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 Plaintiff,

LegalForce RAPC Worldwide, P.C.

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

LegalForce RAPC WORLDWIDE, P.C. COMPLAINT FOR:

Plaintiff, 1. DECLARATORY JUDGMENT;

2. CALIFORNIA UNFAIR
vs. COMPETITION;
3. PROFESSIONAL NEGLIGENCE;
MYCORPORATION BUSINESS 4. NEGLIGENCE PER SE; and
SERVICES, INC., a corporation; 5. BREACH OF FIDUCIARY DUTIES.
DEBORAH S. SWEENEY, individually
and as owner of MYCORPORATION
BUSINESS SERVICES, INC.; and
DOES 1 through 50 inclusive,
JURY TRIAL DEMANDED
Defendants.

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ORIGINAL COMPLAINT
 1. Plaintiff LegalForce RAPC Worldwide, P.C. (“RAPC”) is a law corporation
organized and existing under the laws of California, and is and was at all times
mentioned herein qualified to do business in California. Defendant MyCorporation
Business Services, Inc. is hereinafter referred to as “MyCorporation”. Defendant
Deborah S. Sweeney is hereinafter referred to as “Sweeney”.
2. RAPC alleges as follows upon actual knowledge with respect to itself and its
own acts, and upon information and belief as to all other matters.
NATURE OF ACTION
3. MyCorporation forges the signatures of its customers filing U.S. trademarks
before the United States Patent & Trademark Office (“USPTO”) for the specific purpose
of deceiving the federal government and third parties. Its founder and California
attorney Sweeney knows her company cannot legally do this. However, Sweeney
brazenly ignores the law and fails to supervise her staff at MyCorporation.
4. Through its act of unlawfully signing applicants’ names on USPTO trademark
applications, MyCorporation and Sweeney harm the “public interest” in that consumers
become susceptible to the risk that their trademarks may be found invalid or
unenforceable by the USPTO or by courts in the future.
5. MyCorporation’s non-attorney trademark filing services regularly require its
non-attorney staff to forge signatures of its customers on trademark declarations when
filing trademarks. By forging signatures of its customers, MyCorporation has made it
difficult for the USPTO to examine which trademarks are filed by MyCorporation, and
therefore unable to challenge their illegal business model and practices.
6. RAPC, on the other hand, provides its legal services through a U.S. law firm that
performs conflict checks, maintains IOLTA accounts, and involves licensed U.S.
trademark attorneys who provide legal advice and supervision throughout the process.
It is able to offer quality representation at much lower prices than traditional trademark
law firms because of its innovation, technology and volume. For example, it uses
technology to automate its work flow and separate the tasks that require U.S.

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trademark attorney involvement from everything else.
7. USPTO rules require that a trademark application can only be signed by either
the applicant’s represented attorney, the corporate officer, or person with first hand
knowledge of the facts and actual authority to act under 37 CFR 2.193(e). However,
MyCorporation and Sweeney chose to disregard the federal rules. By deceiving the
USPTO into believing that their customers, rather than themselves, are the actual
signatories on USPTO trademark forms, MyCorporation and Sweeney gain three
significant competitive advantages over RAPC: (1) they greatly reduce the support
costs in the trademark filing process because customers have less questions about
what statements they are asked to make under oath in their declaration signify; (2) they
evade scrutiny from the USPTO regarding their practices because the USPTO cannot
see MyCorporation’s name on any of the filings; and (3) they create a false impression
to customers that MyCorporation is able to do things that otherwise only attorneys
could. Therefore, MyCorporation has gained substantial cost advantages over RAPC.
RAPC contends that MyCorporation’s entire trademark business is built upon forging
customers’ signatures on their trademark applications.
THE PARTIES
The Plaintiff
8. RAPC is a law firm wholly owned by Raj Abhyanker, a member in good standing
of the State Bar of California, and the United States Patent Bar. The firm practices
patent and trademark law before the USPTO 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 Avenue, Tempe, AZ 85282.
The Defendants
9. MyCorporation Business Services, Inc. is an Arizona corporation with a principal
place of business at 26025 Mureau Road, Suite 120, Calabasas, CA 91302. Upon
information and belief, MyCorporation is not a law firm in the United States and is not
authorized to practice law in any state. MyCorporation is not a registered or bonded

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legal document assistant under California Business and Professions Code, sections §
6400 et seq.
10. Defendant Deborah Sweeney is an owner and Chief Executive Officer of
MyCorporation, and a licensed California attorney, having a principal place of business
at 26025 Mureau Road, Suite 120, Calabasas, CA 91302.
11. DOES 1 through 50 inclusive, are individuals or entities whose true names,
capacities, nature, or the extent of participation in the alleged activities are unknown to
Plaintiff and therefore Plaintiff sues these defendants by such fictitious names. Plaintiff
will amend the complaint to allege their true names and capacities when ascertained.
JURISDICTION AND VENUE
12. This Court has general personal jurisdiction over MyCorporation because
MyCorporation’s principal place of business is in California. Alternatively, this Court has
specific personal jurisdiction over MyCorporation because MyCorporation purposefully
directed its advertisements or promotions at consumers in this county and caused
harm to Plaintiff in this county. MyCorporation thus has minimum contacts with the
State of California and those contacts are related to this lawsuit. This Court has
general personal jurisdiction over Sweeney because Sweeney resides in California.
13. Venue is proper in the County of Los Angeles because a substantial part of the
events or omissions giving rise to this action occurred in this county. In addition, all
defendants reside in this county.
SUBSTANTIVE ALLEGATIONS
I. ​MyCorporation’s unlawful business practice of forging applicants’ signatures
on trademark applications​.
14. Troubling facts were revealed from a recent trademark application filed through
MyCorporation. The facts are illustrated below.
15. On December 31, 2017, RAPC requested the filing of a trademark application
through MyCorporation.com website. Email address of Raj Abhyanker, the sole
shareholder of RAPC, was used as the applicant’s contact email address.

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ORIGINAL COMPLAINT
 16. This trademark application was for a federal intent-to-use trademark registration
related to a real business of RAPC—“PacerAlert”, which is the trade name of a new
public docket alert system for federal litigation that RAPC intends to use in commerce.
Raj Abhyanker paid $149 through the MyCorporation website.
17. During the workflow, MyCorporation asked Raj Abhyanker to sign, and Raj
Abhyanker did sign, the following statement (“Client Consent”) on MyCorporation’s
website:
/RAJ ABHYANKER/
I acknowledge that I have read and agree to be bound by the
MyCorporation® Terms of Use Agreement. I specifically acknowledge
that neither MyCorporation®, nor any of its employees or agents have
provided me with any legal services or legal advice. ​I also authorize
MyCorporation® to affix my electronic signature to documents,
where applicable. Further, if ordered, I authorize MyCorporation® to
automatically bill my credit card each year for Registered Agent
Service, MyIncGuard®, Annual Report Service or MaintainMyBiz®
unless written notification of cancellation and proof of resignation is
provided in the time frame stated by MyCorporation®. I acknowledge
that once documents are successfully submitted to the state, if
applicable, I am not entitled to a refund of any state/government filing
fees, MyCorporation® service fees, or shipping & handling fees.
Exhibit A at 2 (emphasis added).
18. On January 3, 2018, Raj Abhyanker’s signature was electronically entered as
“/raj abhyanker/” by MyCorporation on USPTO’s Trademark Electronic Application
System (“TEAS”), thereby identified by MyCorporation as the signatory of the
“Declaration” to the USPTO. ​See ​Exhibit B at 6.
19. The “Declaration” to USPTO states, ​inter alia,​ the following:
a. “The signatory believes that the applicant is entitled to use the mark in
commerce;”
b. “The applicant has a bona fide intention to use the mark in commerce on
or in connection with the goods/services in the application;”
c. “To the best of the signatory's knowledge and belief, the facts recited in
the application are accurate.”

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ORIGINAL COMPLAINT
 d. “To the best of the signatory's knowledge and belief, no other persons,
except, if applicable, concurrent users, have the right to use the mark in
commerce, either in the identical form or in such near resemblance as to
be likely, when used on or in connection with the goods/services of such
other persons, to cause confusion or mistake, or to deceive.”
e. “To the best of the signatory's knowledge, information, and belief, formed
after an inquiry reasonable under the circumstances, the allegations and
other factual contentions made above have evidentiary support.”
f. “The signatory being warned that ​willful false statements and the like
are punishable by fine or imprisonment, or both, under 18 U.S.C. §
1001​, and that such willful false statements and the like may jeopardize
the validity of the application or submission or any registration resulting
therefrom, ​declares that all statements made of his/her own
knowledge are true ​and all statements made on information and belief
are believed to be true.”
20. MyCorporation’s staff entered Raj Abhyanker’s name and signature, and
electronically signed as follows:
Declaration Signature
Signature: /raj abhyanker/ Date: 01/03/2018
Signatory's Name: Raj Abhyanker
Signatory's Position: Owner
21. Then, MyCorporation officially submitted the “Declaration” to the USPTO. This
signing and submitting process was completed by MyCorporation alone. Raj
Abhyanker was not involved in the process and had no knowledge of the process.
22. Upon information and belief, MyCorporation has been forging applicants’
signatures on thousands of trademark applications per year, for a period of more than
ten years.
II. ​MyCorporation waived various clients’ rights by forging clients’ signatures
23. Furthermore, by forging clients’ signature on their “Declaration” to the USPTO,

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MyCorporation signs away many of clients’ rights before the federal government.
24. The Client Consent statement (Ex. A) signed by a client of MyCorporation does
not provide any permission by the client allowing MyCorporation to waive client’s right
to privacy before the USPTO. Therefore, MyCorporation signs away clients’ right to
privacy when signing their names on “Declaration” to the USPTO.
25. In addition, MyCorporation unilaterally waive client’s right to privacy when its
non-attorney staff, on behalf of client but without client’s knowledge, pay government
fees on USPTO’s fee payment form by agreeing to the following: (1) waiving clients’
right to cancel the filing or refund the government fee; (2) waiving clients’ right to
privacy by allowing their name, phone number, email and street addresses to be
published publicly; and (3) representing to the federal government that clients have the
authority to grant, and are granting, the USPTO permission to make the information
available on its online database and in public trademark application and registration
records.
26. MyCorporation’s practice violates clients’ state constitutional right to privacy
(Cal. Const., art. I, § 1), which states that “[a]ll people are by nature free and
independent and have inalienable rights. Among these are enjoying and defending life
and liberty, acquiring, possessing, and protecting property, and pursuing and obtaining
safety, happiness, and ​privacy​.” Id. (emphasis added).
27. In addition, MyCorporation signs away clients’ copyright publication rights to the
USPTO. Specifically, MyCorporation attests that MyCorporation has the authority to
grant the USPTO permission to make submitted information available on its online
database regardless of clients’ underlying copyrights.
28. Upon information and belief, MyCorporation has signed away its clients’ right to
privacy, copyrights, and other rights described herein for thousands of clients each
year, for a period of more than ten years.
III. ​MyCorporation’s unlawful practice violates Federal and California laws
29. MyCorporation’s unlawful practice of forging applicants’ signatures on

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 trademark applications violates several federal and California laws.
30. ​First​, ​it is a clear violation of federal rules when a non-attorney electronically
signs the name of a trademark applicant and files the applicant’s trademark application
to the USPTO. ​See In re Shia​, Exhibit C, Proceeding No. D2014-31 (USPTO, March 4,
2016)1 at pg. 23.
31. In ​In re Shia​, the Under Secretary of Commerce and Director of USPTO
explains that there are three acceptable signature methods available when filing
documents electronically through Trademark Electronic Application System (“TEAS”).
Id.​ at pg. 4-5.
32. The first method is the “Direct” signature method. It permits an appropriate
signatory to personally enter his or her name, in a combination of letters, numbers,
spaces, and/or punctuation marks, between two forward slashes. ​Id. ​at pg. 22.
33. The second method, “Esign-on” or “E-mail Text Form to second party for
signature,” allows a TEAS user to email a text version of a TEAS form to the
appropriate signatory for signature, which is then automatically returned via TEAS to
the party who requested signature for filing. ​Id.
34. The third method for signing trademark documents is the “HSign-On” or
“Handwritten pen-and-ink signature” method, where a user can submit a printed
pen-and-ink signature personally made by an appropriate signatory, which is then
scanned as a PDF or JPEG file and attached to the TEAS form for filing. ​Id.
35. “Regardless of which of the three methods chosen, ​no circumstances ​permit a
person to sign the name of another person on a trademark document.” ​Id. (emphasis
added). “Instead, all documents must be personally signed.” ​Id.​;​ ​37 C.F.R. § 2.193​.
36. Federal rule 37 C.F.R. § 2.193(d) provides as follows: “​Signatory must be
identified. The name of the person who signs a document in connection with a
trademark application, registration, or proceeding before the Trademark Trial and
Appeal Board must be set forth in printed or typed form immediately below or adjacent

1
​See ​https://e-foia.uspto.gov/Foia/RetrievePdf?system=OED&flNm=0874_DIS_2016-03-04
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ORIGINAL COMPLAINT
to the signature, or identified elsewhere in the filing (e.g., in a cover letter or other
document that accompanies the filing).” ​Id. ​(emphasis added).
37. Therefore, even when the person is expressly authorized to “affix [client’s]
electronic signature to documents”, Ex. A at 2, that authorization is invalid under the
law. The person can only sign his or her own name on trademark documents and
identify himself or herself, not the client, as the signatory on these documents.
38. MyCorporation violates 37 C.F.R. § 2.193 because it electronically signs client's
name on a trademark document, identifies client as the signatory, and files that
document with the USPTO.
39. MyCorporation’s unlawful practice of forging applicants’ signatures escaped
USPTO’s scrutiny and enforcement action over the years because USPTO does not
proactively investigate filings that appear correct on their face to determine if a
signatory is authorized. ​In re Shia ​at 5.
40. ​Second​, by forging applicants’ signatures on the Declaration to the USPTO,
MyCorporation as a practitioner before the USPTO violates the following federal rules:
a. MyCorporation violates 37 C.F.R. § 11.804(c) by engaging in conduct
involving misrepresentation. ​See Id. ​at 31 (“Falsely signing a document
and submitting it to the [USPTO] is a false representation even if the
substance of the document is accurate, because the signature is
misleading.”).
b. MyCorporation violates 37 C.F.R. § 11.804(d) by engaging in conduct that
is prejudicial to the administration of justice. ​See id. ​at 35 (“filing
documents with forged signatures seriously interferes with the
administration of justice.”) (citation omitted).
c. MyCorporation violates 37 C.F.R. § 11.18(a) by failure to ensure that
“each piece of correspondence filed by a practitioner in the [USPTO] must
bear a signature, personally signed or inserted by such practitioner.” ​Id.
d. MyCorporation violates 37 C.F.R. § 11.18(b) by falsely certifying on paper

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 presented to the USPTO that “[a]ll statements made therein of the party's
own knowledge are true”. ​Id.
e. MyCorporation violates 37 C.F.R. § 11.503(a) because it fails to ensure
that MyCorporation has measures giving reasonable assurance that its
non-practitioner assistants’ conducts are compatible with the professional
obligations of the practitioner.
41. ​Third​, MyCorporation and its staff’’s conduct violates federal criminal statute 18
U.S.C. § 1001 by knowingly and willfully making any materially false representation.
This crime is punishable by imprisonment of 5 years.
42. ​Fourth​, MyCorporation and its staff’’s conduct violates California Penal Code §
470(a), which provides that “[e]very person who, with the intent to defraud, knowing
that he or she has no authority to do so, signs the name of another person or of a
fictitious person to any of the items listed [​e.g.​, a contract] is guilty of forgery.” ​Id. This
crime is punishable by imprisonment in a county jail for one year. Cal. Pen. Code §
473.
43. MyCorporation knowingly and willfully made material false representation, and
had specific intent to defraud the USPTO because, its owner and CEO, Defendant
Deborah Sweeney, is a licensed California attorney. Sweeney possesses the training,
education and professional qualifications that it should be obvious to her that forging
applicants’ signatures on trademark applications violates various federal and California
laws. Moreover, Sweeney is a self-styled teacher on trademark law. She repeatedly
writes about trademark practice before the USPTO on various websites.2
44. Despite having sufficient knowledge of the violation, MyCorporation still
engages in this unlawful practice. Upon information and belief, MyCorporation has
been forging thousands of applicants’ signatures for more than ten years.

2
​For example, Deborah Sweeney wrote “Why Trademarking Is the Best Thing to Do for Your Business”
https://www.advertisemint.com/trademarking-best-thing-business/​, ”T is for Trademark”
https://blog.mycorporation.com/2013/05/t-is-for-trademark/​. and ”3 Ways to Protect Your Business's
Intellectual Property”
.​https://www.business.com/articles/3-ways-to-protect-your-business-intellectual-property/​.
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ORIGINAL COMPLAINT
 45. The California State Bar and USPTO have investigated, disciplined and
excluded attorneys and non-attorneys for conduct related to forgery. ​See In re Shia​;
see also In re Modlin​, in 2016, the State Bar Court of California ruled to summarily
disbar Folsom attorney Delbert Joe Modlin after he was convicted for conspiracy to
commit forgery. See: ​http://members.calbar.ca.gov/courtDocs/11-C-12725-2.pdf
IV. ​Sweeney’s conduct violates various federal and California laws
46. Sweeney is vicariously liable for all of the above federal and state law violations
committed by MyCorporation because she is the owner and CEO of MyCorporation
and a licensed California attorney.
47. Furthermore, Sweeney violates all of the above federal and California laws by
aiding and abetting MyCorporation and MyCorporation’s staff to commit violations of
these laws.
V. ​RAPC’s lawful and innovative practice
48. RAPC offers trademark filing services for $199 plus government filing fees
through RAPC, Inc.’s Trademarkia.com website. Unlike MyCorporation, RAPC is a law
firm. Indeed, it is the largest law firm filer of trademarks before the USPTO and has
been for each of the past five years.
49. Like MyCorporation, RAPC provides clients with legal advice and
representation in the prosecution of a trademark application. But unlike MyCorporation,
RAPC’s service is attorney-supervised. A U.S. trademark attorney is involved at all
critical steps of the application process and the same licensed attorney personally
signs off prior to each filing.
50. Raj Abhyanker is the founder and sole shareholder of RAPC. He is an
accomplished Silicon Valley electrical and software engineer, innovator, and inventor.
He is a former founder and Chief Executive of an internet neighborhood social
networking startup that raised more than $5.5M in venture funding prior to its
acquisition by Google, Inc. in 2011. Abhyanker is the inventor of thirty (30) granted
U.S. utility and design patents, including five (5) owned by Google, Inc. in the fields of

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ORIGINAL COMPLAINT
software technology, neighborhood social networking, robotics, drones, autonomous
vehicles, and communications engineering.
51. Beyond being an engineer, Abhyanker is also a California licensed attorney
who practices patent and trademark law before the USPTO. He was named as a 2013
Legal Rebel by the ABA Journal, a distinction reserved for “change leaders of the legal
profession,” and was on the Fastcase 50, an annual award recognizing 50 of the
“smartest, most courageous innovators, techies, visionaries, and leaders in the law,”
because of his success in his mission to increase small businesses’ access to
trademark services without a loss of quality.
52. RAPC has accomplished that mission by innovating within the bounds of the
regulations governing the legal profession:
a. Client/Matter Management Technology. RAPC has developed its own
platform for client and matter management that automates many
processes, detects and corrects errors through artificial intelligence,
streamlines the work flow, and focuses attorney attention on only attorney
tasks. The USPTO uses similar but perhaps even less advanced
technology to manage its process.
b. Volume. With over 400 new trademark clients a month, RAPC attorneys
spend most of their time consulting clients over the phone or via email and
giving legal advice—which not only develops their expertise but makes
them more efficient. Five of the top ten most successful filers, ranked by
the 2017 World Trademark Review industry publication, are RAPC
attorneys.
c. Bifurcated Supply Chain Management. RAPC applied best manufacturing
practices to legal services by taking all non-attorney work off of attorneys’
plates and globalizing it to improve quality while reducing costs.
d. Training. RAPC attorneys undergo a three-month intensive training
process modeled after the USPTO trademark examining attorney training

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ORIGINAL COMPLAINT
 program to ensure they are proficient and efficient trademark attorneys.
Heather Sapp, an 11-year veteran USPTO trademark examining attorney,
who reviewed approximately 13,000 trademark applications over the
course of her career at the USPTO, is the full-time communications and
training manager of RAPC.
53. The results demonstrate its success: RAPC has a higher allowance rate than
any other law firm in the country that charges less than $1,000 per trademark filing,
and files more than 100 trademark applications per year.
VI. ​An uneven playing field and the unfair competition
54. As explained above, RAPC provides superior technology, is more innovative,
and provides more qualified, higher quality services than MyCorporation at the same
price. But it is losing the battle because it is being fought on an uneven playing field.
RAPC and its attorneys are bound by the rules of conduct governing the legal
profession. MyCorporation has eschewed those rules by fraudulently signing USPTO
documents. Many of those rules protect consumers. They ensure competence and
loyalty and provide remedies when those duties are violated.
55. MyCorporation’s unlawful business practices have enabled it to have a
significantly lower cost of services rendered. As a result of MyCorporation’s unfair
competition, Plaintiff has suffered lost revenue, loss of market share, reduced asset
value, diverted sales to Defendants, and increased advertising costs.
56. RAPC lost significant competitive bidding opportunities on approximately $1.4
million dollars of advertising spent in the year 2017 alone, at least partially due to
MyCorporation. RAPC has reduced their attorney led service prices to $199 and lower
to meet the unfair competition of MyCorporation.
57. A good percentage of consumers likely would not have purchased
MyCorporation’s “customer service and support” trademark filing services and may
have opted for those of RAPC instead. In total, RAPC’s lost sales opportunities exceed
$500,000 based on the lifetime value per customer in the past three years alone, upon

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ORIGINAL COMPLAINT
information and belief.
58. RAPC has also lost asset value. RAPC has seen its market share decline from
nearly 3% of all U.S. trademarks filed in the United States in 2011 to approximately
1.8% in 2017. RAPC has lost market share of approximately 1.1% of the overall
trademark market since 2011 (approximately 5,000 trademarks filings per year) in the
relevant market for U.S. trademark filing and prosecution at least partially because of
MyCorporation.
59. Moreover, RAPC’s advertising costs have increased. RAPC’s cost per click and
total advertising attract for trademark clients has gone up by approximately 20%. In
addition, as a direct consequence of MyCorporation’s wrongful acts, upon information
and belief, RAPC has reduced their trademark service prices from $499 to $199 in
order to match the unfair competition from MyCorporation.
FIRST CLAIM FOR RELIEF
DECLARATORY JUDGMENT
UNDER CODE CIV. PROC. §§ 1060-1062.5 and other relevant sections
(Against MyCorporation)

60. RAPC repeats each and every allegation contained in the paragraphs above
and incorporates by reference each preceding paragraph as though fully set forth
herein.
61. An actual controversy has arisen and now exists between RAPC and
MyCorporation because MyCorporation unfairly competes with RAPC. The Court must
first answer a fundamental question: whether MyCorporation’s trademark filing service
violates federal and California laws by forging applicant’s signature on USPTO forms.
62. As a direct result of MyCorporation’s unfair competition, RAPC has suffered
injury-in-fact including lost revenue and market share, reduced asset value, and
increased advertising costs over the past six years.
63. RAPC’s injury is fairly traceable to MyCorporation’s conduct of signing
documents with their customer’s signature before the USPTO. By signing their
customer’s name, MyCorporation is able to shortcut their processes for preparing and

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filing trademarks.
64. RAPC’s injury will be redressed by the Court’s declaration addressing the
question of whether MyCorporation’s manner of signing USPTO documents is illegal. If
the answer to this question is affirmative, then MyCorporation will no longer be able to
take shortcuts in signing USPTO documents using their customers’ names. RAPC will
be able to effectively compete with MyCorporation on a level playing field. If the answer
to this question is negative, then RAPC will be able to sign trademark filing applications
as MyCorporation does, and will also be able to effectively compete with
MyCorporation on a level playing field.
65. Therefore, RAPC seeks a declaration from this Court that MyCorporation’s
manner of signing government documents is illegal. Specifically, RAPC seeks a
declaration from this Court that the following conduct by MyCorporation in trademark
filing service is illegal:
a. Signing USPTO trademark filing forms by entering each customer’s name
and electronically signing and submitting the forms to USPTO.

SECOND CLAIM FOR RELIEF

CALIFORNIA UNFAIR COMPETITION IN VIOLATION OF
CAL. BUS. & PROF. CODE § 17200 ​ET SEQ.
(Against all Defendants and DOES 1-50)

66. RAPC repeats each and every allegation contained in the paragraphs above
and incorporates by reference each preceding paragraph as though fully set forth
herein.
67. RAPC has standing to sue because they have suffered injury-in-fact and lost
money, including diverted sales to Defendants, lost revenue, loss of market share,
reduced asset value, and increased advertising costs.
68. Sweeney, in her personal capacity, has violated the unlawful prong of UCL
because of the following:
a. Sweeney violates various federal and California laws as alleged

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 throughout this Complaint.
b. Sweeney violates 37 C.F.R. § 11.18(a) by failure to ensure that “each
piece of correspondence filed by a practitioner in the [USPTO] must bear
a signature, personally signed or inserted by such practitioner.” ​Id.
c. Sweeney violates 37 C.F.R. § 11.18(b) by falsely certifying on paper
presented to the USPTO that “[a]ll statements made therein of the party’s
own knowledge are true”. ​Id.
d. Sweeney violates 37 C.F.R. § 11.503(a) because she fails to ensure that
MyCorporation has measures in effect to give reasonable assurance that
her non-practitioner assistants’ conduct is compatible with the professional
obligations of the practitioner.
e. Sweeney fails to exercise reasonable efforts to ensure that measures are
in effect to give reasonable assurance that her non-practitioner assistants’
conduct is compatible with the professional obligations of Sweeney as
defined in 37 C.F.R. § 11.503(b), at least because MyCorporation fails to
maintain an IOLTA account for their customers and fails to conduct conflict
checks.
f. Sweeney fails to self-regulate conduct of her non-practitioner assistants
because Sweeney ratifies the conduct involved as defined in 37 C.F.R. §
11.503(c), because a licensed attorney such as Sweeney would be fined,
disbarred or imprisoned for violation of forgery laws.
g. Sweeney engages in conduct that is prejudicial to the administration of
justice as defined in 37 C.F.R. § 11.804(d) because instead of running a
law firm practicing trademark law, she runs her MyCorporation business
as a non-law firm to avoid regulation and enforcement from the USPTO
and the state bar.
69. MyCorporation’s conduct violates all three prongs of the California Unfair
Competition law in § 17200 et. seq., in that the practices alleged are unlawful, unfair

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ORIGINAL COMPLAINT
and fraudulent.
70. MyCorporation has violated the unlawful prong of UCL because of the following:
a. MyCorporation violates federal and California laws as alleged throughout
this Complaint.
b. MyCorporation fails to exercise reasonable efforts to ensure that it has
measures in effect that give reasonable assurance that non-practitioner
assistants’ conduct is compatible with the professional obligations of
Sweeney as defined in 37 C.F.R. §11.503(b).
c. Sweeney fails to self-regulate conduct of her non-practitioner assistants
because Sweeney ratifies the conduct involved as defined in 37 C.F.R. §
11.503(c), because a licensed attorney such as Sweeney would be fined,
disbarred or imprisoned for violation of forgery laws.
d. MyCorporation performs trademark searches and delivers results from the
searches of potentially conflicting trademarks directly to customers without
attorney review and without advance approval from an attorney, and
thereby goes well beyond mere “form filling”, because such activities
require unique application of legal rules to specific unique sets of facts.
e. MyCorporation fails to conduct conflict checks for trademark customers of
MyCorporation prior to assisting them in preparation and filing of U.S.
trademarks.
f. MyCorporation fails to deposit funds of their trademark customers into an
IOLTA trust account until a conflict check is completed.
71. MyCorporation claims that it can sign declarations before the USPTO without
verification because each trademark customer agrees to “Client Consent”. However,
without each customer’s express consent, MyCorporation uses this misleading
representation to declarations before the USPTO.
72. MyCorporation has violated the unfair prong of UCL because of the following:
a. It is immoral and unethical for MyCorporation to forge clients’ signatures

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ORIGINAL COMPLAINT
 and to violate various federal and state laws in order to gain competitive
advantage over RAPC.
b. The resulting injury to consumers is substantial because “such willful false
statements and the like may jeopardize the validity of the application or
submission or any [trademark] registration.” ​See ​Exhibit B at 6.
c. This unlawful, immoral and unethical business practice produces no
benefits whatsoever to the consumers or to the competition. The injury to
consumers, which could well be the invalidation or nullification of
consumers’ trademark applications by the USPTO, is not outweighed by
any countervailing benefits (because there is none).
d. The injury is of the kind that consumers themselves could not reasonably
be avoided, because reasonable customers of MyCorporation are not
aware that their signatures are being forged and do not understand the
dire consequence of such forgery.
73. MyCorporation has violated the fraudulent prong of UCL because of the
following:
a. Who ​- MyCorporation.
b. What ​- Practicing the crime of forging signatures of its customers when
filing trademarks before the USPTO.
c. When ​- Between approximately January 1, 2005 and continuing through
today Friday March 23, 2018.
d. Where - Across the United States and the world through their Internet
website MyCorporation for customers across the United States through a
headquarters location at 26025 Mureau Road, Suite 120, Calabasas, CA
91302-3180.
e. How ​- By fraudulently affixing the name of their customers on USPTO
forms.
f. Because ​- These fraudulent business acts and practices are likely to

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ORIGINAL COMPLAINT
 deceive reasonable consumers as well as the general public and the
USPTO itself.
74. RAPC is informed and believe that MyCorporation and Sweeney, as
competitors to RAPC, performed the acts alleged herein for the purpose of injuring
RAPC. The acts alleged herein continue to this day and present a threat to RAPC, the
general public, the trade, and consumers.
75. As a result of the wrongful acts of MyCorporation and Sweeney, RAPC has
suffered and will continue to suffer loss of millions of dollars of revenue, loss of profits,
loss of market share, reduced asset value, diverted sales to Defendants, increased
advertising costs and loss of valuable business opportunities. These restitutions are all
belonged to or vested to Plaintiff but taken away by Defendants as a result of their
wrongful acts.
76. If Defendants are not preliminarily or permanently enjoined, they will continue to
derive revenue, profits, market share and sales from Plaintiff by wrongful acts. Unless
restrained by this court, Defendants will cause additional injury to Plaintiff for which
Plaintiff has no adequate remedy at law.
77. RAPC seeks an order of this Court under California Business & Professions
Code § 17200 that preliminarily and permanently enjoins MyCorporation and Sweeney
from continuing to engage in the unlawful and fraudulent acts or practices set forth
herein, as well as restitution.

THIRD CLAIM FOR RELIEF

PROFESSIONAL NEGLIGENCE
(Against Sweeney)

78. RAPC repeats each and every allegation contained in the paragraphs above
and incorporate by reference each preceding paragraph as though fully set forth
herein.
79. Sweeney owed a duty to RAPC when her business, MyCorporation, collected
more than $149 in legal service and government fees from RAPC to file trademark

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ORIGINAL COMPLAINT
application for PACERALERT.
80. Sweeney has breached her duty by forging the signature of Raj Abhyanker on
the PACERALERT trademark on behalf of RAPC using non-attorney staff.
81. Moreover, Sweeney breached her duty to RAPC by not supervising non-lawyer
assistants who fraudulently signed a declaration, waived privacy rights, and waived
underlying copyrights in the federal trademark application for PACERALERT.
82. In addition, Sweeney owed a duty to RAPC to act at all times in good faith and
in RAPC’s best interests, and had a duty, among other things, to perform the services
for which her corporate entity MyCorporation was retained with reasonable care and
skill to prepare and file the PACERALERT trademark, to act in the RAPC highest and
best interests at all times, and to not expose RAPC to unnecessary risk or peril. As a
licensed practitioner, Sweeney knew or should have known practices with respect to
signing Declarations and documents before the United States Patent & Trademark
Office.
83. By not supervising, and actively aiding and abetting her non-lawyer staff to sign
a declaration, sign away privacy, and disclaim copyright without properly informing
RAPC in advance, Sweeney exposed RAPC to risk or peril for their PACERALERT
trademark as described by the USPTO web page subheading “Signatures on
trademark applications and associated documents” which clearly explains :
Improperly signed submissions may delay or prolong the application
process, may lead to the abandonment of your application, and may
jeopardize the validity of any resulting registration. If the USPTO
determines that a submission is improperly signed, the submission
will not be accepted and any arguments, evidence, or amendments
set forth in the submission will not be considered or entered.

Exhibit D.

84. Sweeney breached professional duties to RAPC by failing to properly supervise

legal assistants, paid search specialists, and/or on-page marketing specialists in
violation of 37 CFR § 11.503 – Duty to supervise non-lawyers. Specifically, Sweeney

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ORIGINAL COMPLAINT
failed to supervise a non-practitioner assistant employed or retained by or associated
with MyCorporation. She is responsible for conduct of such a person that would be a
violation of the USPTO Rules of Professional Conduct if engaged in by a practitioner.
85. In addition, Sweeney breached her duty to RAPC by:
a. Failing to make reasonable efforts to ensure that that “each piece of
correspondence filed by a practitioner in the [USPTO] must bear a
signature, personally signed or inserted by such practitioner.” 37 C.F.R. §
11.18(a).
b. Falsely certifying on paper presented to the USPTO that “[a]ll statements
made therein of the party's own knowledge are true”. 37 C.F.R. § 11.18(b).
c. Failing to make reasonable efforts to ensure that MyCorporation has in
effect measures giving reasonable assurance that its non-practitioner
assistants’ conduct is compatible with the professional obligations of
licensed attorneys as defined in 37 C.F.R. § 11.503(a).
d. Failing to exercise reasonable efforts to ensure that she has in effect
measures giving reasonable assurance that non-practitioner assistant’s
conduct is compatible with the professional obligations of Deborah S.
Sweeney as defined in 37 C.F.R. § 11.503(b) at least because
MyCorporation fails to maintain an IOLTA account for customers of
MyCorporation, fails to conduct conflict checks, and fails to take
reasonable measures to avoid aiding and abetting customers with
submitting fraudulent specimens to the USPTO in violation of 18 U.S.C. §
1001.
e. Failing to self-regulate conduct of a non-practitioner assistant that would
be a violation of the USPTO Rules of Professional Conduct if engaged in
Deborah S. Sweeney because MyCorporation orders, or with the
knowledge of the specific conduct, ratifies the conduct involved as defined
in 37 C.F.R. §11.503(c) because a licensed attorney including Deborah S.

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ORIGINAL COMPLAINT
 Sweeney would be disbarred or imprisoned for knowingly engaging in the
crime of unauthorized practice of law.
f. Engaging in conduct that is prejudicial to the administration of justice as
defined in 37 C.F.R. § 11.804(d) because instead of running a law firm
practicing trademark law, she runs her MyCorporation business as a
non-law firm to avoid regulation and enforcement from the USPTO and the
state bar.
86. At all times mentioned here, Defendants failed to exercise the required
standard of care and have jeopardized the validity of RAPC’s’ PACERALERT
trademark.
87. Further, as a direct and proximate result of Sweeney’s breach of professional
negligence, omissions, and/or intentional acts, RAPC has sustained damages including
potential invalidation of the PACERALERT trademark by the USPTO, legal fees paid to
MyCorporation in the amount of $149, the government fee of $275 and other amounts
which will be determined according to proof at trial.

FOURTH CLAIM FOR RELIEF

NEGLIGENCE PER SE
(Against all Defendants and DOES 1-50)

88. RAPC repeats each and every allegation contained in the paragraphs above
and incorporate by reference each preceding paragraph as though fully set forth
herein.
89. MyCorporation and Sweeney owed a duty of professional care to RAPC when
MyCorporation.com collected more than $149 in legal service and government fees
from RAPC to file trademark application for PACERALERT.
90. MyCorporation and Sweeney violated various federal and California laws as
alleged throughout this Complaint.
91. The injuries sustained by RAPC was exactly the kind of injuries that these laws
were designed to prevent.

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ORIGINAL COMPLAINT
 92. The purpose of these laws was to protect the class of persons of trademark
applicants and RAPC is one member of such class.
93. As a direct and proximate result of Defendants’ breach, RAPC has sustained
damages including potential invalidation of the PACERALERT trademark by the
USPTO, legal fees paid to MyCorporation in the amount of $149, the government fee
of $275 and other amounts which will be determined according to proof at trial.

FIFTH CLAIM FOR RELIEF

BREACH OF FIDUCIARY DUTIES
(Against Sweeney)

94. RAPC repeats each and every allegation contained in the paragraphs above
and incorporate by reference each preceding paragraph as though fully set forth
herein.
95. Sweeney owed a fiduciary duty to RAPC when MyCorporation.com collected
more than $149 in legal service and government fees from RAPC to file trademark
application for PACERALERT.
96. Sweeney has breached her fiduciary duty by forging the signature of the
PACERALERT trademark on behalf of RAPC using non-attorney staff.
97. Moreover, Sweeney breached her duty to RAPC by not supervising non-lawyer
assistants who fraudulently signed a declaration, waived privacy rights, and waived
underlying copyrights in the federal trademark application for PACERALERT.
98. In addition, Sweeney owed a duty to RAPC to act at all times in good faith and
in RAPC best interests, and had a duty, among other things, to perform the services for
which her corporate entity MyCorporation was retained with reasonable care and skill
to prepare and file the PACERALERT trademark, to act in the RAPC highest and best
interests at all times, and to not expose RAPC to unnecessary risk or peril. As a
licensed practitioner, Sweeney knew or should have known practices with respect to
signing Declarations and documents before the United States Patent & Trademark
Office.

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ORIGINAL COMPLAINT
 99. By not supervising, and actively aiding and abetting her non-lawyer staff to sign
a declaration, sign away privacy, and disclaim copyright without properly informing
RAPC in advance, Sweeney exposed RAPC to risk or peril for their PACERALERT
trademark as described by the USPTO web page titled “Proper representation in
trademark matters,” including but not limited to (1) delaying and prolonging in the
trademark application process, potentially leading to abandonment of the
PACERALERT application, and jeopardizing the validity of any resulting registration.
100. Sweeney breached her fiduciary duties to RAPC by failing to properly
supervise legal assistants, paid search specialists, and/or on-page marketing
specialists in violation of 37 CFR § 11.503 – Duty to supervise non-lawyers.
Specifically, Sweeney failed to supervise a non-practitioner assistant employed or
retained by or associated with MyCorporation while being responsible for conduct of
such a person that would be a violation of the USPTO Rules of Professional Conduct if
engaged in by a practitioner.
101. In addition, Sweeney breached her fiduciary duty to RAPC in the same ways
as alleged in Paragraph 85 above.
102. At all times mentioned here, Defendants failed to exercise the required
fiduciary duty and have jeopardized the validity of the RAPC’s PACERALERT
trademark.
103. Further, as a direct and proximate result of Sweeney’s breach of fiduciary
duty, omissions, and/or intentional acts, RAPC has sustained damages including
potential invalidation of the PACERALERT trademark by the USPTO, legal fees paid to
MyCorporation in the amount of $149, the government fee of $275 and other amounts
which will be determined according to proof at trial.

REQUEST FOR RELIEF

WHEREFORE, RAPC requests that this Court:
1. Declare that MyCorporation’s conduct of forging applicants’ signatures on

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ORIGINAL COMPLAINT
 trademark applications violates federal and California law and is therefore
illegal;
2. Enter award against MyCorporation and Sweeney;
3. Award RAPC damages and restitution against MyCorporation in the
amount exceeding $25,000 and against Sweeney in the amount
exceeding $25,000;
4. Award RAPC its costs and expenses of this action against MyCorporation
and Sweeney, including its reasonable attorneys’ fees necessarily
incurred in bringing and pressing this case;
5. Award RAPC pre- and post-award interest at the applicable rates on all
amounts awarded;
6. Grant permanent injunctive relief to prevent the recurrence of the
violations for which redress is sought in this Complaint; and
7. Award any other such relief as the Court deems appropriate.

Respectfully submitted this Thursday, May 31, 2018.

LegalForce RAPC WORLDWIDE P.C.

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

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ORIGINAL COMPLAINT
 JURY TRIAL DEMAND
Plaintiff hereby requests a jury trial for all causes of action except declaratory
relief as alleged in this Complaint.

Respectfully submitted this Thursday, May 31, 2018.

LegalForce RAPC WORLDWIDE P.C.

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

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ORIGINAL COMPLAINT