What was filed
The complaint is Document 1 in No. 1:26-cv-06695, U.S. District Court for the Eastern District of New York, filed and dated October 18, 2026 (11 pages). The plaintiff is Cuong Nguyen, also known as Cuong Tien Nguyen, who the complaint says lives in Hanoi, Vietnam, writes under the pseudonym "Leo Corners," and designs, authors, and sells felt children's activity books through online marketplaces, including Etsy. The defendant is Joan Okwose, d/b/a jojoxgifts, an individual the complaint says operates the Etsy storefront "jojoxgifts" from Walsall, United Kingdom. Counsel for Nguyen is David Bosland of Bosland Law, PLLC, Seattle, Washington, who filed a motion to appear pro hac vice the same day. The complaint does not include a jury demand. Its three exhibits (the registration certificates and deposit photographs, the Etsy listing, and Etsy's notice forwarding the counter-notification) are not publicly available. (Compl. paras. 1 to 5, 11, 14, 18; p. 11; Dkt. 2.)
The works and the alleged copies
The complaint identifies four felt books, each marketed as a "busy book" and a "quiet book": Bear Adventure (Reg. No. VA0002469110), Wild Lion (VA0002469107), and Fairy Theme Garden (VA0002469105), each effective December 1, 2025, and Berry Tale (VA0002468423), effective July 27, 2025. It says each was first published in the United States on June 22, 2025 and is registered as a pseudonymous work under the name "Leo Corners." The Copyright Office's public records list the same numbers, effective dates, and titles, with Cuong Tien Nguyen as claimant on the first three and "Leo Corners" on Berry Tale. The complaint says Nguyen sells the books with a customer's chosen name stitched on the cover. (Compl. paras. 1, 10 to 12.)
The complaint alleges that the defendant's felt books copy the covers, characters, page designs, and arrangement of the four works, differing only in the personalized name, the color of some elements, or the advertising photographs. It points to an Etsy listing offering books in styles titled "Bear Adventure," "Lion Friends," "Mushroom House," and "Strawberry Season," with interior pages it says reproduce his cake, rainbow, airplane, acorn, unicorn, and owl pages. It alleges the listing quoted shipping from the United Kingdom to Washington State, and that on October 16, 2026 it was marked "Bestseller" with the statement "29 people bought this in the last 24 hours." It alleges, on information and belief, that the defendant began offering the copies after the registrations took effect; it says the storefront has been on Etsy since about March 2026. (Compl. paras. 13 to 16.)
The takedown, the counter-notification, and the 512(f) claim
According to the complaint, Nguyen's counsel sent Etsy a notice under 17 U.S.C. 512(c)(3) on September 10, 2026 identifying seven listings, and Etsy disabled access to them. The defendant then submitted a counter-notification for all seven, swearing "under penalty of perjury" to "a good faith belief that the material was removed or disabled by mistake or because of misidentification of the material." Etsy forwarded it and advised that, absent notice of a court action, the listings could be reactivated on September 25, 2026, and the complaint says Etsy permitted the listings to be reinstated. It alleges the statement was false and that the defendant knew it was false, because the listings showed page-for-page copies and the counter-notification identified no mistake. After further written demands from counsel in October, it says, six of the seven listings came down, but the "Bestseller" listing remained active as of October 16, 2026. (Compl. paras. 2, 17 to 22.)
Personal jurisdiction by counter-notice consent
The complaint quotes the counter-notification's consent "to the jurisdiction of Federal Court for the judicial district in which I am located, or if my address is outside of the United States, for any judicial district in which Etsy is located," and alleges that Etsy's principal place of business and designated agent are in Brooklyn, in the Eastern District of New York. It cites Nguyen v. Hu, No. 3:25-cv-10356-JSC (N.D. Cal.), an earlier case in which Nguyen, asserting the same four registrations, sued a different Etsy seller; David Bosland, his counsel here, appeared for him there in January 2026 and signed his response on personal jurisdiction. In that case, Judge Jacqueline Scott Corley's August 10, 2026 order held that the seller, by his DMCA counter-notification to Etsy, "consented to jurisdiction in the Eastern District of New York, which encompasses Brooklyn," and dismissed for lack of personal jurisdiction in California after concluding that this consent defeated the plaintiff's reliance on Federal Rule of Civil Procedure 4(k)(2). A September 9, 2026 order amended the judgment to transfer that case to the Eastern District of New York instead. The new complaint pleads Rule 4(k)(2) only in the alternative, and pleads venue under 28 U.S.C. 1391(c)(3) and 1400(a) and by consent. (Compl. paras. 7 to 9; Nguyen v. Hu, Dkt. 11 paras. 10, 18; Dkt. 14; Dkt. 40; Dkt. 42 at 3 to 4; Dkt. 44.)
Counts and relief
Count I alleges copyright infringement under 17 U.S.C. 106 and 501 and pleads willfulness, pointing to continued sales after the takedown notice, the counter-notification, and counsel's demands. Count II alleges a knowing material misrepresentation in the counter-notification under 17 U.S.C. 512(f), with Etsy's reinstatement of the listings as the reliance. The prayer seeks a permanent injunction; relief under 17 U.S.C. 512(j) as to specifically identified listings, on notice to the service provider as 512(j)(3) requires; impoundment and destruction under 17 U.S.C. 503; statutory damages, including enhanced damages for willfulness (which the complaint puts at up to $150,000 per work), or actual damages and profits; damages, costs, and fees under 512(f); an accounting; fees under 17 U.S.C. 505; and interest. (Compl. paras. 23, 26 to 34; pp. 9 to 11.)
On October 19, 2026, the clerk noted that the case could not be assigned to a judge without a completed civil cover sheet. The public docket, as last updated on October 20, 2026, shows no assigned judge.