HomeVestors of America, Inc. v. American REIS LLC; Extreme REIS; Jeremy Glickman; Khurram Rasool; Farhad Rasool; Robert Werner; and Frank White

CourtDistrict Court, N.D. Texas
DecidedMarch 30, 2026
Docket3:25-cv-00644
StatusUnknown

This text of HomeVestors of America, Inc. v. American REIS LLC; Extreme REIS; Jeremy Glickman; Khurram Rasool; Farhad Rasool; Robert Werner; and Frank White (HomeVestors of America, Inc. v. American REIS LLC; Extreme REIS; Jeremy Glickman; Khurram Rasool; Farhad Rasool; Robert Werner; and Frank White) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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HomeVestors of America, Inc. v. American REIS LLC; Extreme REIS; Jeremy Glickman; Khurram Rasool; Farhad Rasool; Robert Werner; and Frank White, (N.D. Tex. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

HOMEVESTORS OF AMERICA, INC., § § Plaintiff, § § v. § Civil Action No. 3:25-CV-644-L § AMERICAN REIS LLC; EXTREME § REIS; JEREMY GLICKMAN; § KHURRAM RASOOL; FARHAD § RASOOL; ROBERT WERNER; and § FRANK WHITE, § § Defendants. §

MEMORANDUM OPINION AND ORDER

Before the court is Plaintiff’s Motion for Default Judgment (“Motion”) (Doc. 15), filed June 26, 2025; and Plaintiff’s Motion for Hearing on Pending Motion (Doc. 16), filed January 21, 2026. After careful consideration of the Motion, pleadings, the record, and applicable law, the court grants in part and denies in part the Motion (Doc. 15); and denies as moot Plaintiff’s Motion for Hearing on Pending Motion (Doc. 16). I. Background On March 17, 2025, Plaintiff HomeVestors of America, Inc. (“Plaintiff” or “HomeVestors”) brought this action against Defendants American REIS LLC, Extreme REIS LLC, Jeremy Glickman,1 Khurram Rasool, Fahrad Rasool, Robert Werner, and Frank White (collectively, “Defendants” or “Reis Defendants”) for trademark infringement, trademark dilution, false designation of origin, unfair competition, and copyright infringement, alleging that

1 Defendants Jeremy Glickman and Robert Werner were dismissed from this action by Plaintiff on May 7, 2025, and are no longer parties to this action. Accordingly, the court’s reference to “Defendants” or “REIS Defendants” refers to the remaining Defendants in this action. Defendants copied HomeVestors’ website, trademarks, copyrighted materials, and even HomeVestors’ origin story to unfairly compete with HomeVestors. Plaintiff seeks a default judgment with respect to all of its claims against Defendants, an award of monetary damages, attorney’s fees and costs, and a permanent injunction. As Plaintiff’s Motion includes a request for

a hearing to develop evidence supporting its claim for damages, attorney’s fees, and costs, the court’s focus here is only on its request for entry of a default judgment as to Defendants’ liability for the claims asserted and a permanent injunction against Defendants.2 Plaintiff also recently filed a separate Request for Hearing on Pending Motion (Doc. 16) on January 21, 2026, out of concern regarding Defendants’ continuing unlawful use of Plaintiff’s registered marks and copyrighted materials; however, the court’s ruling on Plaintiff’s Motion for Default Judgment as to liability and the imposition of a permanent injunction moots that request. II. Default Judgment A. Legal Standard A party is entitled to entry of a default by the clerk of the court if the opposing party fails

to plead or otherwise defend as required by law. Fed. R. Civ. P. 55(a). Under Rule 55(a), a default must be entered before the court may enter a default judgment. See id.; New York Life Ins. Co. v. Brown, 84 F.3d 137, 141 (5th Cir. 1996). The clerk of court has entered a default against Defendants (Doc. 14). Based upon the pleadings and information in the record, the court finds that Defendants are not minors, incompetents, or members of the United States military. Defendants, by failing to answer or otherwise respond to Plaintiff’s Complaint, have admitted the well-pleaded

2 Plaintiff contends that Defendants’ conduct was willful, and that this is an “exceptional case.” The court need not address these issues, as they pertain to damages and attorney’s fees that will be addressed in a separate hearing. Moreover, these issues need further development, as the facts and legal authority relied on by Plaintiff in its Motion are conclusory and weak. allegations of the Complaint and are precluded from contesting the established facts on appeal. Nishimatsu Constr. Co. v. Houston Nat’l Bank, 515 F.2d 1200, 1206 (5th Cir. 1975) (citations omitted). Stated differently, a “defendant is not held to admit facts that are not well-pleaded or to admit conclusions of law.” Wooten v. McDonald Transit Assocs., Inc., 788 F.3d 490, 496 (5th Cir.

2015) (citation omitted). Accordingly, Defendants may not contest the “sufficiency of the evidence” on appeal, but they are “entitled to contest the sufficiency of the complaint and [the] allegations to support the judgment.” Id. Based on the well-pleaded allegations in Plaintiff’s Complaint, which the court accepts as true, and the record in this action, the court, for the reasons herein explained, determines that Defendants are in default, and that Plaintiff is entitled to a default judgment. See United States v. Shipco Gen., 814 F.2d 1011, 1014 (5th Cir. 1987) (citation omitted) (“A default judgment is a judgment on the merits that conclusively establishes the defendant’s liability.”). B. Requirements for Trademark Infringement, False Designation of Origin, and Unfair Competition

Section 1114 of the Lanham Act covers trademark infringement claims, whereas § 1125 covers false designation of origin and unfair competition claims. The “central inquiry” with false designation of origin and unfair competition claims is “whether the defendant is passing off his goods or services as those of the plaintiff by virtue of substantial similarity between the two, leading to confusion on the part of potential customers.” Sun–Fun Prods., Inc. v. Suntan Rsch. & Dev., Inc., 656 F.2d 186, 192 (5th Cir. 1981) (citation omitted). “The factors relevant to this inquiry are essentially the same as those relevant in determining trademark infringement[.]” Id. To recover on a claim of trademark infringement under the Lanham Act, a plaintiff must show that “(1) it possesses a legally protectable trademark” and (2) the defendant’s use of the trademark “creates a likelihood of confusion as to source, affiliation, or sponsorship.” Streamline Prod. Sys., Inc. v. Streamline Mfg., Inc., 851 F.3d 440, 450 (5th Cir. 2017) (citation omitted). “To be legally protectable, a mark must be ‘distinctive’ in one of two ways”: “(1) inherent distinctiveness or (2) acquired distinctiveness through secondary meaning.” Id. (citations omitted). Registration of a mark or marks constitutes “prima facie evidence that the marks are inherently

distinctive.” Nola Spice Designs, LLC v. Haydel Enters., Inc., 783 F.3d 527, 537 (5th Cir. 2015) (citation omitted). To determine whether a defendant’s use of a mark is likely to cause confusion, the Fifth Circuit uses a non-exhaustive list of factors referred to as “digits of confusion.” Jim S. Adler, P.C. v. McNeil Consultants, LLC, 10 F.4th 422, 427 (5th Cir. 2021) (citation omitted). These factors or digits include: “(1) the type of trademark; (2) mark similarity; (3) product similarity; (4) outlet and purchaser identity; (5) advertising media identity; (6) defendant’s intent; (7) actual confusion; and (8) care exercised by potential purchasers.” Xtreme Lashes, LLC v. Xtended Beauty, Inc., 576 F.3d 221, 227 (5th Cir. 2009).

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HomeVestors of America, Inc. v. American REIS LLC; Extreme REIS; Jeremy Glickman; Khurram Rasool; Farhad Rasool; Robert Werner; and Frank White, Counsel Stack Legal Research, https://law.counselstack.com/opinion/homevestors-of-america-inc-v-american-reis-llc-extreme-reis-jeremy-txnd-2026.