The complaint

Reflex MD, Inc. v. Dynamic Trading Enterprises, LLC, No. 1:26-cv-27682-JEM (S.D. Fla., Miami Division), was filed October 29, 2026 (25 pages, with two exhibits). The docket assigns the case to Judge Jose E. Martinez. The plaintiff is Reflex MD, Inc., a Delaware corporation that the complaint says offers semaglutide, a GLP-1 weight-loss pharmaceutical, through its telehealth platform at reflexmd.com. The defendants are Dynamic Trading Enterprises, LLC, a Pennsylvania limited liability company doing business as Join Layla, which the complaint says has operated a telehealth platform selling semaglutide at joinlayla.com since about 2022, and Gabriel Vaturi, also known as Gabriel Zion Vaturi, whom the complaint describes as a principal of the company residing in Broward County, Florida. The complaint says the two companies are competitors. Reflex MD demands a jury trial. (Compl. caption; paras. 1 to 4, 12, 40; Docket.)

The works

The complaint identifies two registered works, each with an effective registration date of September 17, 2026: "ReflexMD Website Text and HTML Code-2023 Version," Registration No. TX 9-639-199, which it describes as a human-authored HTML literary work, and "Reflex MD, Inc.'s Website (2023)," Registration No. TX 9-639-202, which it says covers the website's selection, coordination, and arrangement of text and photographs. It alleges Reflex MD owns both through written assignment. The Copyright Office public records for both registrations list Reflex MD, Inc. as claimant by written agreement, a 2023 completion year, and first publication on September 30, 2023. The certificate for TX 9-639-202 attached to the complaint excludes photographs and artwork from the claim. (Compl. paras. 42 to 44, 57 to 61; Exs. A, B.)

What the complaint alleges

The complaint alleges Reflex MD commissioned and created its website in 2023, and that Dynamic Trading Enterprises, whose earlier joinlayla.com website it says was in no way similar, later copied substantial portions of the Reflex MD website's protected text, HTML, and appearance and used them on its own competing website without authorization. It says Reflex MD first learned of possible copying on or about November 3, 2023, and that the company adopted the layouts, visual elements, text, and ordering flow of the Reflex MD website in or about September 2023. It alleges, on information and belief, that the company copied protectable portions of the site's HTML and/or CSS code. It alleges the company promoted the accused site through Facebook advertisements linking to it. After Reflex MD demanded in early December 2023 that the company stop, the complaint says, the company discontinued, removed, and/or ceased displaying the copied content. (Compl. paras. 15, 23 to 25, 32, 37, 47 to 49, 103.)

The complaint alleges the 2023 Reflex MD website carried copyright management information, including a copyright notice identifying Reflex MD as the copyright owner, and that Dynamic Trading Enterprises intentionally omitted, concealed, or altered it in copying the content. It alleges Gabriel Vaturi owned and directed the company and controlled decisions on the development, content, and launch of the accused version of the joinlayla.com website, and alleges, on information and belief, that he knowingly directed or approved the use of portions of the Reflex MD website. (Compl. paras. 71 to 73, 117 to 119.)

Counts and relief

  • Count I, copyright infringement of the HTML work under 17 U.S.C. 106 and 501, by Reflex MD against Dynamic Trading Enterprises. (Compl. paras. 41 to 55.)
  • Count II, copyright infringement of the website compilation under 17 U.S.C. 106 and 501, by Reflex MD against Dynamic Trading Enterprises. (Compl. paras. 56 to 69.)
  • Count III, removal of copyright management information under 17 U.S.C. 1202(b)(1) and, to the extent copies were distributed or displayed with knowledge that the information had been removed or altered, 17 U.S.C. 1202(b)(3), by Reflex MD against Dynamic Trading Enterprises. (Compl. paras. 70 to 76.)
  • Count IV, tortious interference with advantageous business relationships, by Reflex MD against Dynamic Trading Enterprises. (Compl. paras. 77 to 83.)
  • Count V, trade dress infringement and false designation of origin under section 43(a) of the Lanham Act, 15 U.S.C. 1125(a), by Reflex MD against Dynamic Trading Enterprises. (Compl. paras. 84 to 100.)
  • Count VI, unfair competition under the Florida Deceptive and Unfair Trade Practices Act, Fla. Stat. 501.204, by Reflex MD against Dynamic Trading Enterprises. (Compl. paras. 101 to 107.)
  • Count VII, unfair competition under Florida common law, by Reflex MD against Dynamic Trading Enterprises. (Compl. paras. 108 to 115.)
  • Count VIII, contributory copyright infringement, by Reflex MD against Gabriel Vaturi. (Compl. paras. 116 to 122.)
  • Count IX, vicarious copyright infringement, by Reflex MD against Gabriel Vaturi. (Compl. paras. 123 to 126.)

On Counts I and II, Reflex MD seeks actual damages, including the reasonable fair market value of a license, and the company's profits under 17 U.S.C. 504(b), interest, costs, recoverable attorneys' fees, and other equitable relief. On Counts VIII and IX, it asks that Gabriel Vaturi be held jointly and severally liable with the company for actual damages and recoverable profits under 17 U.S.C. 504(b), with fees and costs under 17 U.S.C. 505, interest, and other relief. Count III seeks actual damages and profits or statutory damages, costs, and fees under 17 U.S.C. 1203. Count V seeks profits, actual damages, and costs under 15 U.S.C. 1117(a) and an accounting. Counts IV, VI, and VII seek compensatory or actual damages, including lost profits, with interest and costs, and Count VI also seeks attorney's fees under Fla. Stat. 501.2105 and 501.211(2). (Compl. pp. 11 to 12, 14 to 16, 20 to 25.)