixed the link
www.legalzoom.com/trademark/attorney​ to correctly point to its attorney-led service page.

12
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
B. LZ’S INTENTIONALLY INCLUDES MISLEADING STATEMENT “A
TRADEMARK ATTORNEY WILL NAVIGATE THE TRADEMARK PROCESS FOR
YOU” IN ALTERNATIVE TEXT ON NON-ATTORNEY TRADEMARK SERVICE
PAGE TO DECEIVE HANDICAPPED PERSONS, THE PUBLIC, THE GOOGLE
SEARCH ENGINE, AND STEER CLIENTS FROM LAWFUL COMPETITORS
INCLUDING RAPC.

40. LZ surreptitiously uses the statement “A trademark attorney will navigate the trademark
process for you”​ as “alt text” of a search image below:

41. On the non-attorney trademark service description page of ​Exhibit 58 ​(screen captured as
Exhibit 52 to show the effect of alt-text), nowhere on the page does the statement “A trademark
​ xhibit 58​. Rather,
attorney will navigate the trademark process for you” visually appear. ​See E
the statement is deceptively embedded in the source code between lines 646 to 649. ​See ​Exhibit
53​ at 8.3 The pertinent source code is shown below:
<img src="data:image/gif;base64,R0lGODlhAQABAID/AMDAwAAAACH5BAEAAAAAL
AAAAAABAAEAQAICRAEAOw==" data-blzsrc="​/resources/img/icons/vb_search.png​"
alt="A trademark attorney will navigate the trademark process for you" title="​A trademark
attorney will navigate the trademark process for you​" class="" style=""/>
<h2 style="">We look out for you</h2>
<p>Before we submit your application, we do a basic trademark search and inform you of any
direct conflicts so your brand has a better chance of succeeding.</p>

Exhibit 53​ at 8 (emphasis added).

42. In web programming terms the embedded line of code, ​alt=”A trademark attorney will
navigate the trademark process for you”​, is called “alt text” or “alternative text”. Alt text is always
associated with an image and it is used to describe the image in text format, so that “[a] visually
impaired reader using a screen reader such as Orca will hear the alt text in place of the image.”
See ​Exhibit 68​ at 1.
43. Here, the alt text is associated with the blue search button image having the URL address

3
Source code of a webpage can be viewed by opening the web page in a browser and pressing
Ctrl + U on your computer keyboard (or pressing Command + Option + U if you are using Mac).
13
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 "/resources/img/icons/vb_search.png".4 An image of a search button depicts the meaning of
“search”, which corresponds to the meaning of the statements provided below the image:
We look out for you
Before we submit your application, we do a basic trademark search
and inform you of any direct conflicts so your brand has a better
chance of succeeding.
Exhibit 58​ at 1.
44. Therefore, the search button image and the statements appear to be representing that LZ
will do a basic trademark search before submitting a trademark application. However, this
representation is completely unrelated to meaning of the alt text associated to the image, which
is “[a] trademark attorney will navigate the trademark process for you.”
45. LZ’s unethical use of alt text violates the World Wide Web Consortium (“W3C”)
standards, which is the main international standard for the World Wide Web. ​See ​Exhibit 65​;
​ xhibit 63 ​(“some of your visitors cannot see images, be they blind, color-blind,
see also E
low-sighted; the alt attribute is of great help for those people that can rely on it to have a good
idea of what's on your page.”).
46. Thus, when a blind person visits this page with the help of a screen reader tool such as
Orca, he or she will hear the statement “[a] trademark attorney will navigate the trademark
process for you” and will be goaded into purchasing the service to file trademark, which process
is in fact not navigated by an attorney. For customers with healthy eyes, only when they hover
mouse cursor over the search button image, the same statement will be shown and in a similar
way, they will be goaded into purchasing the service to file trademark.
47. Other than deceiving handicapped persons and consumers, LZ’s use of alt text also serves
an important LZ purpose of deceiving search engines.
48. Although alt text of a web page is hidden, it is not hidden for internet search engines. As
the W3C standard states, “if you want your website to be indexed [by search engines] as well as
it deserves, use the alt attribute to make sure that they won’t miss important sections of your
pages.” ​Exhibit 63​.

4
The actual image is shown in ​Exhibit 54​.
14
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 49. In addition to the W3C standards, HTML.com states that:
The alt attribute is used to assign a text alternative to an img. The alternative text
is used anytime the image is not rendered and by assistive technologies such as
screen readers. In addition, search engines that offer image-based search
capabilities rely on the alt text to determine the meaning of images. Providing alt
values for images really isn’t optional, it’s something you absolutely should do if
you're a designer, developer, or webmaster. However, using the alt attribute
properly is just as important as using it in the first place.
Exhibit 64​.
50. By using the alt text describing an attorney service on a non-attorney service page
(​Exhibit 58​), LZ deceives Google and Bing search engines so that the page and the alt text
statement “[a] trademark attorney will navigate the trademark process for you” is indexed by
Google. This means that when a user searches “legalzoom trademark attorney” or similar terms
on Google, the alt text statement will show in Google search result. ​See​ Exhibit 56​ and below:

51. As a result, the alt text displayed as search result deceives customers that the link is about
LZ’s trademark registration services to be provided by trademark attorneys.
52. Exhibits and statements in ​Exhibit 52, 53, 55 and 58 ​were made with respect to “​A
trademark attorney will navigate the trademark process for you”​ were published, available to
the public, and printed and visible to handicapped access readers on September 18, 2018
(“when”). The statements (“what”) were made visible as a Google search result (“where”) on
the Google search engine (“how”), republishing statements originally made by LZ (“who”) on
the LZ website, on third party websites, or at public events. The statements were made with an
intent to deceive handicapped consumers and the public into thinking the statement “A
trademark attorney will navigate the trademark process for you” is truthful and legitimate for
the specific intent to harm competition.
53. “People with disabilities are at a higher risk of abuse, neglect and being victims of crime.
Estimates show they are at least four to ten times more likely victims than people without

15
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 disabilities are” according to Disability Rights California (​www.disabilityrightsca.org​).
54. LZ’s unethical use of alt text violates the World Wide Web Consortium (“W3C”)
standards, which is the main international standard for the World Wide Web. ​See ​Exhibit 65​;
​ xhibit 63 ​(“some of your visitors cannot see images, be they blind, color-blind,
see also E
low-sighted; the alt attribute is of great help for those people that can rely on it to have a good
idea of what's on your page.”).
C. LZ MISDIRECTS MOST CUSTOMERS SEEKING ATTORNEY-LED SERVICE TO
NON-ATTORNEY SERVICE PAGE, BUT SELECTIVELY AND SURREPTITIOUSLY
SHOW THE ATTORNEY-LED SERVICE PAGE TO SOME CUSTOMERS

55. LZ employs a software programming technique through “Optimizely” to display different

web pages to different users based on each user’s behavioral, contextual and demographic
attributes.5
56. When customers visit the non-attorney trademark service page (​Exhibit 58​) with the
URL: ​https://www.legalzoom.com/business/intellectual-property/trademark-registration
-overview.html​, some (but not all) customers are selectively directed to a different web page upon

arriving at this URL. A “-c” is surreptitiously appended to the URL which makes it
https://www.legalzoom.com/business/intellectual-property/trademark-registration
-overview​-c​.html​. This new URL is the attorney-led trademark service page (​Exhibit 62​).
57. However, LZ does not redirect all visitors to the new URL, but only selectively redirect
based on some user attributes such as income and profession. LZ achieves this selective
redirection by calling Optimizely’s Javascript when the web page (​Exhibit 58​) is being loaded.
Javascript Snippet for Optimizely is called at​ t​ he beginning of the source code:
<script type='text/javascript' src='//​cdn.optimizely.com​/js/7803129.js'></script>

See ​Exhibit 53​ at 1, line 9 (emphasis added).

58. Optimizely is described as the “world’s leading experimentation platform, enabling
businesses to deliver continuous experimentation and personalization” for websites. ​Exhibit 70​.
LZ employs Optimizely’s URL Targeting tools (as explained in ​Exhibit 71​) to deceive

5
​ ttps://help.optimizely.com/Ideate_and_Hypothesize/Strategy_essentials%3A
​See h
_Personalization on how Optimizely targets web visitors based on different attributes, including
their age, gender and income.
16
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
regulators and attorneys into thinking that LZ is legitimately directing traffic from consumers
searching for trademark attorneys to its attorney-led service page. In fact, it is not. The vast
majority of consumers are misdirected to the non-attorney service of ​Exhibit 58 ​from the search
result shown in ​Exhibit 55​.
59. This web page behavior was verified by Ryan Bethell (“Bethell”), attorney manager at
RAPC’s Tempe, AZ office. On September 19, 2018, Bethell conducted a test search of
“legalzoom trademark attorney” on Google, and saw on his computer screen the exact same
search result as shown in ​Exhibit 56​. When he clicked on the highlighted search result in
Exhibit 56​, he was first directed to the URL of the non-attorney service of ​Exhibit 58​. But
within a split of second and before that page was able to load, a “-c” was appended to the URL
and the attorney-led service page of Exhibit 62 was loaded and shown instead.
60. Exhibits and statements in ​Exhibit 53, 55, 58, and 69 as described in this section ​were
made with respect to the redirecting from advertisements from “​A trademark attorney will
navigate the trademark process for you​” were published, available to the public based on
cookies and browser data through an Optimizely script on ​Exhibit 58 on September 18, 2018
(“when”). The statements (“what”) were made visible as a Google search result (“where”) on
the Google search engine (“how”), republishing statements originally made by LZ (“who”) on
the LZ website, on third party websites, or at public events. The statements were made
surreptitiously with an intent to deceive regulators and licensed U.S. attorneys from not
challenging LZ’s trademark business model and for the specific intent to harm competition.
D. LZ’S MISLEADING STATEMENT “AVOID COSTLY CONFLICTS” IS FALSE AND
MISLEADING.

61. LZ used the false and misleading advertisements with the phrase “avoid costly conflicts”
in advertisements displayed to consumers when they search “trademark attorney”, “trademark
lawyer”, “legalforce”, and “legalforce trademarks.” LZ’s advertising targeting the RAPC was
unique to any other advertisement, and purposefully designed to draw false comparisons and to
mislead consumers. Particularly, in such ads, LZ wrote “Avoids Costly Conflicts” to mislead
customers by implying that RAPC conflict checks are harmful to them. (​Exhibit 105) ​As a
result, LZ has widely disseminated such false and misleading advertisements via the internet to

17
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
relevant purchasing public so as to sufficiently constitute commercial advertising under the
Lanham Act.
E. LZ’S FALSE STATEMENT "I'M ROBERT SHAPIRO AND I CREATED
LEGALZOOM."

62. Robert Shapiro, is well-known to the public as an attorney because of his participation in
the criminal defense of O.J. Simpson. LZ used the false advertisements with the phrase “I'm
Robert Shapiro and I created LegalZoom” in advertisements on television, on podcasts, and on
radio.6 This is a false statement. In fact, LZ’s real founder Lee (who was a suspended California
attorney at the time and even now) simply met Robert Shapiro through a phone solicitation at 9
P.M. at night after calling “411” for information.7
63. LZ makes these advertisements on television, on podcasts, and on radio were published,
available to the public over Youtube on September 21, 2018 (“when”). The statements (“what”)
were made visible as a Google search result (“where”) on the Google search engine (“how”),
republishing statements originally made by LZ (“who”) on national television, radio, podcasts,
on third party websites, and at public events. The statements were made to deceive the public
from the true identity of LZ’s founder Lee who was a suspended attorney in the State of
California when LZ was founded and that Robert Shapiro, with respect to LZ, is nothing more
than a paid spokesman who was given stock to act like he alone “created” LZ. However, letting
consumers across America know that LZ was founded by a suspended attorney would not have
the same marketing punch, and for this reason LZ made this statement in bad faith with a
specific intent to deceive consumers into thinking LZ employs lawyers like Robert Shapiro and
therefore is lawful and trustworthy.
II. ​Violation of Unauthorized Practice of Law
64. LZ violates Cal Bus. & Prof. Code § 6125 which provides that “[n]o person shall practice
law in California unless the person is an active member of the State Bar.” (​Exhibit 1​).
65. LZ unlawfully practices law while providing its non-attorney trademark filing service. LZ

6
LZ Television advertisement,
​https://www.youtube.com/watch?v=zp7bU5NGCfs&t=00m06s​.
7
PandoMonthly: A fireside chat with Shoedazzle’s Brian Lee,
https://www.youtube.com/watch?v=RE5HxiLpxd0&t=22m12s
18
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
and its non-attorney staff practice law by performing, without limitation, the following:
pre-filing trademark searches; creating and reviewing trademark applications; making legal
determinations about classification and other matters; advising clients on problems with their
applications including recommending changes to classifications and goods and services
descriptions; and filing trademark applications on clients’ behalf.
66. The USPTO defines the practice of law to include:
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. (​Exhibit 5​)
67. California courts have defined the practice of law to include, among other things:
a. Legal advice and counsel.
b. Preparation of legal instruments and contracts by which legal rights are secured
although such matter may or may not be depending in a court. ​Exhibit 16​ at 5.
68. LZ admits that its non-attorney “trademark specialists” practice law when it states on its
website: “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

19
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 your Advantage Jeans trademark is used for clothing, we will notify you if someone
uses Advantage for jewelry.” (​Exhibit 17​)
69. The following facts established through actual witnesses secured by RAPC demonstrate
LZ non-attorney “specialists” practice law:
a. LZ specialists conduct pre-filing searches for potentially conflicting marks.
b. LZ specialists modify template descriptions from the USPTO ID Manual.
c. LZ specialists sometimes advise by narrowing the classification to two potential
classes for purposes of the pre-filing search that would be conducted at the next step.
d. For application purposes, LZ specialists sometimes advise to leave the class blank
because of the consequences of the USPTO review process.
e. LZ specialists sometimes advise that additional items be incorporated into the
description of goods and services.
f. LZ specialists sometimes advise that the results of state and federal trademark
searches would not likely prevent registration of the mark.
g. LZ specialists sometimes advise (erroneously) that only similar marks within the
same international trademark classification of goods and services would pose a risk to
obtaining a federal trademark registration.
70. LZ take steps to conceal its legal advice by noting “problems with your order” on its
website and robo-calling customers, rather than creating an email “paper trail” of legal advice.
A few examples from witnesses are alleged in section “​Substantial Consumer Harm​” below.
71. In addition, LZ’s practice violates 18 U.S.C. § 1001 which is the United States federal
crime laid out in Section 1001 of Title 18 of the United States Code, which generally prohibits
knowingly and willfully making false or fraudulent statements, or concealing information, in
“any matter within the jurisdiction” of the United States. (​Exhibit 18​) A preliminary search of
public data reveals that LZ has been submitting directly or aiding and abetting their customers
in submitting dozens of fraudulent specimens to the USPTO. (​Exhibit 19, 20​)
72. LZ has submitted numerous clearly fraudulent specimens including ones listing Adam M.

20
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 Thomas, non-attorney investor in LZ, former member of the “senior leadership” at LZ8, and
former Vice President of Fulfillment Operations - Intellectual Property Division at LZ.
Knowingly making fraudulent statements to the USPTO violates 18 U.S.C. § 1001 and is a
federal crime carrying a maximum penalty of 5 years.9 These fraudulent specimens include
​ xhibit 20​,
fabricated proofs of use submitted to the USPTO on behalf of customers of LZ. ​See E
Declaration Of Randall Hull In Support Of Plaintiff’s Original Complaint. Despite submitting
fraudulent specimens, Mr. Thomas was regularly promoted at LZ and endorsed by corporate
officers at LZ on Mr. Thomas’s LinkedIn profile, including Chas Rampenthal, General Counsel
of LZ, and Ken Friedman, Vice President of Legal and Government Affairs at LZ. (​Exhibit 21​).
As a result, LZ knowingly permits their staff to submit fraudulent specimens by aiding and
abetting customers to knowingly commit a federal crime.
73. LegalZoom even boasts in its advertising with customer quotes hinting that they received
legal advice surreptitiously when it quotes customer Jeremy Hudson “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” (​Exhibit 110​). Moreover, LegalZoom’s CEO boasted that “we
finally shut down the unauthorized practice of lawsuit” and “it cost $16 million dollars over 11
10
years” , and when asked “what is it that you had to stop doing”, LegalZoom’s CEO defiantly

8
For example, see what appears to be fake or fraudulent specimens on US trademark serial
numbers ​86237568​, ​85638020​, and ​85014088 (​see ​Exhibit 19​), all listing Adam M. Thomas, a
former Vice President of LZ. 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 LZ 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 US and international locations.” Mr. Thomas also falsely
represents to the public he is a licensed attorney on his resume by indicating he was a “General
Counsel” of another company from 2015-2017.
9
​See also Nationstar Mortg. LLC v. Mujahid Ahmad​, 2014 TTAB LEXIS 350, *9 (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.”).
10
​Collision Conference interview​, May 5, 2016, New frontiers and how to tackle them - John
Suh & Jonathan Krim, ​https://www.youtube.com/watch?v=pHK21ta6yQI&t=4m40s
21
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 11
responded “​Nothing”​ .
Practice of Trademark Law before the USPTO
74. “Practice before the Office in trademark matters includes, but is not limited to, consulting
with or giving advice to a client in contemplation of filing a trademark application or other
document with the Office.” ​See ​Exhibit 22.​ Only attorneys may represent others before the
USPTO in trademark matters. ​See ​Exhibit 23​. An attorney is “an individual who is an active
member in good standing of the bar of the highest court of any State.” ​See ​37 CFR § 11.1;
Exhibit 24​.
75. Attorneys who practice before the USPTO in trademark matters are subject to regulation
by the states and should generally conform their practice to comply with both state bar rules and
the USPTO Rules of Professional Conduct. ​See, e.g,​ 37 CFR § 11.1 (“Nothing in this part shall
be construed to preempt the authority of each State to regulate the practice of law, except to the
extent necessary for the United States Patent and Trademark Office to accomplish its Federal
objectives.”). ​Id​. Attorneys who practice before the USPTO must ensure that they comply with
the various USPTO Rules of Professional Conduct, and their respective state rules.
76. One former 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 LZ applications:
a. The applications were typically rife with problems, and the applicant was often
“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-attorney “trademark specialists”
often diminished the scope of potential protection for successful applications because

11
​Collision Conference interview​, May 5, 2016, New frontiers and how to tackle them - John
Suh & Jonathan Krim, ​https://www.youtube.com/watch?v=pHK21ta6yQI&t=4m55s

22
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 they were too specific.
Substantial Consumer Harm
77. LZ has caused substantial harm to consumers because of their unfair competition and
unlawful practices. Listed below is a small sample of LZ customers (full names can be
submitted under seal) who have been harmed by LZ’s unlawful practices:
78. A.B. in Ashburn, Virginia requested a filing of trademark application for through LZ on
or about December 2017. A.B. was tricked by LZ’s paid search advertising into believing that
he would be represented by a team of trademark attorneys. Instead, he was directed to a
non-attorney landing page and workflow. A.B. originally entered a broader goods and services
description of his mark, which encompassed consulting services. LZ’s non-attorney staff
advised him to narrow the description to just “real estate”, despite A.B. preferring a broader
description. After the description was narrowed, LZ submitted his application and a serial
number was given. The USPTO later rejected A.B.’s application. A.B. has learned from
independent attorneys that he was tricked, and that there is only a 30% to 40% chance of
overcoming a rejection even if he separately retains them for more money.
79. D.H. in Willow Park, Texas ​requested filing of a trademark application through LZ on
or about December 2017. D.H. was tricked by LZ’s paid search advertising into believing that
he would be represented by a team of trademark attorneys with experience preparing and filing
trademark applications. Instead, he was directed to a non-attorney landing page and workflow.
As an Audit Manager and CPA professional in the 400+ employee distinguished accounting
firm in Dallas, D.H. found LZ’s manner of handling his matter suspicious when LZ’s
non-attorney staff surreptitiously called him to give him legal advice on the selection of
trademark classification and appropriate specimens. D.H. also found it odd that nothing was put
into writing, and LZ’s staff would repeatedly send him automated messages to call back and
then verbally asked him to change things around. LZ specifically tried to give D.H. guidance for
what class was appropriate for business cards and MP3s. The advice he received from LZ’s
non-attorney staff was faulty because his mark that LZ filed received an Office Action for
specimen issues. D.H. wrote to RAPC that “​The individuals I spoke with on the phone seemed

23
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
very confident however the results were obviously lackluster.​” D.H’s trademark was
subsequently rejected and there was no further follow up from LZ.
80. B.S. in Hagerstown, Maryland requested filing of a trademark application for the brand
through LZ on or about July 2017. B.S. was acting in his capacity as Chief Executive Officer
for his company. B.S. was tricked by LZ’s paid search advertising into believing that he would
be represented by a team of trademark attorneys with experience preparing and filing trademark
applications. Instead, he was directed to a non-attorney landing page and workflow. B.S. was
advised over the phone by LZ’s non-attorney staff on the selection of his trademark
classification prior to filing. B.S. does not believe he was informed by LZ that his privacy
would be waived when LZ paid government fees for his trademark filing on his behalf. He has
been getting solicitation emails and mailers ever since. B.S. wrote to RAPC that “ I was lead to
believe that legal zoom was paid a premium because they had attorneys specifically filing my
trademark.​ [sic].​”
81. J.C. in Cheyenne Wyoming requested filing of a trademark application for the brand
through LZ on or about July 2017. J.C. was acting in his capacity as President for his company.
J.C. was tricked by LZ’s paid search advertising into believing that he would be represented by
a trademark lawyer. Instead, he was directed to a non-attorney landing page and workflow. J.C.
wrote to the RAPC that “​We were under the impression that a lawyer would be managing the
process.​” and “​The application was unsuccessful and ultimately a waste of money and our
trademark is not protected​.” [sic]
82. Through its misrepresentations of being merely a “self-help” legal website, LZ has
obtained permission from states to sell its legal plans based on the false representation that itself
does not practice law. When LZ was denied registration to sell its Legal Plans by the State Bar
of North Carolina, LZ sued them into submission by including naming individual members of
State Bar ethics committees as defendants in their personal capacity. (See ​Exhibit 44​) RAPC
contends that LZ has unlawfully and unfairly obtained licenses to sell its legal plans based on
false representations that it does not practice law.
83. Many of LZ’s non-attorney staff involved in providing legal advice to customers. One

24
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
such example is Cheyenne Gabrourel-Moseley (“Moseley”) (​Exhibit 78​), Director - Production,
Business Services. Moseley is not an attorney and holds a B.A. degree in Criminology from
California State University-Bakersfield. Despite this, Moseley holds herself out as an attorney.
She signs USPTO trademark applications as though she is an attorney on behalf of LZ. For
example, Moseley listed herself as the lead attorney in the box ATTORNEY INFORMATION
for U.S. trademark application Serial 87365632 filed by LZ. (​Exhibit 79​).
84. Other LZ’s non-attorney staff involved in providing legal advice to customers of LZ
between the years 2015 and 2018. They provided legal advice on trademark descriptions and
classification selection, signed declarations, waived privacy protections, or otherwise filled out
USPTO trademark documents on behalf of LZ. They include:
a. Ennio Ochoa ​who was the former “Fulfillment Operations Manager” for Trademarks
at LZ (​Exhibit 80​) who provides legal advice and signs declarations on over 200 U.S.
trademark applications filed by LZ in the last 3 years.
b. Maria Clark​, former Trademark Specialist at LZ who provides legal advice and signs
declarations on over 5,300 U.S. trademark applications filed by LZ in the last 3 years
(​Exhibit 81​).
c. I. Valencia (who provides legal advice and signs declarations on over 400 U.S.
trademark applications filed by LZ in the last 3 years), a L. Yong (who provides legal
advice and signs declarations on over 10,000 U.S. trademark applications filed by LZ
in the last 3 years).
d. Vance Parker who is a Senior Intellectual Property Specialist at LZ who provides
legal advice and signs declarations on over 10,000 U.S. trademark applications filed
by LZ in the last 3 years (​Exhibit 82​).
e. Angela Poghosyan a Partner Manager at LZ who provides legal advice and signs
declarations on over 300 U.S. trademark applications filed by LZ in the last 3 years
(​Exhibit 83​).
f. Daniel McMahon​, a Robotic Process Automation Developer at LZ who built the
framework for the automatic trademark signature signing tool in the Kofax Papow

25
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 framework whose software tools were used to “robo sign” over 6700 trademark
applications filed by LZ (​Exhibit 84​).
g. Anh Tran, ​former Director of Operations for LZ (​Exhibit 89​).
h. Josh Hart, Lead, Trademarks at LZ who provides legal advice and signs declarations
on over 100 U.S. trademark applications filed by LZ in the last 3 years as well as
supervising the team since April 2016 (​Exhibit 90​).
LZ has a pattern of engaging in the unauthorized practice of law.
Missouri Court States that LZ Goes Beyond Self-Help
85. In a Missouri case, the Court noted that LZ engaged in UPL under Missouri law. ​See
Janson v. LegalZoom.com, Inc.,​ 802 F. Supp. 2d 1053, 1064 (W.D. Mo. 2011) (“It is the second
function of LegalZoom's website that goes beyond mere general instruction.…LegalZoom
reassures consumers that ‘we'll prepare your legal documents,’ and that ‘LegalZoom takes over’
once customers ‘answer a few simple online questions.’ … LegalZoom’s legal document
preparation service goes beyond self-help because of the role played by its human employees,
not because of the internet medium.”). The plaintiffs purchased estate planning and LLC
organization services. ​See​ ​Exhibit 4​.
86. Ultimately, the case was dismissed pursuant to a settlement. ​See ​Janson v.
LegalZoom.com, Inc., No. 2:10-cv-04018-NKL, 2012 U.S. Dist. LEXIS 60019 (W.D. Mo.
2012). However, the case importantly showed that the court believed that LZ did in fact likely
engage in UPL. ​See ​Exhibit 4​. ​In the 40 page settlement, LZ agreed to pay up to $6,000,000
including attorney’s fees for engaging in UPL after the plaintiffs claims survived a Motion for
​ xhibit 85​, pg. 12, ​highlighted)​
Summary Judgment in part. (​See E ​The court incorrectly held
that “held that Plaintiffs' claims based on LZ’s patent and trademark products sold to Missouri
customers were preempted by federal law permitting nonlawyers to practice before the United
States Patent and Trademark Office [sic]. Products excluded from Class Products as a result
include Design Patent, Full Patent, Patent Search, Provisional Patent (Self-Help), Trademark,
Trademark Monitoring, and Trademark Search.” ​(​See ​Exhibit 85​, pg. 2, ​highlighted ​& Order on
MSJ in ​Exhibit 86​). In the Order on the Motion for Summary Judgment, the court held that

26
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
“With respect to patent and trademark law, federal law preempts Plaintiffs’ claims.” (​Exhibit
86​, page 28)​ . However, there is no federal law permitting nonlawyers to practice before the
USPTO for trademark, trademark monitoring, and trademark search matters. The ​Sperry​, ​Kroll​,
and ​Augustine c​ ases cited by the court do not specifically address trademark practice before the
USPTO.12 To the contrary, individuals must be licensed in a state to practice trademark law
before the USPTO. (​Exhibit 87​). USPTO regulations specifically require that “Any individual
who is an active member in good standing of the highest court in any State may represent others
before the USPTO in trademark matters.” (​Exhibit 87​)
87. LZ’s staff which provides legal advice on trademark matters on its $199 non-attorney
trademark filing service are not attorneys licensed in any state. In addition, while allegations
here are not brought with respect to patent matters - for design patent, utility patent (“full
patent”), patent search, and provisional patent matters, an individual must have a technical
undergraduate degree and must take a patent bar exam to be licensed to practice patent law
before the USPTO. (​Exhibit 88​).
California Case Highlighting Settlement of Two LZ Class Actions
88. In an California opinion, the 2nd District Court of Appeals affirmed a settlement of two
class actions against LZ. ​See Webster v. Legalzoom​, 2014 Cal. App. Unpub. LEXIS 6972 (Cal.
App. 2d Dist. Oct. 1, 2014) ​rev. dismissed 2​ 014 Cal. LEXIS 12132 (Cal., Dec. 4, 2014). ​See
Exhibit 47​.
89. Specifically, one plaintiff sued under unfair competition (Cal. Bus. & Prof. Code Section
17200), and the Legal Document Assistant Act (Cal. Bus. & Prof. Code Section 6400-6415).
The second plaintiff sued under unfair competition (Cal. Bus. & Prof. Code Section 17200), and
the Consumer Legal Remedies Act (Cal. Bus. & Prof. Code Section 1750 ​et. seq​.). The second

12
​See ​Sperry v. Florida ex rel. Florida Bar,​ 373 U.S. 379, 385-87 (1963) (dealing exclusively
with patent practice before the USPTO by a non-attorney, but also noting that it was significant
that the language of the regulation covering patent practice was different from that of
trademarks); ​Kroll v. Finnerty​, 242 F.3d 1359, 1364 (Fed. Cir. 2001) (concerning disciplinary
proceedings in New York against a patent attorney and only weighing in on the regulations
governing patent practitioners); and ​Augustine v. Dep't of Veterans Affairs,​ 429 F.3d 1334, 1340
(Fed. Cir. 2005) (regarding practice before the Veterans Administration Merit Systems
Protection Board).
27
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
plaintiff later added the Legal Document Assistant Act (Cal. Bus. & Prof. Code Section
6400-6415), unjust enrichment, and declaratory relief. One plaintiff’s case dealt with estate
planning, while the other appears to deal with a business issue.
90. While LZ did not admit wrongdoing, this case is important to show that LZ was accused
to misleading customers and failing to comply with the Legal Document Assistant Act.
Texas Case Failing to Certify Class Action Alleges Government Filing Fee Abuse
91. Plaintiff alleged that LZ charged clients $325 for TEAS government fee, put only paid
$275 to the USPTO using TEAS Plus and pocketed the difference and claimed common law
violations of conversion, breach of contract, breach of fiduciary duty, fraud, UCL, and false
advertising, but the appeals court denied nationwide class certification, but left open the
opportunity for a more localized class action. ​See Solotko v. LegalZoom.com, Inc., No.
03-10-00755-CV, 2013 Tex. App. LEXIS 8413 (App. July 11, 2013) ​rev. denied,​ No. 13-0840,
2013 Tex. LEXIS 1061 (Dec. 13, 2013) ​See​ ​Exhibit 48​.
92. Arkansas Case Involving UPL Subject to FAA
93. In Arkansas, the Supreme Court of that state held that LZ was entitled to compel
arbitration, even if the dispute concerned allegations of UPL. ​LegalZoom.com, Inc. v.
McIllwain​, No. 12-cv-1043, 2013 Ark. 370 (Ark. Oct. 3, 2013) ​cert. denied,​ 134 S. Ct. 1563
(2014). The lower court found the arbitration agreement unenforceable because of the
unconscionability of the agreement—since LZ was alleged to have violated the Arkansas Rules
of Professional Conduct, etc., insomuch as the arbitration agreement took away the authority of
the court to regulate the practice of law. The plaintiff purchase estate planning services. While
LZ was able to compel arbitration, the Supreme Court ultimately directed the clerk to file a
copy of the opinion with the Arkansas Supreme Court Committee on UPL. ​See​ ​Exhibit 49​.
Ohio Case Involving UPL Subject to Dismissal without Supreme Court Finding of UPL
94. A District Court in Ohio granted LZ’s motion to dismiss a putative class action
contending that LZ violated Ohio consumer protection laws. ​See Lowry v. Legalzoom.Com, Inc.,
No. 4:11CV02259, 2012 U.S. Dist. LEXIS 100155 (N.D. Ohio July 19, 2012). One of the
statutes states that "[n]o person who is not licensed to practice law in this state shall ... commit

28
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
any act that is prohibited by the supreme court as being the unauthorized practice of law." ​See
Oh. Rev. Code § 4705.07(A)(3). The statute goes on to state “[a]ny person who is damaged by
another person who commits a violation of division (A)(3) of this section may commence a civil
action to recover actual damages from the person who commits the violation, ​upon a finding
by the supreme court ​that the other person has committed an act that is prohibited by the
supreme court as being the unauthorized practice of law in violation of that division.” ​See Oh.
Rev. Code. § 4705.07(C)(2) (emphasis added). ​See​ ​Exhibit 50​.
Washington Settlement Barred LZ from UPL, Privacy Violations, and Providing Forms not
Compliant with Washington Law
95. The Consumer Protection Division of the Washington Attorney General’s office
investigated LZ and entered into a settlement agreement titled “Assurance of Discontinuance”
where LZ agreed, without admitting wrongdoing, to not engage in certain actions including
engaging in UPL, selling consumer information, and stating that privilege and confidentiality do
not apply. ​See​ ​Exhibit 51​.
III. ​LZ has a pattern and practice of engaging in unfair, unlawful, and fraudulent business
practices in the marketing and sale of legal document assistant ("LDA") services.
96. LZ markets and sells legal documents through its website by representing that it will
provide services which it is not legally entitled to provide under California laws regarding
LDAs and the unauthorized practice of law. Cal. Bus. & Prof. Code § 6411(a) prohibits the
making of misleading statements regarding the scope of such LDA services, including also that
"100 percent satisfaction" can be guaranteed. Additionally, LZ does not comply with
requirements for LDAs under Cal. Bus. & Prof. Code §§ 6408 and 6410, including making
specific disclosures to consumers regarding their rights to refunds and contract rescission, the
availability of attorneys' fees, and how to report the unauthorized practice of law on each of
their forms. Further, LZ has no method by which to determine whether any particular client
requires services beyond that which it is legally entitled to provide or to inform such clients that
their situation requires the services of an attorney, in violation of Cal. Bus. & Prof. Code §
6401.6.

29
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 97. LZ represents that it can provide services and a product which it is not legally entitled to
provide, including but not limited to the following: a) "unlimited customer support"; b)
"customized" legal documents; c) a thorough and careful review of a customer's documents for
accuracy and reliability; and d) legal documents which are guaranteed to be valid and
enforceable in all 50 states.
98. RAPC on behalf of customer Team Messaging Solutions Inc. purchased and received
services from LZ. Specifically, Team Messaging Solutions Inc. purchased a trademark filing
service for the PIGGIEBANK product name.
99. As the direct result of LZ’s unfair, unlawful and fraudulent business practices, Team
Messaging Solutions Inc. suffered actual pecuniary harm in the form of lost payments made to
LZ.
100. LZ’s business is premised on creating a false sense of security that people do not need
to hire a traditional attorney because LZ can assure through development of its materials by top
attorneys, unlimited customer support, and a peace-of-mind review guarantee, that all work
done will be legally binding and reliable.
101. Elsewhere on LZ’s website, it confusingly represents it ​actually is a​ legal document
service by maintaining as current press releases. In a press release on the LZ website as of
September 20, 2018, LZ writes “LegalZoom.com's legal document assistants review all
submissions for completeness and consistency” and “LegalZoom also offers attorney referral
services.” (​Exhibit 98​). In addition, on numerous web pages on the LegalZoom.com website as
of September 20, 2018, LZ continues to represent itself as a registered legal document assistant.
For example, ​Exhibit 93 shows that LZ writes “LegalZoom.com, Inc. is a registered and
bonded legal document assistant, #0104, Los Angeles County (exp. 12/13).” Similarly, ​Exhibit
94 also includes the same line about being a “registered” and “bonded legal document
assistant.” It appears that LZ’s registration has expired. (​See ​Exhibit 72​).
102. Pursuant to Cal. Bus. & Prof. Code § 6400, LDAs are prohibited under California
law from providing legal advice or otherwise engaging in the practice of law.
103. An LDA may only provide "self-help" or secretarial assistance to members of the

30
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
public in exchange for compensation. "Self-help service" is defined as any of the following:
a. Completing legal documents in a ministerial manner, selected by a person who is
representing himself or herself in a legal matter, by typing or otherwise completing
the documents at the person's specific direction.
b. Providing general published factual information that has been written or approved by
an attorney, pertaining to legal procedures, rights, or obligations to a person who is
representing himself or herself in a legal matter, to assist the person in representing
himself or herself. This service in and of itself, shall not require registration as a
legal document assistant.
c. Making published legal documents available to a person who is representing himself
or herself in a legal matter.
d. Filing and serving legal forms and documents at the specific direction of a person
who is representing himself or herself in a legal matter.
Cal. B&P §6400(d).
104. However, many prominent statements on its website and in its marketing material
confirm that LZ does more than it is permitted to do as an LDA. In fact, the service LZ purports
to provide on its website and in its marketing constitute the unauthorized practice of law in
violation of B&P Code §§6125 and 6126. LZ in fact does provide what amounts to legal advice
in offering specific forms, helping to select forms, and providing advice or options to users
which result in the execution of legal documents with or without certain information.
105. As shown by the information provided in customer reviews of trademark services
published by LZ on its website (​Exhibit 92​), LZ is clearly providing customers with more than
just the services authorized for legal document assistants. LZ's employees are providing legal
advice assistance amounting to the unauthorized practice of law. The customers note that they
received answers to ​any questions they asked, they received legal advice on the classes and
categories for the trademark, LZ corrected not just typos but misunderstandings of trademark
elements to correct filings. This level of back and forth and legal advice rises beyond mere legal
document assistance and into the practice of law; it is far more than just typing or otherwise

31
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
completing the documents at a person's specific direction.
106. Throughout LZ’s website and other marketing materials, LZ prominently states that
its products are "customized" to each client's particular needs: "We set up a customized
trademark monitoring query." (​Exhibit 106​) and “We develop a customized search strategy.”
(​Exhibit 107​).
107. As an LDA however, LZ cannot give advice or select or "customize" legal documents
for its clients, but can only fill in documents at the ·client's direction. Despite this, LZ boldly
claims on its website that:
a. “We've Filed More Than 250k Applications & We're Still Counting!” (​Exhibit 95​)
b. “Let Us Help You.” (​Exhibit 55​)
c. “Peace Of Mind Review.”(​Exhibit 96​)
d. “File Your Trademark Easy, Hassle-Free And Affordable.” (​Exhibit 97​)
e. “Search Trademarks In All 50 States” (​Exhibit 97​)
108. LZ emphasizes that it was developed and is overseen by expert attorneys and
capitalizes on the fact that one of its strawman co-founders Robert Shapiro, is well-known to the
public as an attorney because of his participation in the criminal defense of O.J. Simpson. In
many of its ads, Mr. Shapiro appears stating, "I'm Robert Shapiro and I created LegalZoom."13
LZ claims that its documents are navigated by a "trademark attorney." (​Exhibit 58​) In other
pages, LZ says for trademarks a "personally review" "for completeness and consistency" is
offered for their peace of mind non-attorney service. (​Exhibit 108​) It tells customers that they
will save thousands of dollars by using LZ because an attorney would charge that much of the
same product. However, LZ is only an LDA. It is not authorized to practice law or provide the
careful review for mistakes and quality that a licensed attorney may provide. Additionally, in
response to a previous lawsuit (​Webster ​v. LegalZoom,​ Superior Court for the County of Los
Angeles, BC438637), Mr. Shapiro contended through his attorney that he is a “passive
shareholder and a spokesperson” for LZ and is “not involved in management.” In fact, LZ’s
real founder Brian Lee (who was a suspended California attorney at the time and even now)

13
LZ Television advertisement,
​https://www.youtube.com/watch?v=zp7bU5NGCfs&t=00m06s​.
32
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
simply met Robert Shapiro through a phone solicitation at 9 P.M. at night after calling “411” for
information.14
109. LZ has trademarked the phrase "Peace of Mind Review," which LZ contends makes it
more reliable and thorough. LZ states on its website that it is different from a do-it-yourself kit
or software because LZ will personally review its customers' answers for "completeness and
consistency." (​See ​Exhibits ​14-15​.) As an LDA, however, LZ is not legally permitted to correct
its customers' mistakes other than secretarial corrections such as spelling.
110. An LDA may not "provide service to a client who requires assistance that exceeds the
definition of self-help service [as defined in B&P Code § 6400(d)], and shall inform the client
that the client requires the services of an attorney." Cal. B&P Code §6401.6.
111. LZ has no method by which it can determine whether any particular client requires
services which exceed what LZ may' legally provide. Neither does LZ have a procedure by
which. to notify those clients that they need an attorney.
IV. ​Acting As Unregistered Lawyer Referral Service
112. LZ violates Cal. Bus. & Prof. Code § 6155(a) by providing referrals to lawyers of
potential clients from a lawyer referral service not registered with the State Bar of California.
​ xhibit 72​).
(​See E
113. Cal. Bus. & Prof. Code § 6155(a) provides that “[a]n individual, partnership,
corporation, association, or any other entity shall not operate for the direct or indirect purpose,
in whole or in part, of referring potential clients to attorneys,” unless the service is registered
​ xhibit 73​, ​highlighted)​
with the State Bar of California as a “lawyer referral service”. (​See E
According to the State Bar of California, “[a] lawyer referral service refers potential clients to
​ xhibit 74​).
attorneys.” (​See E
114. LZ has been acting as an agent for its attorneys in soliciting potential clients using
LZ.com’s legal resource pages. (​See ​Exhibits 75, 76​.) LZ then advertises these pages or causes
these pages to show up on the search results of Google and other online marketplaces. At the
end of each legal resource page there is always a direct solicitation of legal services for its

14
PandoMonthly: A fireside chat with Shoedazzle’s Brian Lee,
https://www.youtube.com/watch?v=RE5HxiLpxd0&t=22m12s
33
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
attorneys.
115. These legal resource pages include sales pitch for LZ through which it steers referrals
to independent attorneys. For Example:
a. “[I]f you think you need legal consultation, LegalZoom can also ​refer you to a
trusted trademark attorney.” (​Exhibit 75​, ​highlighted, emphasis added.​ )
b. “If you haven't found an attorney yet, LegalZoom can help”. (​Exhibit 76​,
highlighted​.)
116. LZ carefully avoids mentioning the words “refer” or “referral” on many of its web
pages (except in ​Exhibit 75 where “refer” is explicitly stated). However, a service that connects
potential clients with the independent attorneys is nothing but a lawyer referral service.
117. Although there is a disclaimer in some of LZ’s web pages stating that LZ is not a
​ xhibit 66 at 4 (“ATTORNEY ADVERTISEMENT: This portion
“lawyer referral service”, ​see E
of the LZ website is an advertisement. This portion of the LZ website is not a lawyer referral
service.”), referring attorneys to potential clients is in essence what LZ provides here. In web
page titled “Trademarking Groundhog Day” (​Exhibit 75​), customers looking for trademark
attorneys are referred to independent attorneys when they sign up for LZ’s monthly legal plan.
LZ advertises these attorneys in its “Attorney Directory”. A version of Attorney Directory for
Trademark Attorneys is found in web page titled “Trademark - Find an Attorney Who Has
Knowledge of Trademark”. ​See ​Exhibit 72​.
118. LZ is thus a ​de facto “lawyer referral service”, however, it is not registered with the
State Bar of California. (​See ​Exhibit 77​.) Therefore, LZ has violated Cal. Bus. & Prof. Code
§ 6155(a).
V. ​Acting as Runner and Capper to Solicit Business for Attorneys
119. LZ violates Cal. Bus. & Prof. Code § 6152 by acting as a runner and capper to solicit
legal service for LZK, a UK-based law firm, and for other independent attorneys. LZK is a law
firm registered by the Solicitors Regulation Authority (“SRA”) of England and Wales under ID:
617803 and registered with the UK Companies house under company number 08823370.
(​Exhibit 111​). According to SRA records, LZK has one solicitor, U.S. attorney James Peters

34
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 (also a James Peters - VP - New Market Initiatives at LZ), who also serves as a manager of
LZK, alongside Craig Holt, Francis Monestere, Peter Henry Oey, and Sham Telang. No other
solicitors appear to be registered with LZK. It does not appear that the above attorneys working
for LZK maintain a client trust account for US clients in the State of California.
120. LZ’s CEO John Suh has recently said, in “chapter 3” of LZ’s corporate evolution, that
it can provide legal services in the United States since it became a law firm in United Kingdom
15
in 2015 when he stated as much in an Ernst & Young interview and a similar interview with a
16
customer Bill Carmody in the United States less than a month earlier. Suh even explained that
LZ’s law firm structure in the United Kingdom enables the company to practice law in the
United States to the New Hampshire Bar while also boasting that LZ has spent two years
advertising their new “law firm” structure and how certain practice areas are entirely done with
17
a lawyer. In reality, LegalZoom is not a law firm in the United States and is not authorized to
practice law in any state. LegalZoom has become a law firm in the United Kingdom only after
acquiring a law firm in that country following deregulation of ownership of law firms in the
United Kingdom in 2012. (​Exhibit 109​)
121. “Lead Trademark Attorney” Nicholas Santucci (“Santucci”) is the Lead Trademark
Attorney at LZK who has been leading LZ’s attorney led trademark filing and watch services.
Since 2017, Santucci has been the attorney of record for at least forty-three (43) trademark
applications filed with the United States Patent and Trademark Office. (​Exhibit 3​). As a New
York licensed attorney practicing federal trademark law in California, Santucci aids and abets
LZ, a non-lawyer, to practice law. He also unlawfully shares legal fees with LZ through a
foreign law firm LZK, which is owned 100% by non-lawyer LZ.
122. It appears that the conduct of Santucci by sharing fees with non-practitioner LZ, and
possibly violating multiple other conduct rules by allowing LZ to market legal services without

15
LegalZoom exec reflects on the company’s evolution, on November 16, 2016,
https://www.youtube.com/watch?v=ORbZcMmDJOs&t=2m49s
16
John Suh, CEO of LegalZoom interview with Bill Carmody on October 21, 2016,
https://www.youtube.com/watch?v=aOKFr2XTbsE&t=12m52s
17
New Hampshire Bar Association Midyear Meeting held in Manchester, NH, on March 4,
2016, ​https://www.youtube.com/watch?v=ClBpYWcc6jU&t=4m31s
35
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
appropriate compliance with advertising rules, likely violates various provisions of the USPTO
Rules of Professional Conduct. The status of LZK as an SRA-licensed Alternative Business
Structure does not shield the attorneys from liability and rather creates a monopoly power for
LZ in the relevant market for online trademark filing services by private entities.
123. Even if LZK complies with the SRA rules regarding conflicts and client accounts,
they likely cannot comply with the fee sharing and independence requirements under the
USPTO Rules of Professional Conduct. Furthermore, while LZ also appears to also offer legal
referral services, the sheer fact that LZ owns LZK, and likely controls certain legal functions,
creates a unreasonable restraint on trade.
124. Cal. Bus. & Prof. Code § 6151(a) defines a runner or capper as “any person, firm,
association or corporation acting for consideration in any manner or in any capacity as an agent
for an attorney at law or law firm, whether the attorney or any member of the law firm is
admitted in California or any other jurisdiction, in the solicitation or procurement of business
for the attorney at law or law firm.” ​Exhibit 45​.
125. According to Cal. Bus. & Prof. Code § 6152(a), it is unlawful “for any firm,
corporation, partnership or association to act as a runner or capper for any attorneys or to solicit
any business for any attorneys … in any public place … or upon private property of any
character whatsoever.” ​Exhibit 2​.
126. Starting on November 21, 2017, LZ began referring solicited clients who apply for
“attorney led” trademark filings in the United States to its foreign subsidiary LZK, a law firm
organized in the United Kingdom. ​Exhibit 3 ​shows a collection of trademarks for U.S.
customers of LZ which have been filed by U.S. licensed attorneys working at LZK. LZK hires
U.S. licensed trademark lawyers (including Santucci, ​see ​Exhibit 27​) to work from LZ’s
corporate offices in Austin, Texas or Glendale, California to practice law. Through this method,
LZ also ignores 37 CFR §11.504, the USPTO’s ethics rule regarding prohibitions of
corporations owning law firms that practice before the USPTO. (​Exhibit 7​).
127. When US-based clients of LZ visit the LZ website, they select and purchase legal
services, including trademark registration and Office Action responses, and then purportedly

36
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
engage LZK to perform the legal services. The payment for legal services is delivered to LZ, the
non-law firm entity. (“LegalZoom UK uses certain service providers to complete the services
under this Agreement. Any funds required for those covered services are included in your
​ xhibit 25 at 2. Any
original payment and require no additional payment by you.”). ​See E
termination of LZK “is subject to the agreement between you and LegalZoom.com, Inc.” ​See
Exhibit 25​ at 12.
128. It appears that LZK employs New York and Iowa-licensed attorneys to practice
​ preadsheet of USPTO applications filed by LZK
before the USPTO in trademark matters. ​See S
for U.S. customers of LZ (​Exhibit 3​).
129. It appears that Santucci (​Exhibit 27​), Kaela Joyner (“Joyner”, ​Exhibit 28)​, and
Alexander JSW Johnson (“Johnson”, ​Exhibit 29​) prepare the selected applications for clients of
LZ, on behalf of their employer, LZK, while physically located within the LZ office in Austin,
Texas or Glendale, California.
130. Therefore, LZ violates Cal. Bus. & Prof. Code § 6152(a) because it acts as runner
and capper to solicit legal service for LZK, a UK-based law firm.
131. LZ violates Cal. Bus. & Prof. Code § 6152(a) also because it solicits and refers legal
​ ection IV “Acting As Unregistered Lawyer
services for other independent attorneys. ​See S
Referral Service” ​supra.
132. Violation of Bus. & Prof. Code § 6152(a) is “punishable, upon a first conviction, by
imprisonment in a county jail for not more than one year or by a fine not exceeding fifteen
thousand dollars ($15,000), or by both that imprisonment and fine.” Bus. & Prof. Code § 6153.
(​See ​Exhibit 46​.) Upon a second or subsequent conviction, “a person, firm, partnership,
association, or corporation is punishable by imprisonment in a county jail for not more than one
year, or by imprisonment pursuant to subdivision (h) of Section 1170 of the Penal Code for two,
three, or four years, or by a fine not exceeding fifteen thousand dollars ($15,000), or by both
that imprisonment and fine.” ​Id.
133. The consumer injury caused by LZ’s violation of Cal. Bus. & Prof. Code § 6152(a) is
substantial because the contract between consumers and their attorneys secured through LZ is

37
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
voided by law. Bus. & Prof. Code provides the following:
Any contract for professional services secured by any attorney at law or law
firm in this state through the services of a runner or capper is ​void​. In any
action against any attorney or law firm under the Unfair Practices Act,
Chapter 4 (commencing with Section 17000) of Division 7, or Chapter 5
(commencing with Section 17200) of Division 7, any judgment shall include
an order divesting the attorney or law firm of any fees and other compensation
received pursuant to any such void contract. ​Those fees and compensation
shall be recoverable as additional civil penalties under Chapter 4
(commencing with Section 17000) or Chapter 5 (commencing with Section
17200) of Division 7.
Bus. & Prof. Code § 6154 (emphasis added). Furthermore, the attorney fees and compensation
charged by LZ shall be recoverable as additional civil penalties. ​Id.
FIRST CLAIM FOR RELIEF
FALSE OR MISLEADING ADVERTISING
THE LANHAM ACT, 15 U.S.C. § 1125(a)
134. RAPC repeats each and every allegations contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
135. LZ violated 15 U.S.C. § 1125(a) by making the false and misleading advertising
statements as alleged in Section I, ​supra.​
136. The statement was made as a commercial advertisements or promotions because:
a. It was designed to promote the services of LZ;
b. It proposed commercial transactions, including but not limited to the purchase of
LZ’s non-attorney trademark filing service;
c. It promoted LZ’ commercial activities;
d. It was motivated by LZ’ economic interests; and
e. The statement were sufficiently disseminated to the relevant purchasing public,
namely consumers seeking trademark protection assistance.
137. The statement was made in connection with services offered by LZ. The statements
relate to descriptions or representations of fact that misrepresent the nature, characteristics, and
quality of LZ’s services.
138. LZ’s false or misleading advertisements have caused and, unless enjoined, will

38
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
continue to cause immediate and irreparable harm to RAPC’s for which there is no adequate
remedy at law. In addition, as a result of LZ’s false advertisements, RAPC has been injured,
including but not limited to, lost customers, direct diversion of sales from RAPC to LZ, decline
in sales and market share, lost profits, having to pay increased advertising costs, loss of
goodwill, and additional losses and damages.
139. Furthermore, LZ has been unjustly enriched at the expense of RAPC as a
consequence of LZ’s false and misleading advertising. Accordingly, RAPC is entitled to
injunctive relief and to recover up to three times the damages sustained by RAPC, as well as
LZ’s profits, and reasonable attorney fees under 15 U.S.C. §§ 1114, 1116, and 1117.
SECOND CLAIM FOR RELIEF
CONSPIRACY TO RESTRAIN TRADE
SHERMAN ACT, 15 U.S.C. § 1
140. RAPC repeat each and every allegations contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
141. Section 1 of the Sherman Act, 15 U.S.C. § 1, provides:
Every contract, combination . . . , or conspiracy, in restraint of trade or
commerce among the several States, or with foreign nations, is declared to be
illegal. Every person who shall make any contract or engage in any
combination or conspiracy hereby declared to be illegal shall be deemed
guilty of a felony . . . .
142. LZ is liable as a co-conspirator to restrain trade under the Sherman Act 15 U.S.C. § 1
along with Beaumont Legal, the USPTO and the State Bar of California.
143. Beaumont Legal is a United Kingdom law firm that was acquired by LZ in 2015 and
rebranded as LZK (​Exhibit 109​). It is a horizontal market participant because it offers online
trademark filing services and therefore has no sovereign immunity.
144. The USPTO is an agency in the United States Department of Commerce that issues
patents to inventors and businesses for their inventions, and trademark registration for product
and intellectual property identification. The USPTO has not waived sovereign immunity or
consented to be named as a respondent, and therefore remains an uncharged co-conspirator.
145. The USPTO conspires in conjunction with LZ to restrain trade because it knowingly
permits LZ to fund a government deposit advance account to which LZ has paid $23,191,950

39
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
between 2015 to 2017 to support the USPTO’s operations, accounting for over 5% the
USPTO’s trademark budget. (​Exhibit 99​).
146. If the USPTO were deprived of the income it receives from LZ, the USPTO would
have to cut back on staff and benefits for USPTO Examiners. For this reason, the USPTO has
conspired to restrain trade because it does not enforce its own rules against LZ while actively
enforcing its rules against other smaller non-law firm entities (​Exhibit 100​) and disciplined
lawyers for conduct that is less egregious than that of LZ. Moreover, besides permitting LZ to
place money in a deposit advance account, the USPTO conspires with LZ because it knowingly
permits LZ’s non-attorney employees to enter their email address on USPTO’s “E-Signature(s)
Request Form (​Exhibit 104​) when generating signature links for customers despite receiving
dozens of complaints from internal USPTO trademark attorneys, private law firms, licensed
attorneys, and the public on the rampant unauthorized practice of law of LZ. LZ later waives
privacy rights of customers through Form 1478 without their consent (​Exhibit 101​).
147. LZ enters the customer’s information directly into the USPTO website and requests a
link from the USPTO to the signature form using an internal LZ non-attorney staff’s email ID.
(​Exhibit 104​) Upon information and belief, LZ then repackages this link and sends it to the
customer in a templated email including the USPTO link. After the customer signs the USPTO
link, LZ’s non-lawyer staff again goes to a different USPTO link emailed to LZ by the USPTO
which expressly waives each customer’s right to privacy and has LZ attest that it has the
authority to grant the USPTO permission to make information submitted available on its online
database regardless of the underlying copyrights. (​Exhibit 101) ​On this same form, LZ pays the
government fee to the USPTO on its own LZ credit card and/or deposit account with the
USPTO. ​Id. LZ does not refund $50 of the collected $275 government fee collected through its
website if the non-lawyer staff at LZ determine that the trademark qualifies as a TEAS Plus
application with the lower filing fee of $225.
148. Exhibit 102 ​shows a list of LZ email addresses used in tens of thousands of USPTO
forms 1478 for different customers between 2015 and 2017. Each are associated with a
non-attorney who waived privacy and provided legal advice to customers as described with

40
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
respect to ​Exhibits 78-90​. Once again, unlike smaller non-law firm entities (​Exhibit 100​) and
disciplined lawyers (​Exhibit 103​) that violate USPTO rules, the USPTO ignores LZ’s conduct,
so that both work together to maximize the work done by non-attorneys.
149. LZ conspires with the USPTO and the State Bar of California to restrain trade by
RAPC and other lawyer-practitioners by continuing to unlawfully use non-attorneys knowing
that LZ will be treated differently from RAPC and lawyers for no legitimate governmental
purposes. The USPTO has general statutory power under 35 U.S.C. § 2(a) to grant and issue
U.S. trademarks, as well as specific statutory power under 35 U.S.C. § 2(b)(2)(D) to regulate
the conduct of lawyers and nonlawyers practicing before the USPTO. It also has statutory
power under 35 U.S.C. § 32 to suspend or exclude any persons who do not comply with the
regulations promulgated by the USPTO.
150. However, although fully empowered by congressional authorities to regulate the
conduct of all trademark practitioners, which include both lawyers and nonlawyers, the USPTO
only selectively enforces the regulations to its full extent upon lawyer-practitioners, but —no
regulations at all—upon LZ. Lawyer-practitioners including RAPC and LZ are treated
differently by the USPTO despite the fact that they are similarly situated—that they both
provide trademark filing service before the USPTO, and nothing more. The USPTO and LZ
know that LZ has been openly violating the laws and regulations and has harmed market
competition and restrained trade as a result.
151. Nonetheless, the USPTO and LZ continue to work together perpetrating LZ’s use of
non-attorneys and USPTO even argued it not even in the position to regulate unlawful conduct
committed before it. The USPTO’s argument flies in the face of its recent Show Cause orders
against foreign companies operated by nonlawyer-practitioners (​Exhibit 100​), which further
evidence that is not a matter of being unable to regulate the conduct, and that the USPTO and
LZ knowingly work together to promote LZ’s unlawful practice of law at the expense of other
similarly situated practitioners. The USPTO seems to give deference to LZ in the United States,
whose fees paid to the USPTO help to support a significant percentage of the operating budget
of this self-funded federal agency. Such intentional and purposeful actions by LZ and the

41
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
USPTO can only be done with a discriminatory motive to monopolize opportunities for LZ
because LZ provides a considerable amount of revenue for the USPTO, enough to keep at least
a significant part of the USPTO running.
152. Moreover, as provided by 35 U.S.C. § 32, “[t]he Director [of the USPTO] may, after
notice and opportunity for a hearing ​suspend ​or ​exclude​, either generally or in any particular
case, from further practice before the Patent and Trademark Office, ​any person,​ agent, or
attorney shown to be incompetent or disreputable, or guilty of gross misconduct, or who does
not comply with the regulations established under [35 U.S.C. § 2(b)(2)(D)].” ​Id. (​ emphasis
added).
153. “Person” is defined by the Federal Dictionary Act to include corporations. ​See 1​
U.S.C. § 1 (“[i]n determining the meaning of any Act of Congress, unless the context indicates
otherwise . . . the [word] ‘person’ . . . include[s] corporations, companies, associations, firms,
partnerships, societies, and joint stock companies, as well as individuals.”). No alternate
definitions of “person” are provided in the Patent Act of 35 U.S.C. § 1 ​et seq. Additionally,
nothing in the Patent Act suggests a congressional intent to depart from the Federal Dictionary
Act definition of “person.”
154. Therefore, the USPTO has the authority to suspend or exclude any persons or
corporations (including LZ) “shown to be incompetent or disreputable, or guilty of gross
misconduct,” or who do not comply with the USPTO regulations governing conduct of agents
or other persons (corporations). 35 U.S.C. § 32, and 2(b)(2)(D).
155. Second​, the USPTO’s own actions demonstrate that it does regulate corporations. For
example, on March 26, 2018, the USPTO issued a Show Cause order to a ​corporation rather
than an individual (​Exhibit 100​). Specifically, the USPTO wrote to the USAEU Intellectual
Property Agency Co. Ltd. in China that:
For the reasons set forth below, the United States Patent and Trademark
Office (USPTO) is considering excluding the ​business entity identified
publicly as "USAEU," ​and any of its agents or employees​, from filing
any submissions, engaging in any communications, or participating in
any financial transactions with the USPTO on behalf of others in
connection with any trademark matters before the USPTO.

42
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
(​Id. a​ t 2, lines 3-7 (emphasis added).)
156. In the Show Cause order, USPTO made no effort to separate out any specific
individual. In contrast, it went after the entire “business entity.” (​Id. at 2, line 4). USPTO stated
that “Facts and Circumstances Suggest USAEU is Engaging in Unauthorized Practice.” (​Id at 3,
line 3.) USPTO went on to say that USAEU is not “authorized to practice before the USPTO,
yet is actively engaged in representing others in trademark matters before the USPTO.” (​Id​. at 3,
lines 10-12.)
157. USPTO even defined what it will do to ​exclude USAEU from practicing trademark
law before it by writing,
[i]n view of the foregoing, USAEU is hereby ordered to show cause why the
USPTO should not take the following actions:
(1) Cease acceptance of any filings or related documentation for trademark
applications registrations associated with any individuals, email addresses,
physical addresses, or credit cards linked to USAEU;
(2) Remove all relevant contact information used for correspondence
purposes, including any email addresses linked to USAEU, from the
relevant applications and registrations; and
(3) Prohibit all participation by USAEU and any of its agents or
employees in any trademark applications or registrations, or any related
financial transactions, before the USPTO by any means, including as an
agent, attorney, correspondent, domestic representative, signatory,
intermediary, or other actor.

(​Id.​ at 3-4.)

158. The USPTO’s Show Cause order was signed by Mary Boney Denison, the
Commissioner of Trademarks, who by her profile on the USPTO website makes clear that she
“oversees all aspects of the Trademarks organization, including policy, operations and budget
relating to trademark examination, registration, and maintenance.” ​See
https://www.uspto.gov/about-us/executive-biographies/mary-boney-denison​.
159. For the above reasons, LZ and USPTO actively conspire to restrain trade in favor of
LZ despite congressional authority for USPTO to regulate it.
160. Although according to USPTO regulations, nonlawyers, including LZ “are not
recognized to practice before the [USPTO] in trademark [] matters” (37 C.F.R. § 11.14), the
USPTO has not been following its own rules in actual practice with respect to LZ. LZ practices

43
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
law before the USPTO knowing that the USPTO will permit it to do so. LZ’s non-attorney
practitioners unlawfully modify descriptions of goods and services with respect to trademarks
and assist in the selection of trademark classification. Therefore, LZ is treated by the USPTO as
above the law “practitioners” who can practice law. The actions of LZ and USPTO have in effect
created two classes of USPTO practitioners—practitioners who are lawyers, and ​above the law
practitioners who is LZ, and treats them unequally.
161. This discriminatory treatment among USPTO practitioners based on the classification
of lawyer is intentional and on purpose. It allows LZ to maximize its profits and the amount of
legal work done by non-attorneys so that the revenue for USPTO also grows from the increased
filings by LZ. What the USPTO could have done, is that it could have treated
lawyer-practitioners and LZ equally in two ways: (1) imposing the same regulation for lawyers
on LZ (for example, require LZ to conduct conflict checks or keep IOLTA accounts); or (2) for
the regulations which USPTO does not impose on LZ, not imposing them on lawyers (for
example, do not require lawyers to conduct conflict checks or keep IOLTA accounts). However,
in actual practice, USPTO does not impose the same regulations regulating lawyers onto LZ, at
the same time does not exempt RAPC and other law firms from the regulations which it does not
impose on LZ and thereby LZ and USPTO actively restrain trade at the expense of compliant law
firms. This harms competition by allowing LZ to achieve higher profits than compliant attorney
competitors and makes it harder for new entrants and current competitors that have to operate at
higher, costlier standards.
162. USPTO has a discriminatory motive on the part of its enforcement actions because
LZ alone generates about 5% of USPTO’s annual revenue from trademark service. If the same
regulations are applied to LZ, which they should be, USPTO will end up losing a considerable
amount of revenue and will have to close down offices and lay off staff.
163. This discriminatory treatment is clearly intentional. Despite the fact that LZ has been
constantly and knowingly engaging in unlawful acts and practices before the USPTO, the
USPTO does not impose regulation on LZ by suspending or excluding LZ from practice.
164. The State Bar of California is a quasi-public state agency comprised of active market

44
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
participants--lawyers. It is an “integrated bar,” or an association of attorneys in which
membership and dues are required as a condition of practicing law in the state. It is not like
most state agencies in that its funding comes from its members, only lawyers admitted to
practice in California can be members, and all such lawyers must be members, and a board of
trustees selected from those members is charged with governing it. The State Bar of California
conspires in conjunction with LZ to restrain trade because it permits LZ’s practice out of fear of
antitrust lawsuits by LZ from LZ’s massive amount of financial resources (over $811 million in
venture funding) and LZ’s prior history of suing State Bars such as the North Carolina State
Bar’s ethics committee in their personal capacity to bully itself in getting its way. Moreover, the
State Bar of California has a discriminatory motive because it fears backlash from the widening
gap of access to justice in California.
165. The State Bar of California is a single entity controlled by individual economic actors
who are each independent centers of decision making. That is, all of its actions are undertaken
by an agreement among horizontal competitors who are capable of conspiring rather than as a
single economic entity. The State Bar of California is not believed to have immunity for the
time periods alleged of the anti-competitive conduct between 2015 and 2017. In addition, the
State Bar of California has not waived sovereign immunity after its restructuring in 2018 or
consented to be named as a respondent, and therefore remains an uncharged co-conspirator.
166. LZ has conspired with Beaumont Legal to restrain trade in the years 2015 to 2017 in
the following ways:
a. It has violated rules that prohibit the unauthorized practice of law, that places
special duties on lawyers to supervise non-attorney work, that prohibits the
ownership of law firms by non-lawyers, that impose other requirements and
burdens on lawyers such as conflict checks, IOLTA accounts, etc. that
disadvantage them against LZ.
b. It has violated interpretations of those rules against U.S. lawyers with emerging
business models in a manner that has created uncertainty for RAPC.
167. LZ has conspired with the USPTO to restrain trade in the years 2015 to 2018 in the

45
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
following ways:
a. The USPTO has proposed and enacted rules that prohibit the unauthorized
practice of law, that places special duties on lawyers to supervise non-attorney
work, that prohibits the ownership of law firms by non-lawyers, that impose other
requirements and burdens on lawyers such as conflict checks, IOLTA accounts,
etc. that disadvantage them against LZ.
b. The USPTO has enforced and threatened to enforce its interpretations of those
rules against lawyers with emerging business models in a manner that has created
uncertainty for RAPC. More than that, it has a policy to reciprocally discipline
attorneys disciplined by the State Bar of California regardless of whether the State
Bar of California discipline may have had anticompetitive effects.
c. The USPTO has refused to enforce those restraints equally on LZ who provides
legal services as described in this statement of claim. More specifically, it has not
sought to impose those requirements on LZ or pursue LZ for the unauthorized
practice of law.
d. The USPTO has permitted approximately 70% of all trademarks filed online by
private online trademark filing services to be represented by more than 10
non-attorneys at LZ in the last 3 years alone to fill out more than 20,098
trademark application forms for California residents between 2015 and 2017 on
behalf of customers of LZ after providing legal advice to California, and
knowingly ignoring complaints by California consumers, small businesses, and
licensed California attorneys on investigating LZ’s unfair and unlawful practices
of providing legal advice to California customers.
e. The USPTO has refused the request of RAPC to state whether conduct with
respect to state and federal trademarks and filings constitutes the unauthorized
practice of law, fee sharing, practice of law by USPTO licensed attorneys working
for a foreign law firm in the UK, and ownership of law firms by non-lawyers.
168. LZ conspired with the State Bar of California to restrain trade in the years

46
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 2015 to 2017 in the following ways:
a. The State Bar of California has proposed and enacted rules that prohibit
the unauthorized practice of law, that places special duties on lawyers to
supervise non-attorney work, that prohibits the ownership of law firms by
non-lawyers, that impose other requirements and burdens on lawyers such
as conflict checks, IOLTA accounts, etc. that disadvantage them against
LZ.
b. The State Bar of California has enforced and threatened to enforce its
interpretations of those rules against lawyers with emerging business
models in a manner that has created uncertainty for RAPC. More than that,
it has a policy to reciprocally discipline attorneys disciplined by the
USPTO regardless of whether the USPTO discipline may have had
anticompetitive effects.
c. The State Bar of California has refused to enforce those restraints equally
on LZ who also provides legal services as described in this statement of
claim. More specifically, it has not sought to impose those requirements
on LZ or pursue LZ for the unauthorized practice of law.
d. The State Bar of California has refused the request of RAPC to state
whether conduct with respect to state and federal trademarks and filings
constitutes the unauthorized practice of law, fee sharing, practice of law
by California licensed attorneys working for a foreign law firm in the UK,
and ownership of law firms by non-lawyers.
169. LZ has worked with Beaumont Legal, the USPTO and State Bar of California to
restrain trade in the years 2015 to 2018 in the following ways:
a. It conspired with the USPTO and the State Bar of California by unlawfully
representing approximately 70% of all trademarks filed online by private online
trademark filing services using more than 10 non-attorneys at LZ in the last 3
years alone to fill out more than 76,392 trademark application forms (including

47
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 more than 20,098 trademark application forms for California residents) between
2015 and 2017 after providing legal advice, and knowingly ignoring complaints
by licensed practitioners regarding LZ’s unfair and unlawful practices of
providing legal advice to customers.
b. It has ignored rules to supervise non-attorney work, that prohibits the ownership
of law firms by non-lawyers, that impose other requirements and burdens on
lawyers such as conflict checks, IOLTA accounts, etc. that provide an unfair
advantage for LZ thereby harming legitimate competition from California and
USPTO licensed attorneys and law firms and thereby restraining trade.
c. It has conspired with the State Bar of California and the USPTO to ignore
enforcement of rules toward its business model, its legal plans, and enforcement
of legal document assistant registration to escape scrutiny for the unauthorized
practice of law providing an unfair advantage for LZ thereby harming legitimate
competition from California and USPTO licensed attorneys and law firms; the
effect of which is a restraint on trade.
d. It has conspired with the State Bar of California and the USPTO to escape
scrutiny for the unauthorized practice of law, fee sharing, and ownership of law
firms by non-lawyers through active lobbying efforts that provide an unfair
advantage for LZ thereby harming legitimate competition from California and
USPTO licensed attorneys and law firms and thereby restraining trade.
170. Viewed individually and when properly enforced in a manner that addresses the same
or similar potential consumer harms as to all competitors, many of the restraints have
procompetitive benefits that might, under different circumstances, outweigh their
anticompetitive effects. But that is not what occurred here: the USPTO and the State Bar of
California’s asymmetrical enforcement of these consumer protections actually results in
disadvantaging more qualified, higher quality competitors such as RAPC in favor of less
qualified, lower quality competitors such as LZ. As a result, consumers unknowingly received
faulty and unauthorized legal advice for which they may have little recourse.

48
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 171. Indeed, as a matter of practical economics, the disparately enforced restraints are
destroying competition and leaving consumers far worse off. Even LZ’s CEO, John Suh, has
publicly admitted exactly that: ​“I can destroy innovation and disruption if I take two
elements away #1 capital, and #2 a team.”18 LegalZoom’s CEO John Suh went on to say
seconds later that “the legal industry does not allow law firms to raise capital”, and “it does not
allow them to recruit non-lawyers to the cause”19 and boasting “it will be impossible without
those two elements”20 for lawyers to compete with LegalZoom which uniquely has both these
“elements.”
172. The relevant service market is the market for legal services relating to trademark
protection, which can include assistance with the trademark application process, pre-filing
searches, advice on the characterization of the applicable goods and services, advice on the
description of the mark and other required components of the application, filing of the
trademark application, and advice on the assignment, transfer, and enforcement of trademarks.
Although the scope and quality of services offered varies widely, from a $199 “peace of mind”
service to full-service representation by a law firm, these services are substitutable. (​See
Exhibits 11-12​.) Indeed, LZ’s business model competes with law firm trademark services, and
its advertising reflects that.
173. The relevant geographic market includes California because that is the extent of the
State Bar of California’s jurisdictional reach, and the entire United States of America because
that is the reach of the USPTO. Competing providers must be licensed in the State of California
to provide legal services relating to trademark protection to California residents, and the vast
majority of California residents do not travel out of California to obtain those services.
Competing providers must employ licensed attorneys and be subject to USPTO rules to file
trademarks before it.
174. LZ in conspiracy with the State Bar of California and the USPTO’s conduct has a

18
New Hampshire Bar Association Midyear Meeting held in Manchester, NH, on March 4,
2016, ​https://www.youtube.com/watch?v=ClBpYWcc6jU&t=9m34s
19
​Id.,​ ​https://www.youtube.com/watch?v=ClBpYWcc6jU&t=10m18s
20
​Id.,​ ​https://www.youtube.com/watch?v=ClBpYWcc6jU&t=10m36s
49
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
substantial effect on interstate commerce because it affects competition for services relating to
federal trademark protection administered by the USPTO. Federally protected trademarks are
necessarily used in connection with goods and services in interstate commerce.
175. RAPC and law firm competitors generally have been damaged by LZ in conspiracy
with Beaumont Legal, the State Bar of California and USPTO’s conduct as it has been
prevented from competing on a level playing field against LZ. More specifically, LZ, The State
Bar of California, and the USPTO’s conduct has and continues to prevent RAPC from
competing with LZ on the merits of quality and price because: RAPC is excluded from offering
non-attorney-assisted trademark filing services because it is regulated as a law firm and subject
to the rules governing attorney supervision of non-attorney work; RAPC cannot raise capital in
the same way as LZ; and RAPC is burdened by professional compliance obligations that LZ is
not. It has lost more than $20 million in sales as a result.
176. The State Bar of California is not immune under the Eleventh Amendment because it
is not an “arm of state”:
a. Any money judgment against it would be satisfied by its own funds (which comes
from its members);
b. It may sue or be sued;
c. It may borrow money, contract debts, and own, hold, use, manage, and deal in and
with real and personal property;
d. It may sell, lease, convey, transfer, assign, or dispose of any such property,
including all of its income;
e. It is organized as a public corporation rather than a state agency.
See ​Cal. Bus. & Prof. Code § 6001.
177. The State Bar of California in the years of the alleged harm of between 2015 and
2017 is not exempt from the Sherman Act under the state-action immunity because it cannot
prove that it was, for each instance of the above restraints, (1) acting pursuant to a clearly
articulated state policy to displace competition and (2) actively supervised by the state itself.
a. The California Legislature has declared that “[p]rotection of the public shall be

50
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 the highest priority for the State Bar of California and the board of trustees in
exercising their licensing, regulatory, and disciplinary functions. Whenever the
protection of the public is inconsistent with other interests sought to be promoted,
the protection of the public shall be paramount.” ​Id. at § 6001.1. As explained
supra ​in Paragraph 54, the State Bar of California’s actions and policies have
harmed the public.
b. The State Bar of California is not actively supervised in making
enforcement-related decisions, including who to investigate and initiate
disciplinary proceedings against (or who not investigate and not initiate
disciplinary proceedings against).
c. The California Supreme Court has discretionary review authority in disciplinary
matters which is not always exercised. This is not active supervision for two
reasons: (1) the mere potential for active supervision is insufficient; and (2) the
supervisor must assess the substance of the proposed decision or course of action
to determine whether its anticompetitive effects comports with a specific state
policy to displace competition.
d. The California Supreme Court ultimately approves all rules proposed and enacted
by the State Bar of California. This is not active supervision because the
California Supreme Court’s orders do not specifically reflect an assessment of
whether the anticompetitive effects of the proposed restraints comport with a
specific state policy to displace competition.
e. The State Bar of California knowingly ignored the fact that LZ had not renewed
its registration as an LDA but nonetheless permitted LZ to operate in the State of
California despite receiving numerous complaints from California consumers, law
firms, legal tech companies, and the public while enforcing its LDA rules against
others to restrain trade and create an effective monopoly for LZ in the absence of
competition for its business model with respect to state and federal trademarks
and incorporation.

51
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 f. In 2017, for the first time, the California Supreme Court issued an order
promulgating a “State Bar Antitrust Policy” reflecting its assessment that it has
not provided the active supervision required for the state-action immunity to the
Sherman Act to apply. The policy contains new procedures that make the
potential for active supervision more likely. Since that order was issued, only two
restraints have been reviewed in this matter, each relating to licensing issues not
relevant here. This is ipso facto evidence that the conduct of the State Bar of
California alleged in this complaint was not actively supervised.
178. As a direct and proximate result of these actions, RAPC has suffered and continues to
suffer damages in an amount not yet ascertained. RAPC is entitled to recover damages adequate
to compensate it in an amount to be determined in this arbitration.
THIRD CLAIM FOR RELIEF
MONOPOLY TO RESTRAIN TRADE
SHERMAN ACT, 15 U.S.C. § 2
179. RAPC repeats each and every allegation contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
180. Section 2 of the Sherman Act, 15 U.S.C. § 2 provides:
Every person who shall monopolize, or attempt to monopolize, or combine
or conspire with any other person or persons, to monopolize any part of the
trade or commerce among the several States, or with foreign nations, shall
be deemed guilty of a felony.
181. LZ possess monopoly power in the national market for private online trademark filing
services. In this market, LZ has a market share of about 70% of all trademarks filed online by
private online trademark filing services (“Market”). Approximately 30% of all trademark
applications filed by pro se applicants are filed through LZ. As such, LZ has the power to
exclude competition and has exercised that power in favor of itself.
182. LZ did not achieve its monopoly power through growth or development of a superior
product, service, or business acumen. Rather, LZ achieved its monopoly power through
unlawful, unfair, and anticompetitive conduct that began as a conspiracy between LZ and the
British law firm Beaumont Legal in 2015 (​Exhibit 109​), which was effectuated by an unlawful

52
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
horizontal merger among competitors, and culminated with predatory and exclusionary conduct
by the formation of LZK.
183. Through the conduct described herein, LZ willfully maintained that monopoly power by
anticompetitive and exclusionary conduct. It acted with the intent to maintain this monopoly
power, and the illegal conduct has enabled them to do so in violation of Section 2 of the
Sherman Act.
184. Moreover, LZ, by and through its exclusive control of LZK, holds exclusive rights to
operate and administer a law firm that is able to brazenly violate U.S. and California statutes
and rules described herein.
185. Access to this essential license before the Solicitors Regulation Authority through the
acquisition of Beaumont Legal is indispensable to competition in the small but established
market of private online trademark filing services.
186. Prior to LZ taking control of Beaumont Legal, both Beaumont Legal (when owned and
operated independently) and LZ had each deployed and worked to expand a network of online
access to legal services.
187. Competition among competing online trademark filing services kept consumer costs low
while simultaneously enhancing the consumer’s available choices of legal counsel.
188. Before the anticompetitive conduct, LZ operated a do-it-yourself online trademark filing
service for over thirteen years on a nondiscriminatory basis and enjoyed a cooperative, and
mutually beneficial and profitable relationship with competitors like RAPC.
189. But after the combination, once Beaumont Legal came under the control of LZ, the
rebranded Beaumont Legal as LZK abandoned its policy of nondiscrimination, terminated its
registrations as an LDA, eliminated the essential regulations over online trademark filing
services that had enabled competing service providers to provide competing services, and raised
prices from $159 per trademark application to $199 per trademark application.
190. In doing so, Beaumont Legal became LZK and acted against its own economic interest
in growing its law firm in the U.K. and employing attorneys in the U.K. and instead sought a
course to compete unfairly with U.S. law firms in the effort to monopolize the U.S. legal market

53
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
through eliminating law firm competitors in the United States who could not follow suit.
191. These unlawful actions were essential to LZ’s long-term plan, which was to steal the
existing end-customers in the market, suppress competition, and raise prices to the public after
controlling a captive law firm in the United Kingdom that it could use as a cover to eliminate
competition in the United States market from law firms, including RAPC.
192. Absent these anticompetitive ends, LZ’s unlawful action in giving up its registrations as
an LDA in California would be irrational and make no economic sense. Indeed, before the
anticompetitive conduct, LZ operated primarily as a do-it-yourself website.
193. The market has been harmed as a result of LZ’s conduct as end-customers have been
forced to pay supracompetitive prices while receiving lower quality and fewer services with
more onerous and adhesive contract terms.
194. RAPC provided superior online trademark filing services at lower prices and provided
higher quality and faster service.
195. RAPC has been harmed by LZ’s willful maintenance of its monopoly and its exclusion
of competitors.
196. As a direct and proximate result of these actions, RAPC has suffered and continues to
suffer damages in an amount not yet ascertained. RAPC is entitled to recover damages adequate
to compensate it in an amount to be determined later in the arbitration hearing.
FOURTH CLAIM FOR RELIEF
CALIFORNIA FALSE & MISLEADING ADVERTISING
CAL. BUS. & PROF. CODE § 17500​ ET SEQ.
197. RAPC repeats each and every allegation contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
198. LZ publicly disseminated internet advertisements with the intent to perform services
to consumers in the State of California, as further described in this Claim.
199. LZ’s advertisements were false, misleading, and untrue, as further described in this
Claim.
200. LZ’s advertisements are likely to and actually have deceived consumers. Consumers
have purchased LZ’s services instead of RAPC’s services as a result of their deception.

54
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 201. RAPC has suffered and will continue to suffer loss of revenue, loss of profits, loss of
market share, reduced asset value, diverted sales to LZ, increased advertising costs and loss of
valuable business opportunities, all of which belonged to or vested to RAPC but were taken
away by LZ as a result of its wrongful acts.
202. LZ has been unjustly enriched through its false and misleading advertising.
203. If LZ is not preliminarily or permanently enjoined, it will continue to derive revenue,
profits, market share and sales from RAPC by wrongful acts. Unless restrained by the arbitrator,
LZ will cause additional injury to RAPC for which RAPC has no adequate remedy at law.
204. RAPC seeks an order from the arbitrator under California Business & Professions
Code § 17500 to preliminarily and permanently enjoin LZ from continuing to engage in the
false and misleading advertising set forth herein.
FIFTH CLAIM FOR RELIEF
CALIFORNIA UNFAIR COMPETITION
CAL. BUS. & PROF. CODE § 17200 ​ET SEQ.
205. RAPC repeats each and every allegations contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
206. RAPC has standing to sue in Unfair Competition Law (“UCL”) because it has
suffered injury in fact and lost money, including diverted sales to LZ, lost revenue, loss of
market share, reduced asset value and increased advertising costs.
207. LZ violated the unlawful prong of UCL because of the following reasons:
a. LZ violated Cal Bus. & Prof. Code § 6125 as alleged in Section II ​supra.​
b. LZ violated 18 U.S.C. § 1001 as alleged in Section II ​supra.​
c. LZ violates Cal. Bus. & Prof. Code § 6400, ​et seq​, as alleged in Section III
supra​.
d. LZ violates Cal. Bus. & Prof. Code § 6155 as alleged in Section IV ​supra​.
e. LZ violated Cal Bus. & Prof. Code § 6152 as alleged in Section V ​supra​.
208. LZ violated the unfair prong of UCL because of the following reasons:
a. It is unfair to the competition in the practice of law if LZ is able to offer legal
services by violating state laws, federal regulations and California ethics rules

55
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 without being punished, while the vast majority of attorneys and legal technology
companies, including RAPC, abide by the laws, federal regulations and California
ethics rules.
b. The consumer injury caused by LZ violating the state and federal laws and
regulations is substantial. As these laws and regulations regulate practice of law,
lawyer referral, solicitation, legal document assistant, etc., they are there to ensure
that a lawyer’s independent professional judgment is not interfered with by
nonlawyers, and they are there to protect the interest of the public at large. When
they are violated by LZ, consumers become susceptible to the harm of bad advice
given by non-attorneys or by attorneys unlawfully referred or solicited by LZ. The
contract for legal service between consumers and LZ may be voided by the
operation of law. The public interest is greatly harmed. As alleged ​supra,​ the
consumer harm is substantial.
c. Providing trademark services by unauthorized practice of law, submitting
fraudulent specimens to the USPTO, and violating various laws, regulations and
rules, offer no countervailing benefits to consumers or the competition.
d. Consumers themselves cannot reasonably avoid the injury because reasonable
consumers are not aware of the these laws and regulations and are not aware that
they are being harmed or will be harmed. They not understand what constitutes
the practice of law.
e. It is unfair if LZ is able to offer trademark filing services provided unlawfully in
violation of various state and federal laws and regulations, while RAPC abides by
the laws but customers that would have otherwise chosen RAPC or other licensed
law firms are taken away unfairly by LZ.
f. LZ unfairly pockets $50 of excess government fees as a “processing fee” for
filing U.S. trademark applications, something that RAPC and other law firm’s
cannot do. (​Exhibit 48​).
g. LZ through its co-founders Brian Liu (“Liu”), Eddie Hartman (“Hartman”), and

56
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 Brian Lee (“Lee”) have unfairly competed with RAPC because they are founders
who have created a professional corporation, LZ, which is practicing law for
profit with shareholders who are non-practitioners in violation of CFR § 11.504.
h. Upon information and belief, Lee has also unfairly competed as a California
attorney, suspended since 1999, who formed his corporation LZ with Liu and
Hartman in 2007 (continuing former corporation LZ Delaware, Inc. formed while
Lee was still suspended in 2000) while profiting indirectly as a shareholder from
the over two-hundred fifty thousand trademarks filed with the USPTO through the
LZ website (​Exhibit 95​). Lee has admitted being the “worst lawyer” and “talk to
anyone I did work for” and “you could come to me with a parking ticket, [and]
you would end up in jail” and further admitting “you have to be detail oriented to
be a good lawyer, and I am not that detail oriented.”21
209. LZ prevented competition from RAPC by unfairly gaining potential clients through
illegal solicitation and sharing legal fees with lawyers. But-for LZ’s unlawful and unfair
competition, a good percentage of these potential clients would have otherwise gone to RAPC
and other licensed law firms.
210. LZ’s conduct of unlawful and unfair competition proximately caused RAPC’s injury.
LZ advertises on Google and other online marketplaces where RAPC also advertise. LZ
purchases the same or similar advertising keywords which RAPC also purchase. Thus, LZ
directly competes (unfairly) with RAPC. If LZ did not engage in the alleged unlawful
solicitation and unethical fee sharing, they would not have made false and misleading
advertisements on Google and would not have unfairly competed with RAPC. Therefore, LZ’s
conduct of unfair competition took away potential sales belonging to RAPC and proximately
caused injury to RAPC.
211. As a result of LZ’s wrongful acts, RAPC has suffered and will continue to suffer loss
of revenue, loss of profits, loss of market share, reduced asset value, diverted sales to LZ,
increased advertising costs and loss of valuable business opportunities, all belonging to or

21
PandoDaily, May 11, 2013, ​https://www.youtube.com/watch?v=RE5HxiLpxd0&t=8m00s​.
57
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
vesting to RAPC but taken away by LZ as a result of their wrongful acts.
212. RAPC is informed and believe that LZ, as a competitor to RAPC, performed the acts
alleged herein for the purpose of injuring RAPC and competition generally. The acts alleged
herein continue to this day and present a threat to RAPC, the general public, the trade and
consumers.
213. As the direct and proximate of LZ’s wrongful acts, RAPC has suffered and will
continue to suffer loss of revenue, loss of profits, loss of market share, reduced asset value,
diverted sales to LZ, increased advertising costs and loss of valuable business opportunities.
The losses are all belonged to or vested to RAPC but taken away by LZ as a result of their
wrongful acts.
214. RAPC seeks an order of the arbitrator under Cal Bus. & Prof. Code §17200, ​et. seq.,​
that preliminarily and permanently enjoins LZ from continuing to engage in the unlawful and
unfair acts or practices set forth herein, as well as restitution.
SIXTH CLAIM FOR RELIEF
CONSUMER LEGAL REMEDIES ACT
(Cal. Civ. Code § 1750,​ et seq.​)
215. RAPC repeats each and every allegation contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
216. LZ’s actions as herein alleged constitute unfair and deceptive practices which are
intended to result and/or have resulted in the sale of their services in violation of the Consumers
Legal Remedies Act, Civ. Code § 1750, ​et seq​.
217. LZ misrepresents that its services have characteristics, uses, and benefits that they do
not or that they are not legally entitled to have; misrepresents that its services are of particular,
standard, quality or grade-namely ​“A trademark attorney will navigate the trademark process for
you” and "customized"-when they are not and cannot be by law; advertises its services as "100%
satisfaction guaranteed," when in fact they are not; and represents that purchasing its services
will confer rights or remedies on claimant RAPC on behalf of customer Team Messaging
Solutions Inc., when they do not.
218. LZ’s misrepresentations are intended to result, did and do result in the sale of their

58
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
products and services to Team Messaging Solutions Inc. and other similarly situated small
businesses and individuals.
219. RAPC on behalf of customer Team Messaging Solutions Inc. therefore seeks
damages, declaratory and injunctive relief from the arbitrator in the form of an order directing
Respondent to comply with Cal Bus. & Prof. Code §§ 6401.6, 6408, 6410 and 6411 and
prohibiting LZ from engaging or assisting in the unauthorized practice of law.
220. RAPC is in the process of complying with Cal. Civ. Code § 1782(a). Attached as
Exhibit 91 to this statement of claim is a true and correct copy of the 30-day notice letter RAPC
sent to LZ signed on September 20, 2018 and sent out via certified mail.
221. Wherefore, RAPC pray for judgment against LZ as set forth below.
SEVENTH CLAIM FOR RELIEF
LEGAL DOCUMENT ASSISTANT LAW
(Cal Bus. & Prof. Code § 6400, ​et seq.)​
222. RAPC repeats each and every allegations contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
223. Respondent has committed and continues to violate Cal Bus. & Prof. Code §§ 6400,
6401.6, 6408, 6410, and 6411 as described above.
224. As a result of LZ’s violations of the Legal Document Assistant (LDA) law, claimant
RAPC on behalf of customer Team Messaging Solutions Inc. has suffered actual injury in the
loss of the original payments made to LZ.
225. Wherefore, RAPC pray for judgment against LZ as set forth below.
EIGHTH CLAIM FOR RELIEF
UNJUST ENRICHMENT
226. RAPC repeats each and every allegations contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
227. LZ’s actions have caused claimant RAPC on behalf of customer Team Messaging
Solutions Inc. to pay for services which were not legally provided and which were not as
represented, which payments conferred benefits upon LZ.
228. LZ was fully aware of the benefits being conferred by claimant RAPC on behalf of
customer Team Messaging Solutions Inc., and received those benefits.

59
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 229. The circumstances surrounding the acceptance and retention of the benefits by LZ are
inequitable, such that claimant RAPC on behalf of customer Team Messaging Solutions Inc. is
entitled to a recovery pursuant to the doctrine of unjust enrichment.
230. Wherefore, RAPC pray for judgment against LZ as set forth below.
NINTH CLAIM FOR RELIEF
DECLARATORY RELIEF
231. RAPC repeats each and every allegations contained in the paragraphs above and
incorporate by reference each preceding paragraph as though fully set forth herein.
232. LZ has committed and continues to violate Cal. Bus. & Prof. Code §§ 6400, 6401.6,
6408, 6410, and 6411 as described above, and has committed and continues to commit the
unauthorized practice of law.
233. LZ also has and continues to maintain false and misleading statements on its website,
which induce members of the public acting in reliance on such statements to purchase its
services.
234. RAPC on behalf of customer Team Messaging Solutions Inc. hereby declares the
PIGGIEBANK trademark contract with LZ void under Business & Professions Code §6410(d),
and demands a full refund of all fees paid to LZ.
235. RAPC on behalf of customer Team Messaging Solutions Inc. is also entitled to a
declaration of this Arbitration that the contract is voidable, entitling it to full refunds of all sums
paid to LZ. RAPC on behalf of customer Team Messaging Solutions Inc. also seeks an Order
declaring that its contracts with LZ are void for LZ’s failure to comply with Business &
Professions Code §§ 6408 and 6410.
236. RAPC on behalf of customer Team Messaging Solutions Inc. requests an Order
declaring that the actions of LZ violate the above statutory sections as to the actions which may
be taken or not taken by a legal document assistant, and that LZ’s actions also constitute the
unauthorized practice of law.
237. The above-mentioned wrongful conduct is ongoing and continuous, and has caused
and will continue to cause irreparable harm, and is in direct violation of public policy of the State
of California and each of the other States. Declaratory and injunctive relief is therefore

60
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
appropriate and necessary.
238. RAPC on behalf of customer Team Messaging Solutions Inc. requests an injunction
against the continuation of the above actions, and seeks its attorneys’ fees and costs pursuant to
Cal.Code of Civil Procedure §1021.5 and B & P Code §6412.
REQUEST FOR RELIEF
WHEREFORE, Claimant requests that:
239. RAPC seeks a declaration that LZ’s trademark filing services, specifically the
conduct alleged in section “​The Unlawful Practices of LZ​” ​supra​, violate Cal Bus. & Prof.
Codes as alleged herein including § 6125 and § 6152(a).
240. Enter judgment against LZ;
241. Award RAPC all available damages in an amount believed to be exceeding
$20,000,000.
242. Declare this case as an exceptional case under 15 U.S.C. § 1117(a);
243. Award RAPC’ their costs and expenses of this action against LZ, including any and
all arbitration fees and costs before the American Arbitration Association, reasonable attorneys’
fees necessarily incurred in bringing and pressing this case, as provided in 15 U.S.C. § 1117(a);
244. Award RAPC’ compensatory and punitive damages if available;
245. Award RAPC pre- and post-judgment interest at the applicable rates on all amounts
awarded;
246. Grant permanent injunctive relief to prevent the recurrence of the violations for which
redress is sought in this Statement of Claim;
247. In particular:
248. Under the Sherman Act, 15 U.S.C. §§ 1, 2:
a. For compensatory damages in three times the amount sustained by RAPC as
provided in 15 U.S.C. §§ 15(a) and 26;
b. For attorney fees and costs necessarily incurred in bringing and pressing this case,
as provided in 15 U.S.C. §§ 15(a) and 26;
c. Grant permanent injunctive relief under 15 U.S.C. § 26 to prevent the recurrence

61
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 of the violations for which redress is sought in this Statement of Claim.
249. Under Business and Professions Code §17200 et seq.:
a. For restitution.
b. For injunctive relief.
c. For attorneys’' fees and costs pursuant to Civil Code §1021.5.
d. For any other relief the Arbitrator may deem proper.
e. Order any other such relief as the arbitrator deems appropriate.
250. Under the CLRA, Civil Code section 1750 et seq.:
a. For injunctive relief.
b. For punitive damages.
c. For restitution of property.
d. For statutory damages under Civ. Code § 1780(a).
e. For statutory damages under Civ. Code § 1780(c).
f. For treble penalties under Civ. Code Section §3345.
g. For attorneys' fees and costs.
251. Under Business and Professions Code § 6412.1:
a. For restitution;
b. For injunctive relief;
c. For damages;
d. For attorneys' fees and costs.
e. For any other relief that the Arbitrator may deem proper.
252. Under the Cause of Action for Unjust Enrichment:
a. For restitution of property;
b. For injunctive relief;
c. For attorneys' fees and costs.
d. For any other relief that the Arbitrator may deem proper.
253. Under the Cause of Action for Declaratory Relief:
a. For an Order declaring that the Respondent’s actions violate Cal. B&P Code §§

62
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT
 6401.6, 6408, 6410, and 6411 as described above, and constitute the the
unauthorized practice of law.
b. For restitution of property.
c. For injunctive relief.
d. For attorneys' fees and costs.
254. Declare that LZ is engaged in the unauthorized practice of law while providing
trademark related services to its customers; and
255. Award RAPC its costs and expenses of this action against LZ, including RAPC’s
reasonable attorney fees necessarily incurred in bringing and pressing this case, as provided in
15 U.S.C. § 1117(a).

Respectfully submitted this Friday, September 21, 2018.

LEGALFORCE RAPC WORLDWIDE P.C.

By__​/s/ Raj V. Abhyanker​______

Raj V. Abhyanker
California State Bar No. 233284
Attorney for Claimant:
LegalForce RAPC Worldwide, P.C.

63
STATEMENT OF CLAIM
CASE NO.: 01-18-0001-5162-GT