The complaint
The complaint is Document 1, entered November 13, 2026, in CEDARFIRM LLC v. The Partnerships, Unincorporated Associations Identified on Schedule A, No. 1:26-cv-28078 (S.D. Fla.). It runs 13 pages, including a Schedule A that identifies six seller aliases and their Walmart store URLs. The complaint describes the plaintiff as a limited liability company formed in Wyoming, with its principal place of business in Sheridan, Wyoming. (Compl. para. 7; Sched. A.)
The mark
The complaint says the plaintiff is the owner of all rights, title, and interest in the EXLEAF mark, U.S. Trademark Registration No. 7,817,152, that the registration is valid, subsisting, unrevoked, unchallenged, and uncancelled, and that it constitutes prima facie evidence of validity and of the plaintiff's exclusive right to use the mark under 15 U.S.C. § 1057(b). (Compl. paras. 1, 8.) It says the plaintiff has licensed and authorized e-commerce merchants to promote, market, and sell a range of scissors, electric hair crimpers, electric hair straightening irons, nail nippers, candle wick trimmer sets, and related products in International Class 8 under the mark, offered through selected third-party e-commerce platforms, including Walmart.com. (Compl. para. 9.) USPTO records list U.S. Reg. No. 7,817,152 as a live standard-character registration of EXLEAF on the Principal Register, owned by CedarFirm LLC, a Wyoming limited liability company, registered June 3, 2025, from an application filed September 17, 2024, for Class 8 goods that include scissors, electric hair crimper, electric hair straightening irons, nail nippers, pedicure sets, and razors and razor blades, with first use and use in commerce claimed from May 25, 2024.
What the complaint alleges
The complaint alleges that the defendants, identified as individuals and business entities on Schedule A, own or operate e-commerce stores under the seller aliases listed there, and that those stores advertise, offer for sale, and sell infringing and counterfeit EXLEAF products. (Compl. paras. 2, 12.) It alleges that the plaintiff has identified numerous e-commerce stores offering infringing products on online marketplace platforms such as Amazon, eBay, AliExpress, Alibaba, Wish.com, Walmart, Etsy, DHgate, and Temu, including the stores operating under the seller aliases. (Compl. para. 14.) It alleges, on information and belief, that the defendants reside or operate in the People's Republic of China or other foreign jurisdictions, or redistribute products from the same or similar sources in those locations. (Compl. para. 12.) It alleges that the defendants have targeted sales to Florida residents through online stores that offer shipping to Florida and accept payment in U.S. dollars, and, on information and belief, that they have sold infringing products to Florida residents. (Compl. paras. 6, 17.) It alleges that none of the defendants is authorized to use the EXLEAF mark, and, on information and belief, that the defendants incorporate the mark without authorization into the content, text, and/or meta tags of their e-commerce stores. (Compl. paras. 11, 18-19.) It alleges that the unauthorized use is likely to cause and has caused confusion, mistake, and deception among consumers, and, on information and belief, that the defendants know of the plaintiff's rights in the mark and are willfully infringing it. (Compl. paras. 25, 29.)
Claims and relief
The complaint pleads two counts against the Schedule A defendants: trademark infringement under 15 U.S.C. § 1114 (Count I), which it says amounts to willful trademark infringement and counterfeiting under Section 32 of the Lanham Act, and false designation of origin under 15 U.S.C. § 1125(a) (Count II). (Compl. paras. 26-35.) The prayer seeks a permanent injunction against using the EXLEAF mark or colorable imitations with products that are not genuine or authorized, passing off, acts calculated to cause consumers to believe the defendants' products are authorized by or connected with the plaintiff, further infringement, dealing in unauthorized inventory bearing the mark, and using online marketplace accounts or websites to sell such products. It asks for an order that those in privity with the defendants and those with notice of the injunction, including online marketplace platforms such as eBay, AliExpress, Alibaba, Amazon, Wish.com, Walmart, Etsy, DHgate, and Temu, sponsored search or ad-word providers, payment processors, and Internet search engines, disable services and advertisements used in selling goods under the mark and keep links to the defendants' stores out of search results. It asks that the defendants account for and pay their profits and that damages for infringement be increased by a sum not exceeding three times under 15 U.S.C. § 1117, or in the alternative statutory damages for willful trademark counterfeiting under 15 U.S.C. § 1117(c)(2) of $2,000,000 for each and every use of the EXLEAF mark, together with reasonable attorneys' fees and costs under 15 U.S.C. § 1117 and other relief the court deems just and proper. (Compl., Prayer for Relief.)