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Case 2:15-cv-00630-RJS Document 2 Filed 09/02/15 Page 1 of 13

JUSTIN D. HEIDEMAN (USB No. 8897)


JUSTIN R. ELSWICK (USB No. 9153)
HEIDEMAN & ASSOCIATES
2696 North University Avenue, Suite 180
Provo, Utah 84604
Telephone: (801) 472-7742
Facsimile: (801) 374-1724
Email: jheideman@heidlaw.com
jelswick@heidlaw.com
Attorneys for Plaintiffs Master Strategies, LLC and AAM Investments, LLC

IN THE UNITED STATES DISTRICT COURT IN AND FOR


THE DISTRICT OF UTAH, CENTRAL DIVISION
______________________________________________________________________________
MASTER STRATEGIES, LLC, a Florida
limited liability company, AAM
INVESTMENTS, LLC, a Nevada limited
liability company,

COMPLAINT

Civil No. ___________________

Plaintiff,

Judge ______________________

v.
RJ WORLDWIDE, LLC, a Texas limited
liability company d/b/a/ SKINNY BODY
CARE, and BENJAMIN GLINSKY, an
individual,
Defendants.
Plaintiffs Master Strategies, LLC and AAM Investments, LLC. by and through
undersigned counsel, hereby complains and alleges against Defendants RJ Worldwide, LLC
d/b/a Skinny Body Care and Benjamin Glinsky, as follows:
PARTIES, JURISDICTION AND VENUE
1.

Plaintiff Master Strategies, LLC (Master Strategies) is a duly organized Florida limited

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liability company with a principal place of business located at 6142 Little Lake Sawyer
Drive ,Windermere, Florida 34786.
2.

Plaintiff AAM Investments, LLC. (AAM) is a duly organized Nevada limited liability
with a principal place of business located at 1741 Sand Storm Dr., Henderson, Nevada
89074, which does business in Utah, which has since been accepted and acknowledged
by the United States Patent and Trademark Office.

3.

Defendant Benjamin Glinsky (Glinksy) is a resident of Florida, and the chief executive
officer of a network marketing company named RJ Worldwide, LLC, d/b/a Skinny Body
Care (Glinsky Companies), with a principal place of business located at 3634 Long
Prairie Road, Suite 108-113, Flower Mound, Texas.

4.

This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 inasmuch as this
case arises under the Constitution, laws, or treaties of the United States.

5.

This Court also has supplemental subject matter jurisdiction over any pendent state
claims Plaintiff may wish to bring, or has brought, pursuant to 28 U.S.C. 1367.

6.

Venue is proper in this Court under 28 U.S.C. 1391(b).

7.

This action involves a claim for damages arising from: (1) violations of 15 U.S.C. 1111 et
seq. (the Trademark Act), (2) a breach of contract claim that was entered into in the
State of Utah, and that was to be performed in the State of Utah, and (3) other related
claims.
GENERAL ALLEGATIONS

1.

Master Strategies obtained a trademark for the name Skinny Fiber and registered that
trademark (the Trademark) on March 9, 2010.

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2.

On June 15, 2015, Master Strategies filed a Combined Declaration of Use and
Incontestability under Sections 8 & 15 of the Trademark Act.

3.

Master Strategies is the sole owner of the Trademark, and has never conveyed ownership
of the Trademark to any third party.

4.

In connection with the Trademark, Master Strategies owned, and continues to own, a
weight-loss formula (the Formula).

5.

In Summer/Fall of 2010, Master Strategies licensed the Trademark and the Formula to its
individual members, Travis Beauchesne (Beauchesne), a resident of Utah, and to John
Ziglar (Ziglar), a resident of Florida.

6.

Master Strategies retained ownership of the Trademark and Formula. Beauchesne and
Ziglar only obtained licenses for the use of the Trademark and the Formula subject to
their obligations to pay royalties to Master Strategies from the proceeds derived from any
licensing thereof.

7.

Beauchesne, working with Iclick Promotions, LLC (Iclick) (a Utah limited liability
company partially owned by Beauchesne) began developing a marketing strategy and
marketing materials for the marketing of product and obtained from Master Strategies a
supply of inventory bottles containing pills that incorporated the Formula.

8.

Pursuant to the arrangement between Beauchesne and Iclick, Iclick and Beauchesne
expended significant funds to develop a marketing strategy and leads, and to create
domain names (including skinnyfiber.com) and other materials associated with marketing
the product.

9.

The plan between Master Strategies, Iclick and Beauchesne was that Iclick, acting

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together with Beauchesne, would market and sell the product and pay Master Strategies a
licensing fee for the use of the Formula and the Trademark (which remained the property
of Master Strategies).
10.

In the Fall of 2010, Beauchesne initiated discussions with Stephen Matthew Morrow
(Morrow) to explain his plans for monetizing the use of the Trademark and the
Formula.

11.

Morrow then initiated discussions with an acquaintance, Glinsky, who was in the
marketing business and had developed software and systems to market personal use
products, including multi-level marketing (MLM).

12.

Beauchesnes initial objective was to engage Glinsky as a provider of marketing and


MLM expertise. Discussions proceeded, and Glinsky expressed an interest in becoming
part of a joint business arrangement to market the Trademark and the Formula.

13.

The parties exchanged emails regarding a possible business relationship and met at
Glinskys home in Encinitas, California on October 13, 2010.

14.

In order to reach an accord with Glinsky, Beauchesne had to address his agreement with
Iclick.

15.

After discussion with Master Strategies, it was decided that Iclick would not be the
marketer of the Skinny Fiber product, and it was agreed that Iclick would receive a
reimbursement of some of its costs already expended.

16.

By email dated October 14, 2010, Morrow or Glinksy, without the input of Beauchesne,
drafted and circulated a short agreement.

17.

This draft agreement included a provision that had Iclick transfer to Glinsky the

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Trademark, certain internet domains, an inventory of Skinny Fiber product, and


marketing materials (which marketing materials, according to the draft agreement,
included creative email links, creative banners and additional email creatives).
18.

Beauchesne rejected the draft prepared. The final agreement ultimately reached by the
parties (described below) does not transfer the Trademark; it transfers only the inventory,
the domain names and the creative materials.

19.

On or about October 22, 2010, Glinsky, Beauchesne and Morrow concluded and signed a
final agreement (the Final Agreement.)

20.

The Final Agreement is by and between Beauchesne, Morrow and Glinsky individually.

21.

Master Strategies, the owner of the Trademark and Formula, was not a party to the Final
Agreement.

22.

Under the Final Agreement, Glinsky agreed to pay $12,000 for the transfer of (1) an
inventory of Skinny Fiber bottles containing pills that incorporated the Formula, (2)
certain domain names (including skinnyfiber.com) and (3) other creative materials.

23.

Conspicuously absent from the Final Agreement was any mention of the Skinny Fiber
trademark owned by Master Strategies.

24.

At the direction of Beauchesne, Glinsky wired $12,000 on October 20, 2010 to Iclick, to
reimburse the costs associated with the inventory of bottles, the domain names and the
other creative materials.

25.

No payment was made to Master Strategies (the owner of the Trademark and Formula),
and Master Strategies was not a signatory to the Final Agreement.

26.

In fact, Master Strategies was to be paid licensing fees by Beauchesne for the use of the

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Formula and the Trademark out of his profits from the joint enterprise contemplated by
the Final Agreement.
27.

The Final Agreement also contained additional provisions to compensate Beauchesne and
Morrow as follows:
(a)

According to the fifth paragraph of the Final Agreement, Beauchesne and Morrow
were entitled to a royalty payment of from $2.50 to $4.00 per bottle of product for
the first 60 days up to a maximum of $50,000. One of the purposes of this
paragraph was to fully reimburse Iclick for costs expended in development and
marketing of the product. This per bottle royalty could be continued only if
Beauchesne and Morrow were responsible for 10% of product sales.

(b)

Beauchesne and Morrow, according to the sixth paragraph of the Final


Agreement, were entitled to a separate compensation for 10% of the profits of the
joint enterprise. This was to be computed based on the assumption that $2.50
represented the per bottle profit to the joint enterprise. This additional royalty
could exceed $20,000 per month only if Beauchesne and Morrow were
responsible for a specified level of the joint enterprises sales. According to the
Agreement, [t]he intention of the company is to develop additional products to
be sold through the net, and the royalty was to apply to sales of all such product.

(c)

According to the sixth paragraph of the Final Agreement, Beauchesne and


Morrow, were entitled to a separate compensationBeauchesne and Morrow
were entitled to permanently-grandfathered preferred positions in the MLM
program of the joint enterprise.

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Case 2:15-cv-00630-RJS Document 2 Filed 09/02/15 Page 7 of 13

(d)

Finally, paragraphs three and four of the second page of the Final Agreement
provide that Beauchesne and Morrow and can earn an additional compensation by
enrolling additional participants in the MLM program.

(e)

According to paragraph 3 of the second page of the Final Agreement, the parties
agreed to act in good faith.

28.

The Final Agreement did not require that Beauchesne or Morrow engage in specific acts;
rather, the Final Agreement merely grants additional compensation, over and above the
base compensation payable, to Beauchesne and Morrow if they chose engage in specified
activities.

29.

Sometime after the date of the Final Agreement, Glinsky organized and created the
Glinsky Companies.

30.

The Glinsky Companies began marketing the product and building an MLM organization
of distributors to sell product.

31.

Glinsky currently operates Skinny Body Care as a network marketing company, selling
Skinny Fiber and other health products through a network of independent distributors.

32.

By email dated January 3, 2011, Glinsky contacted Beauchesne and asked where he
should send money resulting from sales.

33.

Despite this request, no funds were ever sent.

34.

These funds arose as a result of pre-launch sales from December, 2010.

35.

The MLM was set to officially open on January 20, 2011.

36.

By email dated January 21, 2011, Glinsky summarily disavowed any agreement among
the parties, saying only sorry it did not work out. Glinsky, however, mentions that he

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would like to work something out on this deal, and move on.
37.

This notice was given less than 24 hours after the official launch of the MLM, at which
time Glinsky knew that the joint enterprise was successful.

38.

By email dated January 24, 2011 Beauchesne responded: lets talk about how we can
unwind it [i.e. the Final Agreement], and also stated that he had not received the
commission check for December or the royalty payments in accordance with the Final
Agreement.

39.

Because Glinsky summarily and unilaterally attempted to terminate the Final Agreement,
Beauchesne and Morrow were denied any opportunity to perform and earn additional
compensation under the Final Agreement.

40.

Unbeknownst to Beauchesne, Glinsky and the Glinsky Companies began to actively


market product, using the Trademark, without payment or notice to Beauchesne.

41.

Beauchesne followed up and attempted email and telephone contact with Glinsky to
discuss his attempted termination of the Final Agreement.

42.

Beauchesne and Master Strategies subsequently retained an attorney to serve Glinsky


with a formal demand letter to cease and desist.

43.

After several attempts to deliver the letter, counsel for Beauchesne and Master Strategies
discovered that Glinsky had left his residence in California with no notice.

44.

By letter dated June 27, 2011, Beauchesnes then-lawyer demanded that Glinsky honor
the License Agreement or cease using the Trademark.

45.

In October of 2013, Beauchesne discovered a business listing for Skinny Fiber in Utah.
Beauchesne discovered that the address for the business was at a manufacturing facility

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Case 2:15-cv-00630-RJS Document 2 Filed 09/02/15 Page 9 of 13

he had introduced to Glinsky in 2010.


46.

Beauchesne visited the facility and discovered that Glinsky and his companies were
conducting business and using a Utah address.

47.

The location was owned by a company named Nova Ship, a company to whom
Beauchesne had introduced Glinsky as a possible producer of bottles containing the
product.

48.

An employee of Nova Ship told Beauchesne that Skinny Fiber was their biggest customer
and that they had manufactured well over 600,000 bottles of Skinny Fiber.

49.

Nova Ship is only one of the manufacturers of product and so the total sales of Skinny
Fiber could be multiplied many times over.

50.

In early October, 2013, Beauchesne called the owner of Nova Ship, who acknowledged
his company was manufacturing Skinny Fiber; this individual also stated that Glinsky had
told him that Glinsky and Beauchesne were still working together.

51.

The owner of Nova Ship advised Beauchesne that Glinsky had changed the formulation,
yet kept the original-designed labels and the Skinny Fiber Trademark.

52.

On October 15, 2013, Beauchesne hired a private investigator and discovered that
Glinsky had relocated his home (from which Glinsky conducted his business operations)
to Florida.

53.

Beauchesne changed law firms, and, by letter dated October 17, 2013, Beauchesnes
lawyer demanded, again, that payment be made and that Glinsky desist using the Skinny
Fiber Trademark.

54.

Glinsky did not respond to the letter.

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Case 2:15-cv-00630-RJS Document 2 Filed 09/02/15 Page 10 of 13

55.

On May 7, 2014, Glinsky, when questioned about his highly-successful MLM and
marketing of Skinny Fiber, stated in a YouTube video that I bought it [Skinny Fiber].

56.

On September 26, 2014, Glinsky also stated in a separate YouTube video that his
company had paid out millions of dollars in commissions and made millions of bottles
of product.

57.

Glinsky and the Glinsky Companies have never had a contract of any kind or nature with
Master Strategies for use of the Trademarkand neither Beauchesne nor Ziglar (the
members of Master Strategies) have ever agreed to the transfer of the Trademark.

58.

Furthermore, Glinsky has defaulted on the royalty and compensation provisions of the
Final Agreement as those pertain to Beauchesne and Morrow and have prevented them
from earning additional compensation thereunder.

59.

Master Strategies discovered that on April 7, 2015, Glinsky and/or the Glinsky
Companies through their legal counsel fraudulently attempted to file a trademark
application for Skinny Fiber.

60.

The trademark application filed by Glinsky and/or the Glinsky Companies was properly
denied because the Trademark is held by Master Strategies.

61.

Counsel for Glinsky has asserted that the Final Agreement effectuated a transfer of the
ownership of Trademark, because the Trademark was part of the creative materials that
were transferred for payment of the $12,000.

62.

As noted above, the draft agreement providing for assignment of the Trademark which
was presented to Beauchesne was rejected.

63.

Beauchesne did not have authority to sell the Trademark to Glinsky because he was only

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a licensee of Master Strategies who is the actual owner of the Trademark, and neither
Beauchesne nor Ziglar ever consented to the transfer of the Trademark.
64.

As previously noted, the Trademark was not held by any of the three individual parties to
the Final Agreement and could not be transferred under the Final Agreement in any
event.

65.

Beauchesne has legally assigned all of his interest in any actual or potential claims
against Defendants Glinsky and the Glinsky Companies to Plaintiff AAM pursuant to a
written assignment agreement.

66.

Defendants Glinsky and the Glinksy Companies have infringed upon Master Strategies
Trademark. Plaintiff is therefore entitled to recover: (1) Defendants profits, (2) any
damages sustained by the Plaintiff, and (3) the costs of the action as provided by 15
U.S.C. 1117 in an amount to be proven at trial.

67.

Defendant Glinsky has materially breached the terms of the Final Agreement causing
damage to Beauchesne in an amount not less than $200,000 or in an amount to be proven
at trial.
FIRST CAUSE OF ACTION
(15 U.S.C. 1114(1) - Defendants Glinsky and the Glinksy Companies)

68.

Plaintiffs incorporate the preceding paragraphs as if fully restated.

69.

Master Strategies Trademark is a valid, protectable trademark.

70.

Master Strategies owns the Trademark.

71.

Defendants Glinsky and the Glinksy Companies have used the Trademark without the
consent of Master Strategies in a manner that is likely to cause confusion among ordinary
consumers as to the source, sponsorship, affiliation, or approval of the goods.
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72.

As a result of Defendants violation, Plaintiff Master Strategies is entitled to recover: (1)


Defendants profits, (2) any damages sustained by the Plaintiff, and (3) the costs of the
action as provided by 15 U.S.C. 1117 in an amount to be proven at trial.
SECOND CAUSE OF ACTION
(Breach of Contract - Defendant Glinsky)

73.

Plaintiffs incorporate the preceding paragraphs as if fully restated.

74.

The October 22, 2010 Final Agreement constitutes a legally enforceable contract.

75.

Beauchesne performed all initial obligations under the Final Agreement.

76.

Defendant Glinsky has materially breached his obligations under the Final Agreement by
failing to pay Beauchesne any royalty income towards the agreed upon $50,000 and by
refusing to allow Beauchesne the opportunity to perform under the terms of Final
Agreement to earn additional royalty income.

77.

As a result of Defendant Glinskys breach of contract, Plaintiff AAM is entitled to


recover in an amount to be proven at trial.
THIRD CAUSE OF ACTION
(Breach of Implied Covenant of Good Faith and Fair Dealing Defendant Glinsky)

78.

Plaintiffs incorporate the preceding paragraphs as if fully restated.

79.

In Utah, the covenant of good faith and fair dealing inheres in every contract.

80.

Defendant Glinsky violated the implied covenant of good faith and fair dealings by:
(a)

summarily attempting to cancel the Final Agreement;

(b)

refusing to pay Beauchesne any of the royalties that were owed; and

(c)

refusing to allow Beauchesne the opportunity to further perform under the terms
of the Final Agreement;

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81.

Defendant Glinskys actions have damaged Beauchesne in an amount to be proven at


trial, which damages are assigned to Plaintiff AAM.
WHEREFORE, Plaintiffs demand judgment against Defendants as follows:
(a)

First Cause of Action - (U.S.C. 1114(1) - Defendants Glinsky and the Glinksy
Companies): (1) Defendants profits, (2) any damages sustained by the Plaintiff,
and (3) the costs of the action as provided by 15 U.S.C. 1117 in an amount to be
proven at trial.

(b)

Second Cause of Action - (Breach of Contract - Defendant Glinsky): Plaintiff is


entitled to recover in an amount to be proven at trial.

(c)

Third Cause of Action - (Breach of Implied Covenant of Good Faith and Fair
Dealing Defendant Glinsky): Plaintiff is entitled to recover in an amount to be
proven at trial.

(d)

Attorneys fees and costs of this action; and

(e)

Any other appropriate relief allowed under the law.

DATED September 2, 2015.


HEIDEMAN & ASSOCIATES
/s/ Justin R. Elswick
JUSTIN R. ELSWICK
Attorney for Plaintiffs Master Strategies, LLC and
AAM Investments, LLC

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Case
Case2:15-cv-00630-RJS
2:15-cv-00630-RJS Document
Document2-1
1 Filed
Filed09/02/15
09/02/15 Page
Page11ofof11

CIVIL COVER SHEET

JS 44 (Rev. 12/J2)

111e JS 44 civil cover sheet and the infom1ation contained herein neither replace nor supplement the filing and service ofpleadin!ls or other papers as required by law, except as
provided by local rules of court. This form, approved by rhe Judicial Conference of the United Stat~s in September 1974,ls requtred for the use of the Clerk ofComt for the
purpose of initiating the civil docket sheet. (SEE INSTRI. 'C110NS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS

DEFENDANTS

AAM Investments. a Nevada limited liability company

(b) County of Residence of First Listed Plaintiff

RJ Worldwide, LLC a Texas limited liability company d/b/a Skinny


Body Care, and Benjamin Glinsky

.Q!ru:!s Counjy_.,...JNu.Y"---~

County of Residence of First Listed Defendfll1t

(EXC!J'PT IN I.'.S. Pl.AIA'TIFF CASES)


NOTE:

(C) Attorneys (F/1711 Name. Addrm. and T~lephone !l'wnbe.)


Justin D. Heideman
Justin R. Elswick I Heideman & Associates 2696 N University Ave. Suite
180, Provo, Utah 84604 (801) 472-7742

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0 6 Multi district
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Cite the U.S. Civil Statute under which you ~rc filing (lJn nor citjurlsdlttlomtl #atutcstmlc.>w 4/l~rs/~~:

Vl. CAUSE OF ACTION ~2~8~U~.S~.C~-~1~33~1~----------------------------------------------------


Briefdescripti1m of cause:
Federal Trade Mark Infringement

VII. REQUESTED IN
0 CHECK If THIS lS A CLASS ACTION
UNDER RULE 23 . F.R.Cv.P.
COMPLAINT:
Vlll. RELATED CASE(S)

IF ANY

(See /nsi/1/Ciions):

JUDGE

DEMAND$
200,000.00

CHECK YES only if demanded in complaint:


JlJHY DEMAND:
0 Yes
)& No
-~DOCKET NUMBER

DATe

09/01/2015
FOR OFFICE USE ONl.Y
RECEIPT ff

-------- AhJOUNT

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Case: 2: 15-cv-00630
Assigned To : Shelby, Robert J.
Assign. Date: 9/2/2015
Description: Master Strategies et al v. RJ Worldwide et al