What Do You Meme sues Zenliv (Taipan Tech) over Emotional Comfort and Support plush listings on Amazon

What was filed

The complaint is Document 1 in No. 1:26-cv-09115, U.S. District Court for the Southern District of New York, filed October 16, 2026. It runs 18 pages. The plaintiff, What Do You Meme, LLC, doing business as Relatable, is located in New York, New York. The defendant, Zenliv Limited, doing business as Taipan Tech, is alleged on information and belief to be a Hong Kong corporation. Counsel is Gottlieb, Rackman & Reisman, P.C. Jurisdiction is pleaded under 28 U.S.C. 1331, 1338, and 1367(a) and 15 U.S.C. 1121(a), and venue under 28 U.S.C. 1391(b). The plaintiff demands a jury.

The works and the marks

The complaint alleges ownership of copyright Registration Nos. VA 2-420-336, VA 2-442-297, VAu 1-554-750, and VAu 1-592-165, with effective dates of August 30, 2024, January 3, 2025, February 12, 2025, and April 16, 2026, for images of its Emotional Support products. It alleges ownership of trademark Registration Nos. 7,566,639 (EMOTIONAL SUPPORT PALS), 6,902,855 (EMOTIONAL SUPPORT FRIES), and 7,497,419 (EMOTIONAL SUPPORT) for stuffed and plush toys, plus common law rights in a line that includes EMOTIONAL SUPPORT DUMPLINGS, DUCKIES, PICKLES, HIGHLAND COWS, and CAPYBARAS.

What the complaint alleges

It alleges Zenliv displays images that are substantially similar to or derived from the registered images under twelve Amazon ASINs listed in paragraph 21, and sets examples side by side. It alleges, on information and belief, that Zenliv makes the images available through its Amazon seller page and intentionally copied the registered images to create them. It alleges Zenliv sells plush toys identical in style and appearance to the plaintiff's under the names EMOTIONAL COMFORT & SUPPORT DUMPLINGS, DUCK, PICKLES, HIGHLAND COW, and CAPYBARA, without authorization, and that the infringement is willful.

Counts and relief

The five counts are copyright infringement under 17 U.S.C. 501, trademark infringement under 15 U.S.C. 1114 and 1117, New York common law trademark infringement, false designation of origin and false advertising under 15 U.S.C. 1125, and unfair competition under 15 U.S.C. 1125(a). The prayer seeks permanent injunctions, Zenliv's profits and damages or, at the plaintiff's election, statutory damages under 17 U.S.C. 504(c), compensatory, consequential, and punitive damages, fees under 17 U.S.C. 505 and 15 U.S.C. 1117, trebling and statutory damages under 15 U.S.C. 1117, destruction under 15 U.S.C. 1118, a recall, and deletion of thirteen listed ASINs.

What to watch next

Watch for service on Zenliv, including any motion for alternative service, and for any motion for preliminary relief against the Amazon listings.