A Rochester-based T-shirt company was awarded default judgment against a rival that allegedly hijacked Amazon.com listings and falsely implied that the two companies' shirts were linked.

But Western District Judge Frank Geraci denied Crazy Dog T-Shirts' request for default against Design Factory Tees' corporate officer, Tony Rallis.

Geraci said a corporate officer may only be held personally liable for trademark infringement and unfair competition “if that officer is a 'moving, active, conscious force behind the corporation's infringement.'” That wasn't shown regarding Rallis, he said.