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Novo Nordisk As V Lv Solutions Inc Dba Timeless Injectables

              IN THE UNITED STATES DISTRICT COURT                        
             FOR THE NORTHERN DISTRICT OF ILLINOIS                       
                       EASTERN DIVISION                                  

NOVO NORDISK A/S AND NOVO                                                 
NORDISK INC.,                                                             

         Plaintiffs,            Case No. 1:24-cv-12801                   
    v.                                                                   
LV SOLUTIONS INC. D/B/A TIMELESS                                          
INJECTABLES,                                                              
         Defendant.                                                      

    AGREED MOTION FOR ENTRY OF FINAL JUDGMENT BY CONSENT                 
    Plaintiffs Novo Nordisk A/S and Novo Nordisk Inc. (“Novo Nordisk” or “Plaintiffs”), with 
the  agreement  of  Defendant  LV  Solutions  Inc.  d/b/a  Timeless  Injectables  (“Defendant”), 
respectfully move this Court to enter a final judgment in this action in favor of Plaintiffs. In support 
of this motion, Plaintiffs state as follows:                              
    1.   Novo Nordisk filed this Complaint on December 12, 2024 (Dkt #1) alleging false 
advertising, unfair competition, and deceptive trade practices in violation of sections 43(a) of the 
Lanham Act, 15 U.S.C. § 1125(a), common law, and the Illinois Consumer Fraud and Deceptive 
Business Practices Act.                                                   
    2.   The parties have agreed to a confidential settlement agreement to resolve Plaintiffs’ 
claims.                                                                   
    3.   Attached as Exhibit A is Defendant’s signed consent to the proposed final judgment 
and permanent injunction (“Final Judgment”).                              
    4.   Upon entry of the Final Judgment, this matter will be resolved in full. 
    5.   Under the Final Judgment, this Court retains jurisdiction solely for the purpose of 
enforcing the parties’ settlement agreement, the Final Judgment, and as otherwise provided in the 
Final Judgment.1                                                          

                          CONCLUSION                                     
    For the reasons stated above, the parties respectfully move this Court to enter the attached 
Final Judgment in favor of Plaintiffs and against Defendant.              
DATED: July 22, 2025                                                      

                               Respectfully Submitted,                   
/s/ Brigid Carmichael           s/ Armin Ghiam                           
Suyash Agrawal                  Armin Ghiam                              
Hillary W. Coustan              HUNTON ANDREWS KURTH LLP                 
Brigid Carmichael               200 Park Avenue                          
MASSEY & GAIL LLP               New York, NY 10166                       
50 E Washington St., Ste. 400   Tel.: (212) 908.6207                     
Chicago, Illinois 60602         Fax: (212) 309.1100                      
(312) 379-0949                  Email: AGhiam@Hunton.com                 
sagrawal@masseygail.com                                                  
hcoustan@masseygail.com         Attorney for Defendant                   
bcarmichael@masseygail.com      LV Solutions Inc.                        

Attorneys for Plaintiffs                                                 
Novo Nordisk A/S and                                                     
Novo Nordisk Inc.                                                        






1 “When a court issues an injunction, it automatically retains jurisdiction to enforce it”. Hyzy v. Baker, No. 18-CV-
5276, 2019 WL 2576533, at *4 (N.D. Ill. June 24, 2019) citing United States v. Fisher, 864 F.2d 434, 436 (7th Cir. 
1988).