2025-cv-22763

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18547587, filed by Aramara Beauty LLC.

Civil Cover Sheet

Exhibit 1 to Complaint - Articles Regarding Plaintiff's Watermelon Glow Sle

Exhibit 2 to Complaint - Certificates of Registration for the Aramara Beauty Mar

Exhibit 3 to Complaint - Ruby McAuliffe Article

Clerks Notice of Judge Assignment to Judge Beth Bloom. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Marty Fulgueira Elfenbein is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

Complaint and Exhibit

OMNIBUS ORDER REGARDING SCHEDULE "A" CAUSES OF ACTION. Signed by Judge Beth Bloom on 6/18/2025. See attached document for full details.

Plaintiff's Corporate Disclosure Statement by Aramara Beauty LLC (Wiborg-Rodriguez, T.)

Plaintiff's RESPONSE to [4] Order by Aramara Beauty LLC. (Wiborg-Rodriguez, T.)

Plaintiff's MOTION to Seal per Local Rule 5.4 by Aramara Beauty LLC.

Text of Proposed Order

PAPERLESS ORDER granting ECF No. 7 Plaintiff's Motion to Seal. Plaintiff may file Schedule "A" to the Complaint and the Summonses under seal and they shall remain under seal until further order from this Court. Signed by Judge Beth Bloom (ap01)

SYSTEM ENTRY - Docket Entry 11 [misc] restricted/sealed until further notice. (1336528)

SYSTEM ENTRY - Docket Entry 12 [misc] restricted/sealed until further notice. (1336528)

SYSTEM ENTRY - Docket Entry 13 [misc] restricted/sealed until further notice.

SYSTEM ENTRY - Docket Entry 14 [order] restricted/sealed until further notice.

SYSTEM ENTRY - Docket Entry 15 [order] restricted/sealed until further notice.

NOTICE of Filing Bond in the amount of $10,000.00 posted by Aramara Beauty LLC Approved by Judge Beth Bloom

Plaintiff's MOTION to Unseal Case by Aramara Beauty LLC. Responses due by 7/23/2025.

Text of Proposed Order

ORDER to Unseal. Plaintiff's Motion to Unseal, ECF No. [17], is GRANTED. Signed by Judge Beth Bloom on 7/9/2025. See attached document for full details.

CLERK'S NOTICE of Compliance re 18 Order.

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Aramara Beauty LLC.

Exhibit 1 to Amended Complaint - Articles Regarding Plaintiff's Watermelon

Exhibit 2 to Amended Complaint - Certificates of Registration for the Aramara Be

Exhibit 3 to Amended Complaint - Ruby McAuliffe Article

Plaintiff's NOTICE upon Defendants via Electronic Mail by Aramara Beauty LLC re [8] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [14] Order on Ex Parte Motion, [17] Plaintiff's MOTION to Unseal Case, [1] Complaint

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Aramara Beauty LLC re [8] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [16] Bond, [9] Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law in Support Thereof, [15] Order on Ex Parte Motion, [11] Sealed Document, [12] Sealed Document, [10] Order on Motion to Seal, [14] Order on Ex Parte Motion, [17] Plaintiff's MOTION to Unseal Case, [4] Order, [7] Plaintiff's MOTION to Seal per Local Rule 5.4, [3] Form AO 120/121, [2] Clerks Notice of Judge Assignment, [1] Complaint, [5] Certificate of Other Affiliates/Corporate Disclosure Statement, [6] Response/Reply (Other) upon Defendants via website posting

Plaintiff's MOTION for Preliminary Injunction Against Defendants and Memorandum of Law in Support Thereof by Aramara Beauty LLC.

Text of Proposed Order Setting Hearing on Motion for Entry of Preliminary Injunc

Plaintiff's MOTION to Extend Temporary Restraining Order re [14] Order on Ex Parte Motion by Aramara Beauty LLC.

Text of Proposed Order

ORDER Setting Hearing on Motion DE [23] Plaintiff's MOTION for Preliminary Injunction Against Defendants and Memorandum of Law in Support Thereof : Motion Hearing set for 7/23/2025 09:00 AM via Zoom video conference before Judge Beth Bloom. Signed by Judge Beth Bloom on 7/11/2025. See attached document for full details.

ORDER granting DE [24] PLAINTIFF'S MOTION TO EXTEND TEMPORARY RESTRAINING ORDER. Signed by Judge Beth Bloom on 7/11/2025. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Aramara Beauty LLC re [26] Order on Motion for Extension of Time, [25] Order Setting Hearing on Motion

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Aramara Beauty LLC re [26] Order on Motion for Extension of Time, [25] Order Setting Hearing on Motion, upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [20] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Aramara Beauty LLC. Afunyo served on 7/11/2025, response/answer due 8/1/2025; Anko Makeup Cosmobeauty served on 7/11/2025, response/answer due 8/1/2025; Bj Hoho served on 7/11/2025, response/answer due 8/1/2025; CCdssr served on 7/11/2025, response/answer due 8/1/2025; ChangshashipingteWanju served on 7/11/2025, response/answer due 8/1/2025; Ckulufk served on 7/11/2025, response/answer due 8/1/2025; Fashionable Co.Ltd served on 7/11/2025, response/answer due 8/1/2025; Fusheng Technology served on 7/11/2025, response/answer due 8/1/2025; Godbay Co.Ltd served on 7/11/2025, response/answer due 8/1/2025; HANJING Co.Ltd served on 7/11/2025, response/answer due 8/1/2025; HGEAIJLA served on 7/11/2025, response/answer due 8/1/2025; Henan Haoyucheng Electronic served on 7/11/2025, response/answer due 8/1/2025; JUANJUANXILIU served on 7/11/2025, response/answer due 8/1/2025; Jileiy Clothing served on 7/11/2025, response/answer due 8/1/2025; JinJun served on 7/11/2025, response/answer due 8/1/2025; MMQ Inc served on 7/11/2025, response/answer due 8/1/2025; Momoko- served on 7/11/2025, response/answer due 8/1/2025; NLTLLWWU served on 7/11/2025, response/answer due 8/1/2025; Ninx served on 7/11/2025, response/answer due 8/1/2025; Pottseth served on 7/11/2025, response/answer due 8/1/2025; Qeandy served on 7/11/2025, response/answer due 8/1/2025; SUJITO Co.Ltd served on 7/11/2025, response/answer due 8/1/2025; SURU Co.Ltd served on 7/11/2025, response/answer due 8/1/2025; Tardaianiella served on 7/11/2025, response/answer due 8/1/2025; UrbanWoven served on 7/11/2025, response/answer due 8/1/2025; Weyolog served on 7/11/2025, response/answer due 8/1/2025; Xhlmnhd served on 7/11/2025, response/answer due 8/1/2025; Yuncang served on 7/11/2025, response/answer due 8/1/2025; ZAIWEN Co.Ltd served on 7/11/2025, response/answer due 8/1/2025; chnxienz served on 7/11/2025, response/answer due 8/1/2025; full-car.custom served on 7/11/2025, response/answer due 8/1/2025; htqttij served on 7/11/2025, response/answer due 8/1/2025; jiaomengmaoyi served on 7/11/2025, response/answer due 8/1/2025; lhydz served on 7/11/2025, response/answer due 8/1/2025; ruiaoxin served on 7/11/2025, response/answer due 8/1/2025; zhenzhenrishang served on 7/11/2025, response/answer due 8/1/2025.

Affidavit of Service

Affidavit of Service

PAPERLESS ORDER Pursuant to the procedures outlined in the CM/ECF Administrative Procedures, Plaintiff is to email its proposed order on the Motion for Preliminary Injunction, see ECF No. 23, to bloom@flsd.uscourts.gov in Word format. The CM/ECF Administrative Procedures may be viewed at http://www.flsd.uscourts.gov. Signed by Judge Beth Bloom (ap01)

Corrected NOTICE upon Defendants via Electronic Mail by Aramara Beauty LLC re [8] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [14] Order on Ex Parte Motion, [17] Plaintiff's MOTION to Unseal Case, [1] Complaint

Exhibit Corrected Certificate of Sevice

Corrected NOTICE upon Defendants via Electronic Mail by Aramara Beauty LLC re [26] Order on Motion for Extension of Time, [25] Order Setting Hearing on Motion

Exhibit Corrected Certificate of Sevice

NOTICE of Attorney Appearance by Andrew Jonathan Palmer on behalf of SURU Co.Ltd. Attorney Andrew Jonathan Palmer added to party SURU Co.Ltd(pty:dft).

PAPERLESS Minute Entry for proceedings held before Judge Beth Bloom, Motion Hearing held on 7/23/2025 re ECF No. 23 Plaintiff's Motion for Preliminary Injunction. For the reasons stated on the record, the Motion for Preliminary Injunction is granted. Paper Order to follow. Total time in court: 15 minutes. Attorney Appearances: T. Raquel Wiborg-Rodriguez, Annie Michaela O'Leary, Andrew Jonathan Palmer. Court Reporter: Yvette Hernandez, 305-523-5698 / Yvette_Hernandez@flsd.uscourts.gov. Signed by Judge Beth Bloom. (ap01)

ORDER GRANTING [23] PLAINTIFF'S MOTION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Beth Bloom on 7/24/2025. See attached document for full details.

NOTICE of Attorney Appearance by Andrew Jonathan Palmer on behalf of HANJING Co.Ltd. Attorney Andrew Jonathan Palmer added to party HANJING Co.Ltd(pty:dft).

ANSWER and Affirmative Defenses to Amended Complaint by HANJING Co.Ltd.

ANSWER and Affirmative Defenses to Amended Complaint by SURU Co.Ltd.

NOTICE of Striking [29] Summons Returned Executed, filed by Aramara Beauty LLC by Aramara Beauty LLC

SUMMONS (Affidavit) Returned Executed on [20] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Aramara Beauty LLC. HANJING Co.Ltd served on 7/22/2025, response/answer due 8/12/2025.

Affidavit of Service

Affidavit of Service

Affidavit of Service

Plaintiff's MOTION for Clerk's Entry of Default as to Afunyo, Anko Makeup Cosmobeauty, Bj Hoho, CCdssr, ChangshashipingteWanju, Ckulufk, Fashionable Co.Ltd, Fusheng Technology, Godbay Co.Ltd, HGEAIJLA, Henan Haoyucheng Electronic, JUANJUANXILIU, Jileiy Clothing, JinJun, MMQ Inc, Momoko-, NLTLLWWU, Ninx, Pottseth, Qeandy, SUJITO Co.Ltd, THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, Tardaianiella, UrbanWoven, Weyolog, Xhlmnhd, Yuncang, ZAIWEN Co.Ltd, chnxienz, full-car.custom, htqttij, jiaomengmaoyi, lhydz, ruiaoxin, zhenzhenrishang by Aramara Beauty LLC.

Exhibit Declaration of Stephen M. Gaffigan in Support of Request for Clerk'

Text of Proposed Order

Clerk's Notice to Filer re 40 Summons Returned Executed. Filer failed to select applicable defendants for summons returned executed. The correction was made by the Clerk. It is not necessary to refile this document but in the future, all applicable defendants must be selected.

Clerk's Entry of Default as to Afunyo, Anko Makeup Cosmobeauty, Bj Hoho, CCdssr, ChangshashipingteWanju, Ckulufk, Fashionable Co.Ltd, Fusheng Technology, Godbay Co.Ltd, HGEAIJLA, Henan Haoyucheng Electronic, JUANJUANXILIU, Jileiy Clothing, JinJun, MMQ Inc, Momoko-, NLTLLWWU, Ninx, Pottseth, Qeandy, SUJITO Co.Ltd, Tardaianiella, UrbanWoven, Weyolog, Xhlmnhd, Yuncang, ZAIWEN Co.Ltd, chnxienz, full-car.custom, htqttij, jiaomengmaoyi, lhydz, ruiaoxin, zhenzhenrishang. Signed by DEPUTY CLERK on 8/5/2025.

NOTICE of Settlement as to Defendant Number 29 by Aramara Beauty LLC (Wiborg-Rodriguez, T.)

ORDER ON DEFAULT JUDGMENT PROCEDURE. (Responses due by 9/5/2025.) Signed by Judge Beth Bloom on 8/6/2025. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Aramara Beauty LLC.

Declaration of Mee (Christine) Chang in Support Thereof

Exhibit 1 to the Declaration of Mee (Christine) Chang

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Text of Proposed Order Granting Plaintiff's Motion for Default Final Judgment

(Text of Proposed Order Default Final Judgment and Permanent Injunction)(Wiborg-Rodriguez, T.)

Joint MOTION to Approve Consent Judgment and Permanent Injunction as to Defendant Number 29 by Aramara Beauty LLC. Responses due by 9/9/2025.

(Exhibit 1 - proposed Consent Final Judgment and Permanent Injunction)(Wiborg-Rodriguez, T.)

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 29 in favor of Aramara Beauty LLC against SURU Co.Ltd. Granting DE [46] Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof filed by Aramara Beauty LLC. Signed by Judge Beth Bloom on 8/27/2025. See attached document for full details.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

(Order) (cwc)

ORDER ON MOTION FOR ENTRY OF DEFAULT FINAL JUDGMENT Granting DE 46 Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof filed by Aramara Beauty LLC Signed by Judge Beth Bloom on 8/28/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of Aramara Beauty LLC against Afunyo, Anko Makeup Cosmobeauty, Bj Hoho, CCdssr, ChangshashipingteWanju, Ckulufk, Fashionable Co.Ltd, Fusheng Technology, Godbay Co.Ltd, HANJING Co.Ltd, HGEAIJLA, Henan Haoyucheng Electronic, JUANJUANXILIU, Jileiy Clothing, JinJun, MMQ Inc, Momoko-, NLTLLWWU, Ninx, Pottseth, Qeandy, SUJITO Co.Ltd, SURU Co.Ltd, THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, Tardaianiella, UrbanWoven, Weyolog, Xhlmnhd, Yuncang, ZAIWEN Co.Ltd, chnxienz, full-car.custom, htqttij, jiaomengmaoyi, lhydz, ruiaoxin, zhenzhenrishang. The Clerk shall ADMINISTRATIVELY CLOSE the case. Signed by Judge Beth Bloom on 8/28/2025. See attached document for full details.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

ORDER ON MOTION FOR ENTRY OF DEFAULT FINAL JUDGMENT

(DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION) (cwc)

NOTICE of Settlement as to Defendant Number 12 by Aramara Beauty LLC (Wiborg-Rodriguez, T.)

STIPULATION of Dismissal With Prejudice, of Defendant Number 12 by Aramara Beauty LLC (Wiborg-Rodriguez, T.)