28) Substantial sales of golf related items, instructional services and/or certification of golf instructors are or have been made by Defendant in Florida and perhaps other states and are affecting business in interstate commerce. Such sales are likely to cause confusion or mistake or to deceive aspiring golf instructors, golf instructors in general and the public of such persons as to sponsorship of it by Plaintiff. Such acts are also likely to and have most likely caused persons who have undergone certification and membership in Plaintiff’s organization to discontinue such membership in its organization.

29) Such infringing sales by Defendant are causing losses to Plaintiff of both its reputation in the professional golfing community and the public at large, thereby reducing the revenue generated by the Plaintiff. The relationship between the Plaintiff and the golf instructors and the public who aspires to learn to play the game of golf from instructors certified by the Plaintiff will be jeopardized in the event that Defendant’s infringing activities remain unrestrained. Moreover, such activities by Defendant are causing instructors in Florida and throughout the world to be concerned about an interference with their promotion of themselves as accredited golf instructors vis a vie instructors who are accredited through the Defendant. The image of the Plaintiff with golf instructors, aspiring golf instructors and the golfing public will be endangered if Defendant is permitted to continue these prejudicial and willful infringing activities by the use of the words “Share the Passion” and other words that are confusingly similar to the registered marks.