RAEN is the owner of U.S. Registered Trademark No. 5,016,634 for REMMY, the name of its top-selling eyewear style. The lawsuit alleges that Warby Parker’s use of REMY in association with its own products constitutes an alleged infringement of RAEN’s federally registered trademark for REMMY. In addition to the use of the name, Warby Parker appears to have paid for search engine advertising of its product by using RAEN’s REMMY trademark. Initial reviews by RAEN found that Warby Parker appears to have named other of its eyewear products after other existing third-party trademarks or individuals associated in the eyewear industry but not associated with Warby Parker. RAEN intends to argue that this pattern of using others’ names is calculated by Warby Parker to drive internet traffic their direction to increase sales.