On October 16, 2026, Reveal Technology, Inc., a Bozeman, Montana defense-technology company, filed an Original Complaint in the U.S. District Court for the Middle District of Florida, Tampa Division. It sued two foreign companies that sell drone-mapping software under the name FARSIGHT VISION: FarsightVision OÜ of Estonia and FarsightVision LLC of Ukraine. The case is Reveal Technology, Inc. v. FarsightVision OÜ and FarsightVision LLC, No. 8:26-cv-03152-VMC-AEP, assigned to U.S. District Judge Virginia M. Hernandez Covington and U.S. Magistrate Judge Anthony E. Porcelli.
The Complaint is a model of how a U.S. brand owner can bring a foreign competitor into a Florida courtroom. The key hook is a trade show. FarsightVision exhibited under the FARSIGHT VISION name at SOF Week 2026 at the Tampa Convention Center (May 18–22, 2026), the annual conference of U.S. Special Operations Command, and was a finalist in the event’s pitch competition. Reveal sent cease-and-desist letters during that same week. When FarsightVision kept going, including at the AUSA Annual Meeting in Washington, D.C. on October 12–14, 2026, Reveal sued days later.
| At a glance | |
|---|---|
| Court | M.D. Fla., Tampa Division |
| Filed | October 16, 2026 (signed October 15) |
| Plaintiff’s counsel | Charles A. Wallace, Scale LLP, San Francisco (pro hac vice pending) |
| Counts | (I) infringement of a registered mark, § 1114(1); (II) unfair competition and false designation of origin, § 1125(a)(1)(A); (III) cybersquatting, § 1125(d); (IV) order refusing registration, § 1119 |
| Key relief | Permanent injunction, transfer of farsightvision.com, refusal of the FARSIGHT VISION application, profits, treble damages, up to $100,000 in statutory damages for cybersquatting, and attorney’s fees |
| Supporting evidence | Declaration of John Karol (actual confusion) and Exhibits A–H |
| Jury | Demanded on all issues triable by jury |
The parties as pleaded
| Who they are | |
|---|---|
| Reveal Technology, Inc. (plaintiff) | A Delaware corporation based at 2425 Technology Blvd. W., Bozeman, Montana. Its flagship product, FARSIGHT, turns surveillance video into 2D and 3D models “in moments,” with measurement, analytic and autonomy tools. It exports map tiles and data layers to command-and-control platforms, including ATAK. Customers include Department of Defense units such as MARSOC (Marine Forces Special Operations Command), other U.S. and allied government users, and public-safety agencies. It markets through revealtech.ai, direct contact with government program offices, social media and defense trade shows, including SOF Week. |
| FarsightVision OÜ (“FSV Estonia”) | An Estonian private limited company registered in Tallinn. It is the applicant for the U.S. FARSIGHT VISION and FSV applications and the registrant of farsightvision.com. |
| FarsightVision LLC (“FSV Ukraine”) | A Ukrainian limited liability company (EDRPOU code 45562705) registered in Lviv. |
| Relationship between the defendants | Pleaded on information and belief as a single integrated business under common ownership and control, sharing founders (Viktoriia Yaremchuk and Volodymyr Nepiuk), branding, products, a website and a LinkedIn page. Each is alleged to be the agent and alter ego of the other, and they are sued as jointly and severally liable. |
| Founding and U.S. ties | Founded in November 2023, “more than four years after” Reveal’s first use. Raised a €7.2 million seed round in February 2026 led by U.S.-based Axon Enterprise. Its CTO, Mr. Nepiuk, is alleged on information and belief to live and work in Spokane, Washington. |
Note that neither defendant is a U.S. company. FarsightVision LLC is a Ukrainian entity, not a U.S. subsidiary. That is why the Complaint relies so heavily on the Tampa trade show, Rule 4(k)(2) and alternative service under Rule 4(f)(3).
The FARSIGHT brand: from start-up to Army program
Reveal’s case depends on how much goodwill the FARSIGHT name has built up in its market. Public sources show steady growth:
| Date | Milestone |
|---|---|
| December 2018 | Reveal Technology is founded by Garrett Smith, a former Marine Corps officer and Stanford graduate, with three colleagues |
| August 2020 | Reveal files four FARSIGHT-formative federal trademark applications (MOBILE, EDGE, NODE, XR) |
| 2021–2024 | Farsight goes into production with programs for the Army, Special Operations Command, the Marine Corps and some foreign militaries; fielded with the 82nd Airborne Division |
| December 2024 | $11.2 million Series A, led by Next Frontier Capital, with defy.vc and 8VC |
| July 2025 | $30 million Series B, led by Ballistic Ventures (Mandiant founder Kevin Mandia joins the board) |
| October 7, 2026 | $9.5 million U.S. Army delivery order for Farsight under a GSA IDIQ contract |
| October 12, 2026 | Launch of Farsight 2.0, adding a “global world model,” autonomous drone tasking and Nett Warrior integration |
What the product does matters for the confusion analysis. Farsight turns drone video into 3D terrain models on a soldier’s smartphone, without an internet connection, and adds line-of-sight, routing and measurement tools. FarsightVision’s FSV Platform does the same core job: it turns drone footage into orthophotos and 3D “digital twins” for military users. Two products that perform nearly the same function, sold under nearly the same name to the same type of buyer, are the strongest setting for a confusion finding.
The timing also matters. Farsight 2.0 launched less than two weeks before this post, and the Army order was announced days earlier. A brand owner whose program is expanding in front of the same buyers that a newer competitor is courting has a strong reason to act quickly, and a strong argument against any claim that it delayed.
FARSIGHT on the register: both sides’ filings
| Filing | Owner | Key dates | Status / significance |
|---|---|---|---|
| FARSIGHT MOBILE, EDGE, NODE, XR (Serial Nos. 90094586, 90094671, 90094697, 90094714) | Reveal | Filed Aug. 5, 2020 | EDGE and XR abandoned Apr. 27, 2021 after office actions went unanswered; not pleaded in the Complaint |
| FARSIGHT (standard characters, Class 9), Serial No. 98862849 | Reveal | Filed Nov. 20, 2024; registered Sept. 30, 2025 as Reg. No. 7,965,165 | Claims first use of Apr. 26, 2019. Covers distance-measuring apparatus and AR and AI software for processing video from drones, aircraft, sensor towers and wearable sensors into 2D maps and 3D models. Pleaded as prima facie evidence of validity and ownership |
| FARSIGHT, International Reg. No. 1832001 (Madrid Protocol) | Reveal | Registered Nov. 21, 2024, based on the U.S. application | Designates the European Union, Estonia, Ukraine and the United Kingdom, the defendants’ home markets |
| FARSIGHT VISION (composite, Class 9), Serial No. 99759402 | FSV Estonia | Filed Apr. 12, 2026 | Covers 3D scanners, terrain-modeling devices, drone video processing, GPS apparatus and related software. Refused in part under § 2(d) for likelihood of confusion with Reveal’s registration; still pending and not published |
| FSV (composite, Class 9), Serial No. 99759396 | FSV Estonia | Filed Apr. 12, 2026 | Pending; not published |
What the register shows.
- Reveal fixed an earlier gap. Its 2020 FARSIGHT-formative applications stalled, but its November 2024 application for FARSIGHT alone matured into a registration in September 2025, about seven months before FarsightVision filed. Because the registration claims a 2019 first-use date, Reveal can claim priority as of April 2019, if it can prove that use.
- The registration is not yet incontestable. It is about a year old, so FarsightVision can still attack it (for example, as descriptive). That is why the Complaint pleads common-law rights in Count II as a separate basis.
- The USPTO has already sided with Reveal. An examining attorney’s § 2(d) refusal does not bind the court, but the Complaint uses it to support willfulness and an “exceptional case” finding.
- Reveal protected the defendants’ home markets first. Its Madrid registration covers Estonia, Ukraine and the EU. If FarsightVision tries to register at home, Reveal is already on the register there.
Pre-suit enforcement of FARSIGHT
We found no earlier lawsuit, TTAB opposition or cancellation by Reveal over FARSIGHT. Before this case, its enforcement consisted of registrations and demand letters:
- Building the register (2024–2025): the U.S. application, the Madrid filing designating the EU, Estonia, Ukraine and the UK, and the September 2025 U.S. registration.
- Demand letters (May 2026): By letters dated May 20, 2026 (to FSV Estonia) and May 22, 2026 (to FSV Ukraine), Reveal asserted its FARSIGHT rights. It described the likelihood of confusion and the documented instances of actual confusion. It demanded that FarsightVision stop using FARSIGHT VISION, remove infringing references, cancel or stop using farsightvision.com and withdraw its U.S. applications. Both letters went out while FarsightVision was exhibiting at SOF Week in Tampa.
- The response: According to the Complaint, FarsightVision “did not comply with any of Plaintiff’s demands.” It kept the name and the domain, continued marketing to U.S. audiences and continued to pursue its application, even after the USPTO’s § 2(d) refusal.
The five months between the letters and the lawsuit undercut any claim that FarsightVision was taken by surprise. They also give Reveal its strongest evidence of willfulness: conduct that continued and expanded after written notice.
The allegations as pleaded
The Complaint’s factual background (Section IV) builds the case in eight steps:
| Section | Key allegations |
|---|---|
| A. Reveal and FARSIGHT | FARSIGHT provides “actionable intelligence in GPS-denied, network-constrained, and tactical cloud environments,” processes surveillance video into 2D and 3D models “in moments” and exports to ATAK. It has been sold continuously since April 26, 2019, to customers including MARSOC. |
| B. Reveal’s trademark rights | U.S. Reg. No. 7,965,165; International Reg. No. 1832001; substantial investment and goodwill among U.S. and allied military and public-safety purchasers. |
| C. Adoption of FARSIGHT VISION | The defendants were founded in November 2023. Their software converts drone imagery into 2D orthophotos and 3D “digital twins,” with object and change detection, works in “GNSS-denied environments” and integrates with ATAK. These are “the same functions, described in materially the same terms.” FARSIGHT is the dominant element of their name, and “VISION” is “a weak term in the field of computer-vision and imaging software.” FSV, FSV Platform, FSV Mapper and FSV App derive from the same name. On information and belief, the defendants knew of Reveal’s “well-known FARSIGHT product” when they adopted the name. |
| D. Use in U.S. commerce | Co-founders solicited U.S. defense contacts in California in 2025. The CTO reportedly lives in Spokane, Washington. FarsightVision exhibited at SOF Week 2026 in Tampa (Booth 5404, Accelerator Alley), with the mark on its banner, tablecloth, handouts and monitors, and was a pitch-competition finalist. It promoted the event on LinkedIn before and after. It appeared at Axon Week 2026 in Nashville, where the mark was shown on the main-stage screen. It publicized its €7.2 million Axon-led round in the U.S. and solicited business at AUSA 2026 (Oct. 12–14). It registered farsightvision.com through Amazon Registrar on January 14, 2024. The site is in English, has no geographic restrictions, offers “Request a demo” and “Contact Sales” forms and a customer login, and its terms of use do not exclude the U.S. It filed the U.S. applications on April 12, 2026, representing use or intent to use in U.S. commerce. |
| E. Actual confusion | In late 2025, a MARSOC representative asked Reveal’s Director of Mission Success, John Karol, about a change to Reveal’s website layout and user interface that the representative had seen on LinkedIn. Reveal had made no such change; the content belonged to FarsightVision. Supported by the Karol Declaration. Further confusion is alleged on information and belief. |
| F. Notice and continued conduct | Demand letters of May 20 and 22, 2026, were ignored. |
| G. Willfulness and exceptional case | Actual knowledge since May 2026 at the latest, and likely earlier. Use was expanded after notice, the application was pursued after the § 2(d) refusal, and nothing was done to avoid confusion. The Complaint argues the case “stands out” because the USPTO “has already found that a likelihood of confusion exists.” |
| H. Harm | Irreparable harm, including loss of control over goodwill, damage to U.S. customer relationships and erosion of distinctiveness. Monetary harm includes lost sales and the cost of corrective efforts. No adequate remedy at law. |
Jurisdiction and venue as pleaded
- Subject matter: 28 U.S.C. §§ 1331 and 1338(a)–(b), and 15 U.S.C. § 1121. The court’s power over the pending application comes from § 1119.
- FSV Estonia: specific jurisdiction under Florida’s long-arm statute for carrying on business in Florida (Fla. Stat. § 48.193(1)(a)(1)) and causing injury in Florida through solicitation and service activities there (§ 48.193(1)(a)(6)(a)). Both rest on the SOF Week booth and pitch. Due process is satisfied because FSV Estonia traveled to Tampa, rented and branded exhibit space and solicited U.S. customers. In the alternative, Reveal relies on Rule 4(k)(2), based on FSV Estonia’s contacts with the United States as a whole.
- FSV Ukraine: jurisdiction on the same bases, through its alleged single-enterprise relationship with FSV Estonia, and on information and belief that its personnel took part in SOF Week. Also Rule 4(k)(2), and the long-arm statute “through the acts of its agent and alter ego”.
- Venue: § 1391(b), because a substantial part of the events occurred in Tampa, and independently § 1391(c)(3), because neither defendant resides in the U.S. .
- Service: under Rule 4(f) and the Hague Service Convention, or by alternative means under Rule 4(f)(3).
The four counts
| Count | Statute | Core theory as pleaded | Remedies claimed |
|---|---|---|---|
| I. Federal trademark infringement | 15 U.S.C. § 1114(1) | Use of FARSIGHT VISION as a “colorable imitation” of the registered mark. The Complaint walks through the Frehling factors: an inherently distinctive registered mark; the dominant element is identical; the goods are “legally identical and actually identical in function”; the same customers, channels and advertising; adoption with knowledge; and actual confusion | Injunction (§ 1116); profits, damages, costs and up to treble damages (§ 1117(a)); destruction of materials (§ 1118); attorney’s fees |
| II. Unfair competition / false designation of origin | 15 U.S.C. § 1125(a)(1)(A) | Common-law rights from continuous use since April 26, 2019, senior to any rights of the defendants. The Karol Declaration is pleaded as “direct evidence” of deception | Same as Count I |
| III. Cybersquatting | 15 U.S.C. § 1125(d) | FARSIGHT was distinctive when farsightvision.com was registered (Jan. 14, 2024) and renewed. The domain is confusingly similar and used in bad faith to divert customers to competing goods, and was kept after the demand letters | Forfeiture or transfer of the domain (§ 1125(d)(1)(C)); statutory damages up to $100,000 (§ 1117(d)) |
| IV. Order directing refusal of registration | 15 U.S.C. § 1119 | An actual controversy over FSV Estonia’s right to register FARSIGHT VISION; the mark is barred under § 2(d) | A declaration of Reveal’s senior rights and an order directing the USPTO to refuse Serial No. 99759402 |
Notably, the Complaint does not include Florida-law claims (common-law unfair competition or FDUTPA) or a dilution claim. It is a purely federal case, which keeps the issues focused for a jury.
Where the case stands and what to watch
- Status: As of October 24, 2026, the Complaint has been filed. We found no published motions or orders yet.
- Admission of counsel: Reveal’s lead counsel is a Texas-barred lawyer in San Francisco whose pro hac vice admission is pending. M.D. Fla. Local Rule 2.01 governs special admission.
- Service abroad: Estonia and Ukraine are both parties to the Hague Service Convention, but service through Ukraine’s Central Authority during wartime can be slow. Watch for an early Rule 4(f)(3) motion for email service, or for service through the defendants’ U.S. contacts or counsel.
- Emergency relief: The Complaint asks only for a permanent injunction. No TRO or preliminary-injunction motion has been filed. Reveal may file one before the next major defense trade show.
- Defense motions: Expect a Rule 12(b)(2) challenge, particularly from FSV Ukraine, whose Florida contacts are pleaded mainly through alter-ego and agency theories. FarsightVision may also challenge the scope of the claimed goods, and could counterclaim to cancel the registration as descriptive or for lack of the claimed 2019 use.
- The USPTO track: The FARSIGHT VISION application’s response to the § 2(d) refusal, or its suspension pending this case, will be worth watching.
Five Key Insights
1. A Florida trade show can be the jurisdictional hook
Neither defendant is a U.S. company. Reveal’s path to a Tampa courtroom runs through five days at SOF Week: a branded booth, handouts, live demonstrations and a pitch on stage, all advertised on LinkedIn before and after. Florida’s long-arm statute reaches a foreign company that “carries on a business” in Florida or causes injury there through solicitation, and trade-show marketing aimed at Florida attendees is classic purposeful availment.
- For Florida brand owners: when a foreign competitor exhibits at a Florida show (SOF Week in Tampa, the Miami International Boat Show, eMerge Americas), document everything: photos of the booth, collateral, social-media posts and the names of booth staff. That evidence may be the basis for jurisdiction later.
- For foreign exhibitors: clear your brand in the U.S. before you rent a booth in Florida.
2. Send the demand letter while the infringer is in town
Reveal’s letters went out on May 20 and 22, 2026, while FarsightVision was exhibiting in Tampa. That timing gave Reveal proof of actual notice tied to Florida conduct. It also gives Reveal its willfulness case: the defendants expanded their U.S. marketing after notice and kept pursuing their application after the USPTO’s § 2(d) refusal. Willfulness supports disgorgement of profits, enhanced damages and fees under § 1117(a).
3. Use the USPTO’s refusal as evidence
The examining attorney’s § 2(d) refusal of FARSIGHT VISION is not binding on the court, but the Complaint uses it twice: as support for likelihood of confusion and as proof that the defendants continued “regardless.” Brand owners should monitor the register so they know when a competitor files, should consider a letter of protest to bring their registration to the examiner’s attention, and should cite any resulting refusal in demand letters and pleadings.
4. One documented instance of confusion by a sophisticated buyer is powerful
Defense buyers are sophisticated, which usually weighs against confusion. Reveal’s answer is a declaration from its own employee describing a MARSOC representative who mistook FarsightVision’s website and LinkedIn content for Reveal’s. In the Eleventh Circuit, actual confusion is the best evidence of likely confusion, and confusion by an expert buyer is especially persuasive. Brand owners should train customer-facing staff to log every misdirected inquiry with the date, the person and what they said, and preserve those records for a declaration.
5. Plead the domain, the application and the home markets: a complete enforcement plan
Reveal did not stop at infringement. It added an ACPA claim for farsightvision.com (transfer plus up to $100,000 in statutory damages), a § 1119 claim to stop the U.S. application, and it had already secured Madrid Protocol protection in Estonia, Ukraine, the EU and the UK, the defendants’ own markets. For Latin American and European companies entering the U.S., this is the other side of the lesson. A competitor’s U.S. registration, a matching domain claim and the competitor’s foreign registrations can take away your brand both in the U.S. and at home. Clear the name in every market before launch, and register through Madrid early.
Practice notes for the Middle District of Florida
- Local Rule 3.01(g) conferral. Most motions must include a certificate that the movant conferred with the opposing party. Since the 2021 amendments, the court expects that conferral to happen in person, by phone or by video, not just by email.
- Page limits. Under Local Rule 3.01(a), a motion and its supporting memorandum together may not exceed 25 pages. A response is limited to 20 pages under Rule 3.01(b). A reply requires leave and is limited to 7 pages under Rule 3.01(d).
- Typography. Local Rule 1.08 sets the typeface and size requirements, for example 13-point Book Antiqua or 14-point Times New Roman.
- Case management. Expect an early case management report under Local Rule 3.02. For a foreign defendant, the parties should build in extra time for service and translation.
- Emergency relief. Local Rule 6.01 governs temporary restraining orders. It requires a verified complaint or declaration and a precise description of the conduct to be enjoined. Any preliminary-injunction motion is decided under the four-factor test the Eleventh Circuit applies in Lanham Act cases.
Are you involved in a trademark litigation matter in Tampa Federal Court? Contact our team of Florida Trademark Litigators today through email at [email protected] or call 305-374-8303 to address how we can help your Lanham case in the Middle District of Florida.
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