"In exchange for a loan in the amount of $150,000 from AXL, which VHT has not repaid, VHT agreed, inter alia, to a contingent assignment of the VHT AMPLIFICATION and VHT trademarks and the goodwill appertaining thereto. On May 7, 2008, the contingent assignment becam an actual assignment when VHT defualted on the loan. AXL subsequently recorded its ownership of the VHT AMPLIFICATION trademark and the goodwill appertaining thereto by filing the assignment in the U.S. Patent and Trademark Office. Despite AXL's repeated demands that VHT cease using the VHT AMPLIFICATION and VHT trademarks and transfer all the goodwill in the trademarks, VHT continues to use the VHT AMPLIFICATION and VHT trademarks. Upon information and belief, VHT's continued use of the VHT AMPLIFICATION and VHT trademarks constitues trademark infringement and unfair competition in violation of laws of the United States and the State of California...."