CEDARFIRM LLC v. Schedule A Defendants: The EXLEAF and LADYGYM Suits Before Judges Huck and Bloom

On October 20, 2026, Fort Lauderdale firm Palmer Law Group, P.A. filed two “Schedule A” trademark lawsuits for CEDARFIRM LLC in the Southern District of Florida in Miami. Each case asserts a different registered mark against a different group of online sellers:

• The EXLEAF case is before Senior Judge Paul C. Huck. It started against six Walmart sellers.
• The LADYGYM case is before Judge Beth Bloom. It names two Amazon sellers and three Walmart sellers.

Within a day of filing, Judge Huck questioned whether the six sellers in his case belonged in one lawsuit. He ordered CEDARFIRM to show cause why every defendant except the first should not be severed and dismissed. CEDARFIRM did not wait for the deadline. Three days later it filed an amended complaint cutting the case to two sellers, along with a brief defending joinder of those two.

This post has been rebuilt from the court filings in both cases. It covers:

• both complaints and the amended complaint;
• the registration exhibit and the infringement-evidence exhibit;
• Judge Huck’s order to show cause and CEDARFIRM’s response;
• Judge Bloom’s procedures order;
• the Rule 7.1 disclosure, the prior-suits certification and the notice of entry of parties.

It includes a chart of the asserted trademarks and the complete list of Schedule A defendants named so far.

This update also adds USPTO records showing where both marks came from. Neither registration was originally CEDARFIRM’s:

• EXLEAF was registered to one individual in China.
• LADYGYM was registered to another, Jianjun Ma of Ningxia, China.

On the same day Mr. Ma’s LADYGYM registration issued, a sister registration (LABMARK) issued to him too. It was later assigned to a different, unrelated U.S. company. All facts are current as of October 25, 2026.

The Two Cases at a Glance:

	Case 1: EXLEAF	Case 2: LADYGYM
Case number	1:26-cv-27380-PCH	1:26-cv-27422-BB
Court	S.D. Fla. (Miami)	S.D. Fla. (Miami)
Filed	October 20, 2026	October 20, 2026
District judge	Senior Judge Paul C. Huck	Judge Beth Bloom
Magistrate judge	Eduardo I. Sanchez	Lisette M. Reid
Asserted mark	EXLEAF, Reg. No. 7,817,152 (Class 8)	LADYGYM, Reg. No. 7,945,631 (Class 12)
Counts	(I) Infringement and counterfeiting, 15 U.S.C. § 1114. (II) False designation of origin, § 1125(a).	Same two counts
Marketplaces	Walmart only	Amazon (2) and Walmart (3)
Defendants	6 in the original complaint; 2 after the amendment	5
Demand on docket	$500,000,000	None listed
Damages prayer	Profits trebled under § 1117(a), or statutory damages of “$2,000,000 for each and every use” under § 1117(c)(2)	Same
Plaintiff’s counsel	Andrew J. Palmer, Palmer Law Group, P.A.	Andrew J. Palmer, Palmer Law Group, P.A.
Jury demand	None	None
TRO or asset-freeze motion	None filed	None filed
Status	Joinder challenged; amended complaint and show-cause response filed October 24	Procedures order entered; defendants entered on CM/ECF October 24

Who is CEDARFIRM LLC? A Wyoming mailing address that holds Chinese registrants’ trademarks

CEDARFIRM LLC is a Wyoming limited liability company. Every public record ties it to one address: 30 N Gould St, Ste R, Sheridan, Wyoming 82801. That address appears in both complaints, in the EXLEAF and LADYGYM ownership records at the USPTO, and in CEDARFIRM’s corporate filings. Read together, the court papers and USPTO records point to a narrow role:

On the present record, CEDARFIRM appears to function as a U.S. holding vehicle. It takes assignment of trademarks registered by individuals in China and asserts them in Schedule A lawsuits. We found no evidence that it makes or sells any product, runs any storefront, or does any business beyond owning, “licensing” and enforcing these registrations.

That is a conclusion drawn from the documents described below, not a court finding. CEDARFIRM has not yet had to answer these points, and we will update this post if it offers evidence of an operating business.

The Sheridan Address

30 N. Gould Street is not an office where CEDARFIRM runs a business. It is one of the best-known commercial registered-agent addresses in the country:

• Registered Agents Inc. The International Consortium of Investigative Journalists (ICIJ) reported in March 2025 that more than 266,000 companies were formed using this address between 2019 and 2024. That is more than 40% of Wyoming’s new companies in that period. Registered Agents Inc. operates the building.
• Other agents. The Sheridan Press reported in March 2026 that the building houses 26 commercial registered agents representing close to 300,000 Wyoming LLCs, most of which do no business in Wyoming.
• Ownership stays private. Wyoming does not require LLCs to list their members or managers in public filings. Federal beneficial-ownership reporting under the Corporate Transparency Act no longer applies to U.S.-formed companies after FinCEN’s March 2025 interim rule. A Wyoming LLC at this address can therefore own federal trademark registrations and sue in federal court without publicly revealing who owns or controls it.

Using a registered-agent address is lawful and common, including for legitimate brand owners. But it means the “principal place of business” in CEDARFIRM’s complaints tells the court nothing about where the company operates, who runs it, or whether it has any business at all.

What the record shows about CEDARFIRM’s business:

Indicator	What the filings and USPTO records show
Origin of the marks it asserts	Both were registered by individuals in China (EXLEAF by Xie, Tianhua of Sichuan; LADYGYM by Jianjun Ma of Ningxia) and later assigned to CEDARFIRM
Relationship between the marks	None apparent. Teaspoons and grooming tools (Class 8) and bicycles (Class 12), from two unrelated registrants
Timing	LADYGYM’s assignment was recorded April 1, 2026; suit followed about 6½ months later. EXLEAF’s assignment date is not disclosed.
CEDARFIRM’s own sales	None alleged. The complaints say only that CEDARFIRM “has licensed and authorized e-commerce merchants” to sell the goods, without naming any.
Products, storefront or website	None identified in either complaint or exhibit
Disclosure of the assignments	Neither complaint mentions that the marks were acquired, from whom, or when
Corporate disclosure	No parent, no 10% public owner, no affiliates (ECF 6 in the Bloom case)
Members or managers	Not disclosed anywhere in the record
Enforcement activity	Two Schedule A suits filed the same day, against 11 seller aliases, with a $500 million demand on one docket and statutory damages sought at $2 million “for each and every use”

Why this matters

Standing and ownership. A trademark protects the goodwill of a business, not a word in the abstract. If CEDARFIRM received only the registration certificates, with no products, customers, inventory or quality standards, the assignments may be invalid assignments in gross under 15 U.S.C. § 1060(a)(1). Then CEDARFIRM cannot rely on the original registrants’ use. Either way, its claims to “license” the marks need proof that it controls the nature and quality of the licensed goods. A licensor that exercises no control risks a finding of naked licensing and abandonment.

Irreparable harm and equitable relief. TROs, asset freezes and preliminary injunctions rest on a showing that the plaintiff’s reputation and goodwill are being irreparably harmed. Since 2020, 15 U.S.C. § 1116(a) presumes irreparable harm once likely success is shown. That presumption can be rebutted. A holding company with no products in the market has a hard time explaining whose reputation is being harmed.

Who actually benefits. Judge Bloom’s procedures order requires every party, within 21 days after a defendant appears, to file a certificate of interested parties listing “a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case.” That certificate is a defendant’s first chance to learn the following:

• whether the original registrants, Xie, Tianhua and Jianjun Ma, keep an interest in any recovery;
• whether the “licensed” merchants do;
• whether a litigation funder does.

Defendants should insist on a complete certificate and follow up in discovery with the assignment agreements, payment records, license agreements and CEDARFIRM’s operating agreement.

Credibility before the court. The complaints describe EXLEAF and LADYGYM as brands that “enjoy broad promotion throughout the United States and worldwide” and have “generated substantial sales and revenue.” Those allegations come from an LLC that, so far as the record shows, acquired both registrations recently from foreign individuals and sells nothing itself. They should be tested before any ex parte relief is granted.

Neither of the marks CEDARFIRM is suing on started out as CEDARFIRM’s. USPTO records show that both were applied for, sworn to be in use, and registered by individuals in China. Each was assigned to the Wyoming LLC only afterward.

Where EXLEAF came from

The EXLEAF registration certificate (Exhibit 1 in the Huck case) shows that Reg. No. 7,817,152 was issued on June 3, 2025 to Xie, Tianhua, an individual in Zigong, Sichuan, China. The USPTO status record, printed October 19, 2026 (the day before suit), lists CEDARFIRM LLC as owner. Neither complaint mentions the assignment or gives its date.

Where LADYGYM came from: the Jianjun Ma registrations

The LADYGYM registration certificate and the USPTO’s current record show the following:

• Application. It was filed January 8, 2025 (Serial No. 98-944,662) on a use-based (Section 1(a)) basis by Ma, Jianjun, an individual in Wuzhong City, Ningxia, China.
• Claimed use. First use anywhere and in commerce is claimed as of December 8, 2024, just one month before filing. The claim covers 15 kinds of bicycle goods, from complete bicycles and electric bicycles to derailleurs, baskets and handlebars.
• Registration. The mark was published July 29, 2025 and registered on the Principal Register on September 16, 2025 (Reg. No. 7,945,631).
• Attorney of record. A San Diego attorney is listed. U.S. counsel has been required for foreign-domiciled applicants since 2019.
• Assignment. The record shows one assignment. The USPTO entered an “automatic update of assignment of ownership” on April 1, 2026, and CEDARFIRM LLC is now listed as owner. The assignment’s execution date and terms are not on the summary page.

A USPTO owner search for “Ma, Jianjun” returns four live registrations. We pulled the full USPTO records for all four:

	LADYGYM	LABMARK	WINTERSWEET	PUNHURT
Serial / Reg. No.	98-944,662 / 7,945,631	98-944,822 / 7,945,653	90-656,752 / 6,583,666	90-492,970 / 6,582,108
Class and goods	12: bicycles, e-bikes, bicycle parts and accessories (15 items)	12: car interior organizers, alarms, tires, seats, motor homes, shock absorbers, wipers and other vehicle parts	7: cordless vacuums, dough kneaders, egg beaters, blenders, juicers, milk frothers, food processors, garbage disposals, vacuum packaging machines (12 items)	26: braids, toupees, wigs, clown wigs, hair extensions, hairpieces, human braiding hair and related goods
Claimed first use	Dec. 8, 2024	Not in our printout	Jan. 15, 2021	Jan. 13, 2021
Filed	Jan. 8, 2025 (one month after claimed first use)	About the same time as LADYGYM	Apr. 20, 2021 (TEAS Plus)	Jan. 27, 2021 (two weeks after claimed first use)
Published / registered	July 29, 2025 / Sept. 16, 2025	— / Sept. 16, 2025	Sept. 21, 2021 / Dec. 7, 2021	Sept. 21, 2021 / Dec. 7, 2021
Registrant’s address of record	Wuzhong City, Ningxia	Wuzhong City, Ningxia (same as LADYGYM)	Yuyao City, Zhejiang
Filing representative	San Diego attorney	Not in our printout	Shenzhen-based filing agent (correspondent address in Longhua District, Shenzhen)	Irvine, California attorney (withdrew January 2024)
Assignment	To CEDARFIRM LLC (Wyoming), recorded Apr. 1, 2026	To Ombre LA Inc (California)	None recorded; still held by Ma, Jianjun	To Xuchang Jiashun Renewable Resources Co., Ltd. (Henan, China), recorded Feb. 7, 2024
Section 8 declaration of use due	Sept. 16, 2030 to Sept. 16, 2031	Sept. 16, 2030 to Sept. 16, 2031	Dec. 7, 2026 to Dec. 7, 2027	Dec. 7, 2026 to Dec. 7, 2027

Two filing waves, possibly two different registrants

The records show two waves of filings in the name “Ma, Jianjun”:

• The 2021 wave (WINTERSWEET and PUNHURT). Both were filed early in 2021 on claims of use that began in mid-January 2021. Both were published the same day and registered the same day, December 7, 2021.
• The 2025 wave (LADYGYM and LABMARK). Both were filed in January 2025 and registered the same day, September 16, 2025.

Within each wave the pattern is consistent: individual Chinese registrant, use-based applications filed weeks or months after the claimed first use, long goods lists across a whole product category, and identical publication and registration dates.

But the two waves may not be the same person. “Jianjun Ma” is a common name. The WINTERSWEET registrant’s address of record is in Yuyao City, Zhejiang Province, roughly 1,800 km from the Wuzhong City, Ningxia address on LADYGYM and LABMARK. The filings were handled by different representatives: a Shenzhen filing agent for WINTERSWEET, California attorneys for the others. The USPTO’s owner search groups registrations by name, not by identity. Unless the prosecution files tie them together, a court will likely treat WINTERSWEET and PUNHURT as evidence about a filing pattern, not about this particular registrant.

Where the marks ended up:

The four registrations have gone four different ways:

• LADYGYM went to CEDARFIRM, a Wyoming LLC at a registered-agent address. Within about 6½ months it was asserted in a Southern District of Florida Schedule A case.
• LABMARK, its same-day sister registration, went to Ombre LA Inc, an unrelated California corporation. We have found no lawsuit asserting it so far.
• PUNHURT, for wigs and hair extensions, went in 2024 to a company in Xuchang, Henan. Xuchang is best known for its wig and hair extension manufacturing industry. That assignment looks like an ordinary sale of a brand to a business in its own industry.
• WINTERSWEET has never been assigned and remains in the registrant’s name.

We searched public docket indexes and found no lawsuit, in the Southern District of Florida or elsewhere, asserting WINTERSWEET, PUNHURT or LABMARK. Public indexes are incomplete, and Schedule A complaints are sometimes filed or kept under seal. A PACER party and keyword search is the way to confirm. For now, LADYGYM, through CEDARFIRM, is the only one of the four registrations we can tie to Schedule A litigation.

A deadline that will test actual use

WINTERSWEET and PUNHURT both reach their first maintenance deadline soon. The window for the Section 8 declaration of use opens December 7, 2026, about six weeks from now, and closes December 7, 2027, with a six-month grace period after that. To keep either registration, the owner must swear to current use in commerce for each listed good and submit a specimen. Goods no longer in use must be deleted, and the USPTO audits some declarations for proof of use.

Whether these registrations are maintained, and with what specimens, will show whether they cover real businesses. Watch the USPTO records in 2027.

What the registration history suggests, and what it doesn’t

The records do not show why LADYGYM was filed or what CEDARFIRM paid for it. But the path LADYGYM took raises a fair question: was the registration created to be sold and enforced rather than to brand a real product line? The path:

• One individual registers marks across unrelated product categories.
• Within months, the registrations are assigned to separate U.S. entities.
• At least one is then asserted in a mass-defendant suit within about six months of the assignment.
• The complaint says nothing about the assignment and alleges only that CEDARFIRM “has licensed and authorized e-commerce merchants” to sell the goods.

CEDARFIRM’s other mark followed the same route from a different Chinese individual (EXLEAF). Practitioners writing about Schedule A litigation have described this market directly. A June 2026 World Trademark Review guide chapter reports that “[n]umerous IP agents in China offer to sell US IP registrations at extremely low prices,” sometimes “US$200 or even less.” It explains that this makes it “economically rational to acquire US IP rights … as a litigation weapon.”

The broader Ma, Jianjun records cut both ways, and a court would weigh both:

• Consistent with registrations made for sale. Paired same-day registrations, quick use-based filings with sweeping goods lists, and assignments to unrelated buyers in different places.
• Consistent with ordinary commerce. PUNHURT went to a company in China’s wig-manufacturing hub. WINTERSWEET has stayed with its registrant for nearly five years. Buying a registration is lawful, and many sellers register marks for their own Amazon or Walmart storefronts and later sell the brand along with the business.

The point for defendants is not that the assignment alone defeats the case. It is that the history gives them specific, documentable questions that the plaintiff must be able to answer with evidence:

1. Was goodwill transferred, or only the certificate? Under 15 U.S.C. § 1060(a)(1), a registered mark is assignable only “with the good will of the business in which the mark is used.” An assignment in gross (the bare registration, with no business, products, customers or quality standards behind it) is invalid. The assignee then cannot rely on the assignor’s use or priority.
2. Was the mark actually in use for all 15 bicycle goods on January 8, 2025? A use-based application requires a verified statement that the mark is in use on every listed good. Yet one specimen per class was enough to register. If LADYGYM was never used on, for example, electric bicycles or derailleurs, those goods are vulnerable. If the applicant knew the use claim was false, the registration may be void for fraud on the USPTO under In re Bose Corp., 580 F.3d 1240 (Fed. Cir. 2009). Fraud requires proof of intent to deceive, so non-use alone is not enough.
3. Who are the “licensed and authorized” merchants? If CEDARFIRM controls no product quality and sells nothing, its licensing claim and its theory of irreparable harm both need evidence.
4. What does the prosecution file show? The LADYGYM file holds 21 documents. Defendants should pull the specimen of use from the USPTO’s status and document retrieval database (TSDR) and compare it with real product listings. The USPTO has rejected and sanctioned digitally altered or mock-up specimens.

Why this matters for the lawsuits

A registration certificate is prima facie evidence of validity and ownership (15 U.S.C. §§ 1057(b), 1115(a)), and an assignee generally steps into the assignor’s shoes. That presumption is what makes ex parte TROs and asset freezes possible in Schedule A cases.

But it is a presumption, not a conclusion. Neither registration is incontestable. Both were assigned shortly before suit by foreign individuals the complaints never mention. That gives a judge already scrutinizing joinder good reason to ask for more before freezing anyone’s money:

• the recorded assignment;
• proof that goodwill was transferred;
• evidence of CEDARFIRM’s own or its licensees’ sales.

Chart of Trademarks Asserted

	EXLEAF	LADYGYM
Case	1:26-cv-27380-PCH (Huck)	1:26-cv-27422-BB (Bloom)
Mark type	Standard characters	Standard characters
U.S. Reg. No.	7,817,152	7,945,631
Serial No.	98-754,056	98-944,662
Filing basis	Use in commerce, § 1(a) (TEAS Plus)	Use in commerce, § 1(a)
Application filed	September 17, 2024	January 8, 2025
Claimed first use (anywhere / in commerce)	May 25, 2024 / May 25, 2024	December 8, 2024 / December 8, 2024
Published	April 15, 2025	July 29, 2025
Registered	June 3, 2025, Principal Register	September 16, 2025, Principal Register
International class	8	12
Goods covered	18 items: scissors; hand-operated abrading tools; apparatus for tattooing; artificial eyelash tweezers; non-electric can openers; depilatory appliances; electric hair clippers, crimpers and straightening irons; electric irons; electric nasal hair trimmers; electric razors; fruit-segment cutters; vegetable peelers; nail nippers; pedicure sets; razors and razor blades; tableware, namely knives, forks and spoons	15 items: bicycles; air pumps for bicycles; air pumps for two-wheeled motor vehicles or bicycles; bicycle baskets; bicycle bells; bicycle brakes; bicycle carriers for vehicles and parts; bicycle chains; bicycle horns; derailleurs; bicycle pedals; bicycle seats; bicycle water-bottle cages; electric bicycles; handlebars
Original registrant	Xie, Tianhua (individual, Zigong, Sichuan, China)	Ma, Jianjun (individual, Wuzhong City, Ningxia, China)
Current owner of record	CEDARFIRM LLC (Wyoming)	CEDARFIRM LLC (Wyoming)
Assignment	Date not stated in the filings	One assignment; USPTO record updated April 1, 2026
Time from assignment to suit	Unknown	About 6½ months
Sister registrations	None identified	LABMARK (Reg. No. 7,945,653), same registrant, same registration date, now owned by Ombre LA Inc
Products actually at issue	Gold-leaf long-handle stainless teaspoons (the amended complaint ¶ 8 says “pencils”)	Not identified in the complaint; no infringement exhibit attached
Incontestable (§ 1065)?	No	No
Reexamination window (non-use as of the relevant date)	Until June 3, 2030	Until September 16, 2030
Expungement window (never used)	Opens June 3, 2028	Opens September 16, 2028
Section 8 declaration due	June 3, 2030 to June 3, 2031	September 16, 2030 to September 16, 2031

Four points about these registrations:

1. Neither is incontestable. Under 15 U.S.C. § 1064, a registration under five years old can be cancelled on any ground that would have barred it, including likelihood of confusion with an earlier mark, lack of bona fide use for the listed goods, and fraud.
2. Both goods lists are broad, and both use claims were made shortly before filing. EXLEAF claims 18 kinds of goods, from tattoo machines to teaspoons. LADYGYM claims 15, from handlebars to electric bicycles, with first use one month before filing. Those are the kinds of lists the USPTO’s reexamination proceeding, created by the Trademark Modernization Act (15 U.S.C. § 1066b), is designed to test.
3. Both were assigned to CEDARFIRM by their original foreign registrants. That makes the validity of each assignment, and the transfer of any real goodwill, a live issue.
4. The complaints describe each brand as “highly distinctive” and “especially associated with” teaspoons (EXLEAF) and bicycle accessories (LADYGYM). Neither offers sales figures, advertising spend, consumer recognition, or any history of the brand before CEDARFIRM acquired it.

Case 1: EXLEAF before Judge Huck

The original complaint (October 20)

The original 13-page complaint named six Walmart sellers. It contained no section explaining why they belonged together. It relied on general allegations common to Schedule A pleadings:

• the stores share “templates with common design elements,” keywords, payment methods and “the same incorrect grammar and misspellings”;
• the sellers talk to each other on QQ, WeChat, sellerdefense.cn and kuajingvs.com;
• the sellers move money offshore.

Its exhibits were the registration, a 2021 CBP seizure report, Professor Daniel Chow’s 2020 article on counterfeiting on Alibaba and Amazon, and a 2020 DHS report on counterfeit trafficking. No evidence of any specific defendant’s sales was attached. The civil docket lists a demand of $500,000,000.

Judge Huck’s sua sponte order to show cause (October 21)

One day after filing, and before any motion for a TRO, Judge Huck raised joinder on his own. His order, signed October 21 and entered October 22, found that CEDARFIRM “has not sufficiently set forth why joinder is justified under Federal Rule of Civil Procedure 20.” It cited Galleon Guild Ltd. v. Partnerships & Unincorporated Ass’ns Identified on Schedule A, No. 25-24168-CIV, 2025 WL 4590207, at *2–3 (S.D. Fla. Oct. 3, 2025).

The order directed CEDARFIRM to show cause by November 6, 2026 “why all Defendants, aside from the first named Defendant on Schedule A, should not be severed and dismissed.” It required CEDARFIRM to show both “a proper basis for joinder under Rule 20” and why joinder “would promote judicial economy.”

The message was clear. In Judge Huck’s courtroom, a single $405 filing fee buys one defendant unless the plaintiff can tie the others to the same transaction or occurrence.

The amended complaint (October 24)

CEDARFIRM responded on two tracks the same day, 13 days before its deadline. The first was an amended complaint that:

• Dropped four of the six defendants, including the first-named one. Judge Huck’s order would have kept defendant no. 1, weijing. The amended Schedule A drops weijing and keeps only the original defendants no. 4 (miuning) and no. 6 (yiqinshop).
• Added a “Joinder Is Proper” section (¶¶ 7–10). It alleges that both defendants “sell identical infringing products—pencils under the same Walmart Product listing, sharing the same product title, description and images.” It says CEDARFIRM seeks only several liability.
• Added Exhibit 2, “Infringing Evidence.” This is a 14-page set of Walmart screenshots.
• Kept everything else. That includes the boilerplate on offshore accounts and the prayer for $2,000,000 in statutory damages “for each and every use.”

What Exhibit 2 shows

The pages CEDARFIRM cites (pp. 2 and 9) are screenshots dated September 17, 2026. They show a single Walmart item page titled “EXLEAF 6-Piece Elegant Gold Leaf Long Handle Teaspoons-7.4” Stainless Steel Stir Spoons for Coffee&Tea.” The page’s “More seller options” panel lists at least eight sellers offering the same item at $7.99 to $9.42, all with a ship-to address in Chicago, Illinois 60605. Both miuning ($8.79) and yiqinshop ($9.42) appear in that panel. The two cited pages appear to be the same capture.

The exhibit cuts both ways:

• It supports CEDARFIRM’s narrower joinder theory. Two sellers offering the same item on the same listing at the same time is more concrete than the boilerplate in the original complaint.
• It raises questions CEDARFIRM’s papers do not answer. Walmart’s marketplace lets many sellers attach offers to one shared catalog page, and this page carries the EXLEAF name in its own title. Who created it? Was it an authorized “EXLEAF” listing that unauthorized sellers joined, or did a third party create it? Are the teaspoons these sellers ship genuine EXLEAF goods resold, which the first-sale doctrine protects, or knockoffs? The exhibit shows no test purchase, no product photos side by side with genuine goods, and no explanation of what makes the goods “counterfeit.”
• It also shows at least six other sellers on the same page who were not sued. That undercuts the response’s claim of a coordinated operation between these two particular sellers.

CEDARFIRM’s response to the order to show cause (October 24)

The six-page response opens by noting that the amendment “substantially narrowed the joinder concern.” It then argues that joining the remaining two defendants is proper under Rule 20(a). The arguments:

• Logical relationship. Relying on Alexander v. Fulton County, 207 F.3d 1303, 1323 (11th Cir. 2000), Republic Health Corp. v. Lifemark Hospitals of Florida, 755 F.2d 1453 (11th Cir. 1985), Rhodes v. Target Corp., 313 F.R.D. 656 (M.D. Fla. 2016), and the Federal Circuit’s In re EMC Corp., 677 F.3d 1351 (Fed. Cir. 2012), it argues that the claims arise from the same series of transactions. Both sellers offered “identical counterfeit” teaspoons on the same Walmart listing at the same time.
• Common source. It asserts, without a declaration or exhibit, that “Plaintiff’s investigation revealed that both Defendants source their products from the same supplier.” It also refers to a “common point of contact” that is not described anywhere in the amended complaint.
• Judicial economy. Citing Bose Corp. v. Partnerships, 334 F.R.D. 511, 517 n.6 (N.D. Ill. 2020), it argues that requiring separate suits “could flood the courts” with single-defendant cases.
• A possible larger operation. Citing Shambour v. Carver County (D. Minn. 2014), it argues the two sellers “could be part of a much larger organized operation.”
• Manageability. “Unlike other cases involving … hundreds of defendants, the present case involves only two defendants.”

Readers should note several problems in the filings:

• “Pencils” or “teaspoons”? The amended complaint (¶ 8) says the two defendants sell “pencils.” The response and Exhibit 2 say teaspoons.
• Unsupported facts. The supplier and “common point of contact” assertions appear only in an unsworn brief.
• Citation chain. An “Id.” citation following an Eleventh Circuit case (Swan v. Ray) introduces language that comes from the Federal Circuit’s EMC opinion. Counsel on either side should check every citation against the source. That matters in this district: Judge Bloom’s procedures order in the companion case expressly warns that filings with hallucinated or misdescribed cases will draw sanctions.
• Dilution claims without a dilution count. The complaint alleges “dilution, and tarnishment” but pleads no dilution count under § 1125(c), and it offers no facts showing EXLEAF is famous.

Judge Huck has not ruled. Options include accepting joinder of the two remaining sellers, severing one, or requiring more evidence before considering any request for a TRO or asset freeze.

Case 2: LADYGYM before Judge Bloom

The complaint (October 20)

The LADYGYM complaint is nearly identical to the original EXLEAF complaint, with the mark, the class and the goods changed. It asserts Reg. No. 7,945,631 for bicycles and bicycle accessories in Class 12 and pleads the same two counts and the same prayer. The exhibits are the registration, the CBP report, the Chow article and the DHS report. There is no infringement-evidence exhibit and no joinder section. This is the same pleading gap that drew Judge Huck’s order in the companion case. Judge Bloom had not entered a joinder order as of October 25.

The five defendants are on two different platforms (Amazon and Walmart), which makes a “same listing” joinder theory like the one CEDARFIRM now uses in the Huck case unavailable.

Judge Bloom’s Order Regarding Procedures (October 21)

Judge Bloom’s standard paperless order tells Schedule A plaintiffs and defendants what to expect:

• Service. Rule 4(m)‘s 90-day limit applies, with dismissal without notice if service is not proven. The order notes that the 90-day period does not apply to service in a foreign country under Rule 4(f) or 4(h)(2). That is why Schedule A plaintiffs ask early for alternative service by email.
• Defaults on a timetable. A motion for clerk’s default is due within 7 days after a served defendant’s response deadline passes. A motion for default final judgment is due within 7 days after the clerk’s default and must follow her Standing Order on Default Final Judgment. Missing either deadline risks dismissal.
• Interested parties and scheduling. Certificates of interested parties and a joint scheduling report under Local Rule 16.1 are due within 21 days after any defendant appears.
• Format and proposed orders. Times New Roman 12-point, double-spaced, fully justified.
• Extensions. Every motion for an extension needs a Local Rule 7.1(a)(3) conferral statement, a specific showing of good cause, and a statement of its effect on the dispositive-motion and trial dates.
• A warning about artificial intelligence. Lawyers and pro se parties who use AI “do so at their own risk” and “will be sanctioned” for filings that cite hallucinated cases or misrepresent real ones.

CEDARFIRM’s October 24 filings

• Notice of Entry of Parties (ECF 5). This puts the five sellers on CM/ECF, so the Schedule A in this case is public, not sealed. The notice lists Amazon seller IDs A2NP6ON3UN580M and AEQ7MJ8RTWU6C. The complaint’s Schedule A lists AA2NP6ON3UN580M and AAEQ7MJ8RTWU6C, each with an extra leading “A.” Its column heading also reads “Walmart Store URLs” even though two of the entries are Amazon links. Errors like these can matter when a plaintiff later asks Amazon to freeze specific accounts.
• Rule 7.1 Disclosure (ECF 6). No parent company and no 10% public owner.
• Certification Regarding Prior Suits (ECF 7). Attorney Palmer declares under penalty of perjury that a nationwide PACER search found no earlier CEDARFIRM suit against any of the five defendants. Several S.D. Fla. judges require this certification in Schedule A cases. It keeps a plaintiff from suing the same seller repeatedly for the same conduct and helps the court spot claim-splitting.

Known Schedule A defendants

These are all of the seller aliases CEDARFIRM has publicly named in the two cases. Being named is an allegation, not a finding: no court has found any of these sellers liable, and none has appeared.

Case 1, EXLEAF (1:26-cv-27380-PCH), Walmart

Def. # (original)	Seller alias	Store URL	Status
1	weijing	walmart.com/global/seller/103122942	Dropped by the amended complaint (Oct. 24)
2	jinghai	walmart.com/global/seller/103141875	Dropped by the amended complaint
3	xuemeistore	walmart.com/global/seller/103227475	Dropped by the amended complaint
4	miuning	walmart.com/global/seller/103152019	Retained, now Def. 1
5	haojun	walmart.com/global/seller/103123922	Dropped by the amended complaint
6	yiqinshop	walmart.com/global/seller/103131761	Retained, now Def. 2

Dropping a seller from an amended complaint before service is effectively a dismissal without prejudice. The four dropped sellers could be sued again, in this or another district. If they are, the prior-suits certification the court requires should disclose this case.

Case 2, LADYGYM (1:26-cv-27422-BB)

Def. #	Seller alias	Platform	Store URL (per notice of entry, ECF 5)
1	YAying	Amazon	amazon.com/sp?seller=A2NP6ON3UN580M
2	xinxiuxiu	Amazon	amazon.com/sp?seller=AEQ7MJ8RTWU6C
3	jinqiong	Walmart	walmart.com/global/seller/103154000
4	fudawei	Walmart	walmart.com/global/seller/103147117
5	shiliang	Walmart	walmart.com/global/seller/103143731

Totals: 11 seller aliases have been named across the two cases, and 7 remain active defendants (2 before Judge Huck, 5 before Judge Bloom).

Timeline

Date	Event
May 25, 2024	Claimed first use of EXLEAF (Xie, Tianhua)
Sept. 17, 2024	EXLEAF application filed
Dec. 8, 2024	Claimed first use of LADYGYM (Ma, Jianjun)
Jan. 8, 2025	LADYGYM application filed; LABMARK filed at about the same time
June 3, 2025	EXLEAF registered to Xie, Tianhua
Sept. 16, 2025	LADYGYM and LABMARK both registered to Ma, Jianjun
Apr. 1, 2026	USPTO records LADYGYM assignment; CEDARFIRM becomes owner of record
Date unknown	EXLEAF assigned to CEDARFIRM
Sept. 17, 2026	Walmart screenshots captured (later EXLEAF Ex. 2)
Oct. 19, 2026	EXLEAF status record printed (Ex. 1)
Oct. 20, 2026	Both complaints filed (6 Walmart sellers before Huck; 5 Amazon and Walmart sellers before Bloom); AO 120 reports sent to USPTO
Oct. 21, 2026	Huck: order to show cause on joinder (entered Oct. 22). Bloom: Paperless Order Regarding Procedures
Oct. 24, 2026	Huck case: amended complaint (2 sellers) and show-cause response. Bloom case: notice of entry of parties, Rule 7.1 disclosure, prior-suits certification
Nov. 6, 2026	Original show-cause deadline (Huck)
Jan. 18, 2027	90-day Rule 4(m) date for any domestic service (foreign service is exempt)

Why Judge Huck’s order matters

Schedule A plaintiffs bring these cases to Miami partly because the Southern District of Florida has been a reliable place to get sealed TROs and asset freezes against dozens of sellers at once. Professor Eric Goldman’s study of 3,217 Schedule A cases found 242 filed in the Southern District of Florida, second only to the Northern District of Illinois.

That is changing. In the Northern District of Illinois, Judge Kocoras dissolved a preliminary injunction against 252 improperly joined defendants in Collectanea J. Ltd. v. Schedule A, No. 25 C 4839 (Mar. 31, 2026). He held that shared design elements, SEO tactics and payment methods “are inherent to online counterfeiting” and do not show coordination.

Judge Huck’s order, citing Galleon Guild, shows the same scrutiny in Miami at the earliest possible point: before any TRO motion and before any seller has been heard. The CEDARFIRM case shows how quickly that scrutiny changes a plaintiff’s approach:

• Six sellers became two.
• Boilerplate gave way to a specific (though imperfect) theory that both sellers used the same listing.
• The plaintiff had to produce evidence of what each seller did.

§ 1114 versus § 1125(a) in Miami Schedule A cases

Both CEDARFIRM suits follow the usual Miami pattern: a registered-mark claim under 15 U.S.C. § 1114 paired with false designation of origin under § 1125(a). The registration is what makes the model work.

	§ 1114 (registered marks)	§ 1125(a) only (unregistered marks)
Federal registration required	Yes	No
Registration is evidence of validity and ownership (§ 1115(a))	Yes	No; the plaintiff must prove distinctiveness and priority
Statutory damages for counterfeits, up to $2M per mark per type of goods if willful (§ 1117(c))	Available	Not available
Fit for a sealed TRO and asset freeze	Strong: certificate plus side-by-side listings	Weaker: needs more proof of rights up front

Docket services code each case by the single statute on the civil cover sheet, so they understate how many cases also plead § 1125(a). No public source gives a reliable year-by-year count of § 1114 versus § 1125(a)-only Schedule A filings in this district. One can be built from PACER or Lex Machina by searching Nature of Suit 840 cases with “Schedule A” in the defendant name and reviewing the counts actually pleaded.

Recommendations for sellers named in CEDARFIRM’s cases:

1. Check both Schedule As now. If your alias appears in either table above, assume a TRO and asset-freeze motion may follow, and talk to counsel before your marketplace account is restricted. If you were one of the four sellers dropped from the EXLEAF case, you are out of that case, but you were dismissed without prejudice and could be sued again.
2. Put the chain of title at issue. Both marks came from individual Chinese registrants: Xie, Tianhua for EXLEAF and Jianjun Ma for LADYGYM. Demand:
   • the executed assignments and their dates;
   • what was paid;
   • proof that goodwill (products, inventory, customers, quality standards) was transferred.

An assignment in gross under 15 U.S.C. § 1060(a)(1) undermines the plaintiff’s standing to rely on the registrant’s use.

1. Pull the USPTO files. Download the specimens and declarations from TSDR for Serial Nos. 98-754,056 and 98-944,662. Compare the specimens with real product listings, and look for the claimed first-use products on the marketplace before the claimed dates.
2. Consider USPTO challenges in parallel. Options include:
   • a petition to cancel under § 1064, on grounds such as non-use, fraud or likelihood of confusion with an earlier mark;
   • a reexamination request for goods that were not in use on the relevant date.

A pending challenge also gives you leverage in settlement talks.

1. Gather your sourcing records. If you bought genuine EXLEAF or LADYGYM goods from an authorized source, the first-sale doctrine is a defense. Invoices and supplier records are the best evidence. If you sold your own goods under a different name and the mark appeared only in a shared catalog listing, document that too.
2. Press on joinder before Judge Bloom. The LADYGYM complaint has no joinder allegations and no evidence tied to any seller, and it combines Amazon and Walmart sellers. Those are the same gaps Judge Huck flagged. A motion to sever is a strong first move.
3. Use the errors in the record. These include the “pencils” versus “teaspoons” inconsistency, the brief’s unsworn claims about a common supplier and point of contact, the mismatched Amazon seller IDs, the dilution allegations with no dilution count, and the complaints’ silence about the assignments. Together they support asking for sworn proof before any ex parte relief.
4. Challenge the size of any freeze. Asset restraints should be limited to profits plausibly traceable to sales of the accused product, not a seller’s whole account balance. Bring sales data showing what you actually sold.

Recommendations for brand owners considering Schedule A enforcement in Miami

1. Plead joinder with evidence from the start. Add a joinder section supported by a declaration and seller-by-seller screenshots. Fixing it after an order to show cause costs time and credibility.
2. Group defendants by real connections. Shared listings, shared supply chains, or shared operators can justify joinder. Similar-looking storefronts cannot.
3. If you bought the mark, plead and prove the purchase. Disclose the assignment, record it promptly, and document the goodwill that came with it: inventory, supplier relationships, listings, customer accounts. Be ready to prove quality control over licensees. Judges are learning to check the USPTO’s ownership history, and a complaint that leaves it out invites suspicion.
4. Don’t buy a registration you can’t stand behind. A cheap registration with an inflated goods list, a recent first-use date and no real product history can be cancelled. It can also expose the buyer to fee awards in exceptional cases under § 1117(a). Before asserting an acquired mark, audit the specimen and the actual use.
5. Keep your registration clean. Register only the goods you actually sell. An overbroad goods list invites reexamination and weakens your claims.
6. Proofread and verify citations. Misnamed products, mistyped seller IDs and stray citations can sink an ex parte request. Judge Bloom’s order shows that the district now treats citation errors as a sanctions issue.
7. Expect to be asked for a test purchase. Courts increasingly want proof that each defendant sold infringing goods into the United States, not just screenshots of a shared listing.

What to watch

• Judge Huck’s ruling on joinder of miuning and yiqinshop, and whether CEDARFIRM files an ex parte TRO motion in that case.
• Whether Judge Bloom issues her own joinder order in the LADYGYM case.
• Whether either court asks CEDARFIRM to document its assignments from the original Chinese registrants.
• Whether the four dropped EXLEAF sellers turn up in new CEDARFIRM filings.
• Whether LABMARK (now owned by Ombre LA Inc), WINTERSWEET, PUNHURT, or any other registration traceable to the same registrants appears in new Schedule A filings.
• Whether WINTERSWEET and PUNHURT are maintained when their Section 8 windows open on December 7, 2026, and what specimens of use are filed.
• Any USPTO cancellation or reexamination filings against Reg. Nos. 7,817,152 or 7,945,631.
• Any motion for alternative service, and how each judge sets the bond for a TRO.

If you or your business have been sued for trademark infringement and/or a Schedule A case filed by CEDARFIRM LLC (and/or its law firm Palmer Law Group) in the Southern District of Florida – conduct our team of Miami trademark attorneys today at [email protected] or call 305-374-8303 on how to defend your rights in Miami Federal Court.