Hm? This seems to be the perfect use of this "intellectual property"[1]. Comodo is trying to deceive people, Let's Encrypt is trying to prevent it by enforcing their trademarks. This is how it's supposed to work.
--
[1] I don't like the term "intellectual property" mostly because people forget or misunderstand what it refers to and how the many various things called "intellectual property" work individually and differently from each other.