The complaint

Beanstalk Challenge LLC v. Venky Vijay Reddi and Orangeful Private Ltd., No. 1:26-cv-27890 (S.D. Fla., Miami Division), is a 17-page Complaint for Damages and Injunctive Relief entered on the docket November 6, 2026, ECF No. 1, with a jury demand. The plaintiff is a Florida limited liability company based in Boca Raton, Florida. The complaint alleges, upon information and belief, that Orangeful Private Ltd. is organized under the laws of India with its principal place of business in Gurugram, India, and that Reddi is an individual residing in Delhi, India. It alleges that Orangeful operates BeanStalkx as a division and that Reddi is Orangeful's founder. On personal jurisdiction, it points to the defendants' public invitations to meet in Miami during a domain-industry conference scheduled for November 11 and 12, 2026.

The marks

Beanstalk Challenge says it runs a business incubation and development program that pairs entrepreneurs and operators with premium internet domain names, and asserts common law rights in BEANSTALK CHALLENGE and a stylized BEANSTALKCHALLENGE mark with a sprouting-plant design. USPTO TSDR lists both as applications filed August 12, 2026 by Beanstalk Challenge LLC, a Florida limited liability company, in Class 35 for "business incubation services, namely, providing business development and management assistance to entrepreneurs, business developers, and business operators to establish and grow businesses on premium internet domain names; business development and consulting services in the fields of entrepreneurship, business start-ups, and internet domain names; business matchmaking services, namely, connecting internet domain names and internet domain name owners with entrepreneurs, business developers, and business operators for the development of businesses; arranging and conducting incentive award programs to recognize and reward entrepreneurs, business developers, and business operators for developing businesses on premium internet domain names": Serial No. 50047376 for BEANSTALK CHALLENGE in standard characters, first use March 5, 2026, and Serial No. 50047407 for the stylized mark and design, first use June 14, 2026. Both show the status LIVE/APPLICATION/Awaiting Examination.

What it alleges

The complaint alleges that the defendants promote a competing program under BEANSTALKX and BEANSTALK that contributes domains and brand assets to startup ventures, through beanstalkx.com and through beanstalk.si, which, it alleges upon information and belief, redirects visitors to Orangeful's BeanStalkx page. It alleges, upon information and belief, that one or both defendants own or control the two domains, directly or through an affiliate. It alleges the services compete directly and reach overlapping audiences of founders and domain owners, and that BEANSTALKX takes the entire BEANSTALK portion of the plaintiff's marks. It alleges that WHOIS records list July 28, 2026 as the registration date of beanstalkx.com and September 23, 2026 as the creation date of beanstalk.si, both after its claimed first use. It alleges, upon information and belief, that the defendants adopted the names with knowledge of the plaintiff's marks and use the domains with a bad-faith intent to profit. It also alleges that Reddi personally selected, directed, and controlled the challenged use.

Counts and relief

Count I pleads false designation of origin under 15 U.S.C. § 1125(a). Count II pleads common law trademark infringement. Count III pleads cybersquatting under 15 U.S.C. § 1125(d). Each count is brought against both defendants. The prayer asks for a permanent injunction under 15 U.S.C. § 1116; an order under 15 U.S.C. § 1125(d)(1)(C) transferring beanstalkx.com and beanstalk.si, directing the registrars to implement the transfers, with transfer as equitable relief under 15 U.S.C. § 1116(a) in the alternative; an order barring transfer or deletion of the domains pending relief; removal of the designation from the defendants' websites and promotional materials; delivery up or deletion of infringing materials under 15 U.S.C. § 1118 and a sworn compliance report under 15 U.S.C. § 1116(a); an accounting of profits, damages, and costs under 15 U.S.C. § 1117(a) and Florida law; at its election, statutory damages of $1,000 to $100,000 per domain name under 15 U.S.C. § 1117(d); attorneys' fees under 15 U.S.C. § 1117(a) on an exceptional-case finding; and other relief.

On the docket

The docket shows, on November 6, 2026, a summons issued (ECF No. 3), a Form AO 120/121 report on the filing of a trademark action (ECF No. 4), and a clerk's notice of judge assignment and optional consent.