On September 27, 2021, Halo Composites, LLC d/b/a Halo EFX (“Halo”), and Matthew Fontaine (“Mr. Fontaine”) (collectively, “Plaintiffs”), represented by Cole Younger Carlson of GrayRobinson, P.A., filed a personal injury lawsuit against Mark Figliozzi, (“Defendant”), seeking compensatory and punitive damages along with prejudgment and post-judgement interests among other relief for the alleged defamation of Halo due to which the Plaintiffs allegedly suffered actual harm. This case was filed in the United States District Court in the Southern District of Florida with Judge Aileen M. Cannon presiding.
In the complaint, Plaintiffs alleged that, “Mr. Fontaine independently created and invented Halo’s proprietary peelable paint composition over the course of more than a year of research and development, working after hours” and “Fontaine did not steal this technology from any other company, corporation, or individual but rather painstakingly developed Halo’s formulation in his own garage”. The Plaintiffs then alleged that, “On May 27, 2021, Halo sued Defendant’s company, RAAIL, for infringement of the Halo Patents in the case styled Halo Composites, LLC v. Raail Holdings Corporation d/b/a RAAIL et al” and “Alan Nichols is a named defendant in the Halo Patent Litigation because he directly or indirectly infringed each of the Patents-in-Suit that form the basis of the Halo Patent Litigation and for no other reason.”
Plaintiffs further alleged that, “Alan Nichols made the following post on Facebook (the “Nichols Post”) about the Halo Patent Litigation” and “Mr. Figliozzi, in reply to Mr. Nichols’ post, made several defamatory comments about Mr. Fontaine and Halo directed at specific individuals” The Plaintiffs then alleged that, “Mr. Figliozzi made the assertion that he knew each of the Nichols Post Comments were true and public information when he knew they were false and not public based on his extensive experience with Mr. Fontaine and Halo over the years” and “Defendant’s statements have caused third parties to question the character of Mr. Fontaine and Halo as a company, suggesting that greed was the impetus of the Halo Patent Litigation.”
Plaintiffs also alleged that, “Defendant’s statements were published on Facebook to third parties; specifically, the “friends” of Alan Nichols and to those individuals that Defendants replied to individually. These statements are accessible to anyone with access to Mr. Nichols’ Facebook page” and “Defendant made these statements maliciously while knowing they were false and with the intent to cause harm to Mr. Fontaine and his company financially.”
There are five claims of relief laid down by Plaintiffs. The first claim is for alleged defamation. The second claim is for alleged defamation per se. The third claim is for alleged commercial disparagement and the fourth claim is for alleged civil conspiracy. The fifth claim is for the alleged tortious interference with business relations.
In its prayer for relief, Plaintiffs requested the court for compensatory damages in an amount to be determined at trial but no less than $75,000.01. Plaintiff further requested the court for punitive damages in the amount of at least $1,000,000.00 as a result of Defendant’s specific intent to harm Plaintiffs and the actual harm inflicted on Plaintiffs along with reasonable attorneys’ fees and costs, prejudgement and post-judgement interest, and any other relief the court deems just.
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Pending - Other Pending
Aileen M. Cannon
Halo Composites LLC a Florida limited liability company doing business as Halo EFX
Cole Younger Carlson
Attorney at GrayRobinson, P.A.
401 E Jackson St, Suite 2700
Tampa, FL 33602
(#3) Summons Issued as to Mark Figliozzi. (jc) (Entered: 09/27/2021)
Civil Cover Sheet
Docket(#4) Clerks Notice to Filer re: Electronic Case. Alias (Halo EFX) Not Added. The Filer failed to add the alias information for the party(ies). The correction was made. It is not necessary to re-file this document. (jc) (Entered: 09/27/2021)Read MoreRead Less
Docket(#3) Summons Issued as to Mark Figliozzi. (jc) (Entered: 09/27/2021)Read MoreRead Less
Docket(#2) Clerks Notice of Judge Assignment to Judge Aileen M. Cannon. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Shaniek M. Maynard is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website. (jc) (Entered: 09/27/2021)Read MoreRead Less
Docket(#1) COMPLAINT against All Plaintiffs. Filing fees $ 402.00 receipt number AFLSDC-15044449, filed by Halo Composites LLC, Matthew Fontaine. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Civil Cover Sheet, #4 Summon(s))(Carlson, Cole) (Entered: 09/27/2021)Read MoreRead Less
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