On Oct. 5, Seattle physician Ray Liao, M.D., agreed to a preliminary injunction enjoining him pending trial from “infringing upon the [American Board of Anesthesiology, Inc.’s] name and certification marks,” and from “[m]aking any representation, including any use of brochures, certificates, letterhead, business cards or other written information indicating or implying that the defendant is Board certified by the ABA.”
The ABA’s Sept. 18 complaint alleges that Dr. Liao intentionally used the ABA’s certification mark, THE AMERICAN BOARD OF ANESTHESIOLOGY and design, with the “clear intent to deceive others into believing that he is an ABA Diplomate and that he is an ABA-certified anesthesiologist.” In particular, the ABA alleges that Dr. Liao provided a representative of the Northwest Credentials Verification Service a “counterfeit reproduction of an actual ABA certificate” that contains Dr. Liao’s name and states that he is “qualified to serve as a consultant in anesthesiology” when he had not been Board certified in anesthesiology by the ABA.
Dr. Liao has not yet answered the ABA’s complaint.
The case cite is American Board of Anesthesiology, Inc. v. Liao, No. 07-1458 (W.D. Wash.).