Page:International Code Council v. UpCodes (2021).pdf/4

 an architect prior to founding UpCodes and has experience using and interpreting state and local building codes. Garrett Reynolds is a software engineer who designed the company website. The UpCodes website provides access to materials and tools of particular importance to building professionals, such as the state and local building codes that govern their projects.

The Complaint alleges that UpCodes directly competes with ICC by selling or giving away unauthorized copies of the I-Codes and Custom Codes to both customers and prospective customers. As further detailed below, ICC alleges that while UpCodes claims its codes are up-to-date and contain integrated amendments, Upcodes’sUpCodes’s [sic] codes actually contain numerous errors.
 * 1. Representations of Accuracy and Completeness

According to the Complaint, Defendants falsely assert that the posted codes are “always up to date,” and the UpCodes website assures customers that they will “never work from