The complaint

The complaint is Document 1, entered November 10, 2026, in HK HUALONG INFORMATION TECHNOLOGY LIMITED v. The Partnerships, Unincorporated Associations Identified on Schedule A, No. 1:26-cv-27963 (S.D. Fla.). It runs 13 pages, including a Schedule A that identifies 35 seller aliases and their Walmart store URLs. The plaintiff is a limited company formed in China, with its principal place of business in Kwai Chung, Hong Kong. (Compl. paras. 1, 7; Sched. A.) The docket shows the case assigned to Senior Judge Paul C. Huck on November 10, 2026.

The mark

The complaint says the plaintiff is the owner of all rights, title, and interest in the MUHVWM mark, U.S. Trademark Registration No. 8,390,020, 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 vases, reusable cups, plant baskets, dog water bottles, money saving boxes, slap chopper for vegetables, steel garlic slicer, foldable dog pool, and related products in International Class 21 under the mark, offered through selected third-party e-commerce platforms, including Walmart.com. (Compl. para. 9.) USPTO records list U.S. Reg. No. 8,390,020 as a live standard-character registration of MUHVWM on the Principal Register, owned by HK HUALONG INFORMATION TECHNOLOGY LIMITED, a limited company organized in China, registered August 11, 2026, from an application filed January 23, 2026, for goods including vases, reusable cups, plant baskets, dog bowls, cups and mugs, insulated mugs, and trash cans for household purposes in International Class 21, with first use and use in commerce claimed from December 12, 2025.

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 MUHVWM products. (Compl. paras. 2, 12, 14.) 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, and that those aliases target consumers throughout the United States, including Florida. (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; that they have targeted sales to Florida residents by operating e-commerce stores that offer shipping to the United States, including Florida, and accept payment in U.S. dollars; and that they have sold infringing products to residents of Florida. (Compl. paras. 6, 12, 17.) It alleges that the stores are designed to appear to be authorized online merchants, that they often include content and images that make them difficult to distinguish from an authorized retailer, and that none of the defendants is authorized to use the MUHVWM mark. (Compl. paras. 11, 18.) It further alleges, 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. para. 19.) It alleges that the unauthorized use is likely to cause and has caused confusion, mistake, and deception among consumers. (Compl. para. 25.) It alleges, on information and belief, that the defendants have knowledge of the plaintiff's rights in the mark and are willfully infringing and intentionally using the mark without permission. (Compl. para. 29.)

Claims and relief

The complaint pleads two counts against the Schedule A defendants: trademark infringement and counterfeiting under Section 32 of the Lanham Act, 15 U.S.C. § 1114 (Count I), and false designation of origin under Section 43 of the Lanham Act, 15 U.S.C. § 1125(a) (Count II). (Compl. paras. 26-35.) The prayer seeks a permanent injunction against using the MUHVWM mark or colorable imitations in connection with products that are not genuine or authorized; passing off products as genuine MUHVWM products; acts calculated to cause consumers to believe the defendants' products are authorized or connected with the plaintiff; further infringement of the mark; manufacturing, shipping, storing, or disposing of unauthorized inventory bearing the mark; using or controlling online marketplace accounts used to sell such products; and operating or hosting websites involved in selling them. It also 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, as well as sponsored search or ad-word providers, payment processors, and Internet search engines such as Google, Bing, and Yahoo, disable services and advertisements used in the sale of goods using the mark and take steps to prevent links to the defendants' stores from displaying in search results. It asks that the defendants account for and pay 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 MUHVWM 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.)