Siamas v. Zelcs

CourtDistrict Court, M.D. Florida
DecidedAugust 29, 2025
Docket8:25-cv-01448
StatusUnknown

This text of Siamas v. Zelcs (Siamas v. Zelcs) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Siamas v. Zelcs, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

JOHN SIAMAS,

Plaintiff,

v. Case No. 8:25-cv-1448-TPB-SPF

GAYLE ZELCS,

Defendant. _____________________________/

ORDER DISMISSING COMPLAINT WITHOUT PREJUDICE

This matter is before the Court sua sponte. After reviewing the complaint, court file, and the record, the Court finds as follows: Background1 This case stems from what appears to be an HOA dispute between Plaintiff John Siamas and his neighborhood homeowner’s association, Stonebriar Improvement Association, Inc., led by Defendant Gayle Zelcs as the president. He has not sued the HOA – instead, at this time, Plaintiff has sued only Zelcs individually. Among other things, Plaintiff (who is proceeding pro se in this matter) appears to allege that Defendant fraudulently obtained a Florida state trademark for “Stonebriar” − the same mark he applied for at the United States Patent and

1 The Court accepts as true the facts alleged in the complaint for purposes of ruling on the pending motion to dismiss. See Erickson v. Pardus, 551 U.S. 89, 94 (2007) (“[W]hen ruling on a defendant’s motion to dismiss, a judge must accept as true all of the factual allegations contained in the complaint.”). The Court is not required to accept as true any legal conclusions couched as factual allegations. See Papasan v. Allain, 478 U.S. 265, 286 (1986). Trademark Office (“USPTO”). Plaintiff takes issue with Defendant’s opposition to his federal trademark application. Plaintiff alleges that the opposition includes fraudulent statements that Defendant should have known were false based on her

own prior application for a federal trademark for “Stonebriar.” Plaintiff’s lengthy, winding complaint also recounts several other spats between Plaintiff and Defendant concerning the HOA’s budget, HOA violations, and perceived slights. None of these disputes, of course, have anything to do with trademarks. On June 3, 2025, Plaintiff filed his 62-page complaint, asserting claims for: fraudulent procurement of a trademark under 15 U.S.C. § 1120 (Count I); abuse of process under Florida law (Count II), tortious interference with prospective

economic advantage under Florida law (Count III), declaratory relief (Count IV), attorney’s fees and costs (Count V), breach of fiduciary duty under Florida law (Count VI), and abuse of process (retaliatory fraud allegation), presumably under Florida law (Count VII). (Doc. 1). The following day, he filed over seven hundred pages of exhibits. (Doc. 3). Because subject matter jurisdiction hinges on Plaintiff’s federal claims, this Order considers only those causes of action citing to federal

statutes and leaves the state claims for another day. Analysis Shotgun Pleading As an initial matter, the Court notes that the complaint constitutes a shotgun pleading. A shotgun pleading is one where “it is virtually impossible to know which allegations of fact are intended to support which claim(s) for relief” and the defendant therefore cannot be “expected to frame a responsive pleading.” Anderson v. Dist. Bd. Of Trustees of Cent. Fla. Cmty. College, 77 F.3d 364, 366 (11th Cir. 1996). The Eleventh Circuit has identified four primary types of shotgun pleadings, including:

(1) complaints containing multiple counts where each count adopts the allegations of all preceding counts, causing each successive count to carry all that came before and the last count to be a combination of the entire complaint;

(2) complaints that do not commit the mortal sin of re-alleging all preceding counts but are guilty of the venial sin of being replete with conclusory, vague, and immaterial facts not obviously connected to any particular cause of action;

(3) complaints that commit the sin of not separating into a different count each cause of action or claim for relief; and

(4) complaints that assert multiple claims against multiple defendants without specifying which of the defendants are responsible for which actions or omissions, or which of the defendants the claim is brought against.

Weiland v. Palm Beach Cty. Sheriff’s Office, 792 F.3d 1313, 1322-23 (11th Cir. 2015). Here, the complaint presents a significant problem by intermingling factual allegations as to the parties’ separate state and USPTO trademark disputes, along with general HOA disputes, which makes it very difficult – if not impossible – to determine how each allegation relates to Plaintiff’s claims. Moreover, Plaintiff appears to refer to two different USPTO proceedings at different times throughout the complaint without clarifying which one his fraudulent procurement claim is based on. Notwithstanding these issues, the complaint is otherwise overly long and confusing, spanning over 60 pages without exhibits and over 700 pages with them, and as mentioned, mixing general and typical HOA grievances. This is simply not a “short and plain statement of the claim[s]” required by Fed. R. Civ. P. 8(a)(2). Count I – Fraudulent Procurement of a Trademark

In Count I, Plaintiff brings a claim for fraudulent procurement of a trademark under 15 U.S.C. § 1120. Under this statute, “[a]ny person who shall procure registration in the [USPTO] of a mark by a false or fraudulent declaration or representation, oral or in writing, or by any false means, shall be liable in a civil action by any person injured thereby for any damages sustained in consequence thereof.” Plaintiff’s claim is based in part on Defendant’s alleged false material misrepresentations in its opposition to Plaintiff’s USPTO applications for the mark

“Stonebriar Improvement Association, Inc.” (Doc. 1 at 71-73; 75). He also claims that Defendant’s fraud extends to her own prior Florida trademark and to her federal trademark application for “Stonebriar,” which was apparently denied by the USPTO.2 See (Doc. 1 at 76; 84; 85) First, to the extent that Plaintiff alleges representations made in the context of Florida state trademark proceedings were false or misleading, he does not have

cause of action under 15 U.S.C. § 1120, which by its own terms pertains exclusively to USPTO proceedings. Such misrepresentations would instead be handled at the state level, where specific remedies exist. See § 495.121, F.S. (Florida law imposing liability for making false or fraudulent representations while registering for a trademark with the Florida Department of State).

2 It does not appear that Defendant Zelcs herself owns the Florida trademark – it is owned by the HOA. See (Doc. 3-3). Second, to the extent that Plaintiff challenges Defendant’s opposition to his trademark application currently pending at the USPTO, his claim likewise fails. The statute here provides for civil liability against those who procure registration of

a trademark at the USPTO – not those opposing another’s person or entity’s application. Third, to the extent Plaintiff is attempting to bring a claim against Defendant for her own USPTO registration, the allegations do not clearly identify that a trademark has actually been procured – a requirement to state a claim under 15 U.S.C. § 1120.

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Siamas v. Zelcs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/siamas-v-zelcs-flmd-2025.