What was filed

The complaint is Document 1 in No. 2:26-cv-02837, U.S. District Court for the Middle District of Florida, Fort Myers Division, filed October 19, 2026 (52 pages). The plaintiff, Bucks Holsters LLC, is a Florida limited liability company in Cape Coral, Florida, that the complaint says designs, manufactures, and sells Kydex and hybrid holsters and has operated under the BUCKS HOLSTERS name since at least 2016. The defendants are T5 Investments LLC, a Virginia limited liability company in King William, Virginia, that does business as Tyson Holsters; Trevin Tyson, an individual the complaint places in King William County, Virginia, and says owns and operates the Tyson Holsters business, sued in his individual capacity; and DeMarkus Drumwright, an individual the complaint places in Forney, Texas, and alleges, on information and belief, was and is an agent, representative, or apparent agent of T5 and Tyson Holsters who represented it at trade shows. The complaint calls T5 and Tyson the "Tyson Defendants." Counsel for the plaintiff is Bryan L. Loeffler of Loeffler IP Group, P.A., Naples, Florida. The plaintiff demands a jury trial. Jurisdiction is pleaded under 28 U.S.C. 1331, 1338, and 1367, and venue under 28 U.S.C. 1391(b)(2) and 1400(a). The exhibits, A through J-3, include side-by-side comparisons and what the complaint describes as the Copyright Office's unofficial certificate previews for the three registrations; they are listed on the docket but are not publicly available. (Compl. paras. 6, 8 to 10, 13 to 20, 95; p. 52.)

The three registered eBay works

The complaint says the action "principally concerns" the Tyson Defendants' alleged copying of three eBay literary works: product advertising text for a CANIK holster, product advertising text for a SIG SAUER P365X MACRO AXG LEGION holster, and an earlier eBay About summary. It identifies them as BUCK HOLSTERS-CANIK PRIME EBAY AD COPY (Reg. No. TXu 2-569-556), BUCKS HOLSTER EBAY AD COPY SIG SAUER (TXu 2-569-554), and BUCKS HOLSTERS EBAY STORE BACKGROUND (TXu 2-569-552), each with an effective date of registration of October 10, 2026 and a registration decision date of October 14, 2026. It says each registration identifies Bucks Holsters, LLC as author and claimant, identifies the authorship as text, and identifies the work as made for hire. (Compl. paras. 1, 94 to 95.)

The complaint alleges that the Tyson Defendants' competing eBay listings and seller profile follow the same expressive order and phrasing, with the company name, location, and some product details substituted. For the listing text, it quotes its own sentence, "Using only top-tier materials and refined manufacturing techniques, we produce what we believe to be the most reliable and comfortable concealment holsters available today," and alleges the competing listing repeats phrases including "the most reliable and comfortable concealment holsters available today" and "meticulously hand-molded using the actual firearm model to ensure a precise, secure fit," then runs through the same ordered product details. For the About summary, it alleges the competing profile describes a Virginia-based premium holster company established in 2021 in the same sequence. The complaint says it claims the original prose and its protectable selection and arrangement, not facts, product specifications, functional features, stock platform language, or short phrases standing alone. It alleges, on information and belief, that Trevin Tyson personally selected, directed, approved, published, or caused publication of the accused text. It pleads willfulness "subject to the evidence of knowledge and chronology." (Compl. paras. 29 to 35, 93, 96 to 99.)

The complaint also points to website policy text, an Indeed job posting, identical prices for several product options, and social-media material as supporting examples, and says these are not additional works asserted in the copyright count. Separately, it alleges that in January 2026 Bucks Holsters began closing its eBay listings with the slogan "Because at Buck's Holsters, we don't just build holsters... we build confidence," and that within days the competing listings closed with "because at Tyson Holsters®, we don't just build holsters, we build quality." It claims common law rights in the slogan as a source identifier, not a pending registration. (Compl. paras. 36 to 52, 93.)

The 512(f) takedown claim

The complaint alleges, on information and belief, that the Tyson Defendants submitted notices or reports to X and other social-media platforms targeting Bucks Holsters content, causing or threatening removal, restriction, reduced distribution, or disruption of its content and accounts. Count X alleges that they submitted one or more notifications under 17 U.S.C. 512(c)(3) asserting that Bucks Holsters material was infringing; that the assertions were materially false because Bucks Holsters owned or was authorized to use the material and the Tyson Defendants had copied its earlier material; that they made the assertions knowingly and without a good-faith basis; and that the service provider relied on them in removing or disabling access. It seeks damages, costs, and fees under 512(f). It also relies on the platform reports for its Florida unfair trade practices and unfair competition claims. (Compl. paras. 84 to 85, 159 to 165.)

The other claims

Count II alleges trade dress infringement under 15 U.S.C. 1125(a)(1)(A) in overall nonfunctional combinations, including a trade-show booth presentation (branded skirted tables, a rear logo backdrop, coordinated signs, tall 3D fan display devices, and branded nylon merchandise bags), a holster presentation using colored brads and decorative washers, and an online purchasing presentation. It alleges that a materially similar Tyson Holsters booth appeared at an event in Iowa about six months after Bucks Holsters first used its display at a show in Harrisburg, Pennsylvania. Count III alleges false designation of origin and false association under the same section. Counts IV and V allege Florida common law unfair competition and violation of the Florida Deceptive and Unfair Trade Practices Act, Fla. Stat. 501.201 to 501.213. Counts XI and XII allege unregistered trademark infringement of the slogan under 15 U.S.C. 1125(a)(1)(A) and Florida common law trademark infringement. (Compl. paras. 22 to 25, 53 to 58, 101 to 126, 166 to 179.)

Counts VI and VII allege trade secret misappropriation under the Defend Trade Secrets Act, 18 U.S.C. 1836, and the Florida Uniform Trade Secrets Act. The complaint describes the information as nonpublic information concerning product development, manufacturing processes, supplier terms, dealer and customer contacts, pricing strategy, unreleased marketing plans, influencer negotiations, and show strategy. It alleges that Trevin Tyson approached Bucks Holsters employees at trade shows when management was away from the booth, asked about their compensation and the business, and tried to recruit them, and it alleges, on information and belief, that the Tyson Defendants acquired, used, disclosed, or threatened to use the information through improper employee solicitation or through persons owing duties to Bucks Holsters. Count VIII alleges tortious interference with relationships with influencers, including at least one it says was diverted, employees and show staff, and dealer accounts. (Compl. paras. 59 to 65, 79 to 83, 127 to 149.)

Count IX, against Drumwright and T5 only, alleges defamation and defamation per se under Florida law. It alleges that Drumwright published false statements of fact about Bucks Holsters to third persons, and alleges, on information and belief, that he did so as T5's agent within the scope of that relationship, so that T5 is vicariously liable. The complaint also describes conduct at trade shows that it characterizes as intimidation directed at Bucks Holsters' owner, employees, and agents, including a September 27, 2026 encounter at a gun show in Fort Worth, Texas between Drumwright and a Bucks Holsters representative. It says it claims only its own business injury, not individual damages of the people involved. (Compl. paras. 4, 66 to 78, 90, 150 to 158.)

Defendants by count, and relief

Every count except Count IX is pleaded against T5 and Trevin Tyson; Count IX is pleaded against Drumwright and T5. On the copyright count, the complaint seeks an injunction under 17 U.S.C. 502, impoundment under 503, actual damages and profits under 504(b), and statutory damages under 504(c) and fees under 505 "only to the extent available under § 412." The prayer asks for declarations that the Tyson Defendants infringed its copyrights, violated 15 U.S.C. 1125(a), Florida common law, and FDUTPA, misappropriated trade secrets, and submitted actionable takedown misrepresentations, and that Drumwright and T5 are liable for defamation; preliminary and permanent injunctions against reproducing and publicly displaying the protectable expression of the three eBay works, and injunctions against the confusingly similar trade dress combinations proven at trial and confusing use of the slogan; injunctions against trade secret misuse and interference with its identified business relationships, with any injunction concerning intimidation to identify the specific unlawful threats or conduct proven, the responsible defendants, and the protected business interests, and not to restrain lawful speech, good-faith legal proceedings, or ordinary competition; removal or revision of the accused eBay listing and About text, correction of actionable platform notices, and preservation of evidence; impoundment; actual damages, profits, statutory damages where legally available, and any enhancement authorized by law, with no statutory counterfeiting damages for the slogan; damages for defamation, trade secret misappropriation, tortious interference, and takedown misrepresentations, including presumed or general damages for any defamation per se and exemplary or punitive damages if permitted; interest; and fees and costs under 17 U.S.C. 505 and 512(f), 15 U.S.C. 1117, 18 U.S.C. 1836(b)(3)(D), and Fla. Stat. 501.2105 and 688.005. (Compl. paras. 100, 165; pp. 49 to 51.)

The docket shows summonses issued and a copyright report entered on October 20, 2026, and a civil action order entered on October 21, 2026.