Ezzo v. Google [1]

Jamil E. Ezzo, who holds a Supplemental Register trademark in the phrase "Locate Plastic Surgeon," sued Google, AOL.com, various plastic-surgery websites, and other defendants over their alleged use of the phrase.  Ezzo's Supplemental Register [2] trademark is a federally-registered trademark that does not carry all of the legal protections enjoyed by full-fledged trademarks in the Principal Register [3].

Ezzo's pro se Complaint [4] accuses the defendants of profiting through the improper use of his trademark.  Though the specifics of the defendants' alleged actions are not clear, it appears [5]that Ezzo takes issue with the websites' use of the phrase in keyword advertising [6].  Ezzo's primary legal claim is fraud; he does not bring direct claims of trademark infringement.  The fraud appears to arise from occasions when the defendants' allegedly "fraudulently induced plaintiff to enter into the written and oral agreements," though the complaint does not describe the substance of these agreements.