Robinhood Markets and its founder Vladimir Tenev have taken to Court the owners of VLADTENEV.COM.

The relevant complaint was filed on March 20, 2026 at the California Northern District Court. The defendants are LIBIN ZHU (“Zhu”); DYNADOT INC. (“Dynadot”); and DOES 1-10 (“Does”).

Mr Tenev and Robinhood seek to stop the ongoing infringement of Mr. Tenev’s trademark, name, and likeness, which he has used extensively in his personal capacity, and which Robinhood has used extensively to promote its business.

The plaintiffs have brought the action based on the defendants’ past, current, and planned use of the domain name VLADTENEV.COM and allege claims for federal trademark infringement and unfair competition under Sections 32(1) and 43(a) of the Trademark Act of 1946 (the “Lanham Act”), 15 U.S.C. §§ 1114(1) and 1125(a), for cybersquatting under the Anti-Cybersquatting Consumer Protection Act, 15 U.S.C. § 1125(d)(1), and for substantial and related claims of unfair competition, common law trademark infringement, and violation of Mr. Tenev’s rights of personality arising under California law.

Mr. Tenev is the owner of common law trademark rights in his name VLAD TENEV, which is central to the action.

The plaintiffs alleged that the defendants’ registration and use of the Disputed Domain, which fully incorporates Mr. Tenev’s VLAD TENEV mark, is a bad faith attempt to exploit Mr. Tenev’s and Robinhood’s goodwill and reputation in the mark for commercial gain.

The defendants’ use of the VLAD TENEV mark is identical to the Disputed Domain, which is simply Mr. Tenev’s name with the addition of the functional ending “.com.” Upon information and belief, Defendants’ actions in choosing and registering the Disputed Domain were intentional, with actual and constructive knowledge of, Mr. Tenev, Robinhood, and the VLAD TENEV mark.

Defendants’ unauthorized uses of the VLAD TENEV mark are likely to mislead or have actually misled consumers into believing that Defendants’ Disputed Domain is sponsored, licensed, approved by, or are otherwise associated or affiliated with, Plaintiffs and the VLAD TENEV mark.

Upon information and belief, the defendants adopted and commenced use of, use, and plan to continue to use the VLAD TENEV mark with the intent and purpose of trading upon the extensive goodwill built up by the plaintiffs in the VLAD TENEV mark, and to reap the benefits of the years of effort invested by Plaintiffs to create public recognition of the VLAD TENEV mark and the services offered thereunder.

The plaintiffs requests that judgment be entered in their favor against the defendants as follows:

1. For an order and judgment that Defendants have infringed the VLAD TENEV mark in violation of Mr. Tenev’s rights under federal law, common law, and/or California law;

2. For an order and judgment that Defendants have unfairly competed with Plaintiffs in violation of Plaintiffs’ rights under 15 U.S.C. § 1125(a) and California law;

3. For an order and judgment that Defendants have acted in bad faith, willfully, intentionally, and/or in reckless disregard of Plaintiffs’ rights;

4. For an order permanently enjoining and restraining Defendants and all persons in active concert or participation with them:

1. From using or registering the VLAD TENEV mark or any other trademark, tradename, domain name, or other designation that comprises or includes “VLAD TENEV;”
2. To immediately transfer all domain names that include “VLAD TENEV” to Plaintiffs, including but not limited to <VLADTENEV.COM>; and
3. From engaging in conduct intended to mislead or confuse consumers such as that specified in this complaint or other similar advertisements;

5. For an order requiring Defendants to permanently remove all references to “VLAD TENEV” or any other trademark, tradename, domain name, or other designation that comprises or includes “VLAD TENEV” from any website or social media platform;

6. For an order requiring Defendants to permanently cease use of Mr. Tenev’s name, image, or likeness in any capacity;

7. For an order requiring Defendants to file with the Court and serve upon Plaintiffs within fifteen (15) days after issuance of any injunction, a report in writing under oath setting forth in detail the manner and form in which Defendants have complied with the injunction.

8. For an order awarding Plaintiffs:

1. All profits derived by Defendants’ wrongful acts complained of herein;
2. All damages sustained by reason of Defendants’ wrongful acts complained of herein;
3. Treble the amount of actual damages suffered by Plaintiffs under 15 U.S.C. § 1117(a);
4. Restitution for Defendants’ unfair business practices pursuant to Cal. Bus. & Prof. Code §§ 17200, et seq.;
5. Punitive and exemplary damages in an amount sufficient to deter and punish Defendants for their willful and wrongful acts;
6. Their costs incurred in this action;
7. Their reasonable attorneys’ fees pursuant to 15 U.S.C. § 1117(a); and
8. Pre-judgment and post-judgment interest;

9. For such other and further relief as the Court may deem appropriate.