Juvalips LLC v. Shenzhen Mexi Tech - Complaint

CASE 0:18-cv-01872 Document 1 Filed 07/03/18 Page 1 of 11
UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
Juvalips, LLC,
) Civil Action No: TBD
Plaintiff, )
v. )
)
Shenzhen Mexi Technology )
Co., Limited, )
)
Defendant. )
)
)
COMPLAINT FOR PATENT INFRINGEMENT

& UNFAIR COMPETITION
Plaintiff states the following for its Complaint against Shenzhen Mexi Technology
Co., Limited (“Mexi”):
NATURE OF THE ACTION
1. This is an action for injunctive relief and damages arising from Mexi’s patent
infringement and unfair competition in violation of the laws of the United States.
PARTIES
2. Plaintiff Juvalips, LLC (“Juvalips”) is a Limited Liability Company formed in
the State of Minnesota with its principal place of business at 3472 88th Avenue Northeast,
Circle Pines, MN 55014-4109. Juvalips’ products are sold and offered for sale
internationally, including in this judicial district.
1
3. On information and belief, Mexi is a Chinese corporation with its principal
place of business at F/6, Unit 1, Tangzheng Technology Park, No.152, Shenzhen,
Guangdong, China 518000.
JURISDICTION AND VENUE
4. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331
(actions arising under the laws of the United States) and 28 U.S.C. § 1338(a) and (b)
(actions arising under patent infringement and unfair competition statutes).
5. This Court has personal jurisdiction over Mexi. Mexi makes its products,
including the infringing products described in this Complaint, available for purchase by
persons in this District through commercial websites accessible to and directed towards
citizens of the State of Minnesota.
6. Venue is proper under 28 U.S.C. §§ 1391 and 1400. On information and
belief, Mexi is subject to personal jurisdiction in this District and has conducted acts of
patent infringement in this District. Further, under 28 U.S.C. §1391(c)(3), a defendant not
resident in the United States may be sued in any judicial district.
FACTS
7. Brett Nelson, Juvalips’ CEO, applied for a patent on the design for a lip suction
device on April 7, 2016. That application resulted in U.S. Design Patent No. D819,222,
which issued on May 29, 2018 (“the ‘222 patent”) and is attached as Exhibit A. Figure 1
of the ‘222 patent above depicts one view of the claimed design.
2
9. Figure 6 of the ‘222 Patent, below, depicts a second view of the claimed
design.
10. Figure 7 of the ‘222 Patent, below, depicts a third view of the claimed
design.
3
11. By virtue of assignment, Juvalips is the owner of all right, title, and interest
to the ‘222 patent and has been since the ‘222 patent issued.
12. Juvalips has commercialized the lip suction device design depicted in the ‘222
patent through direct sales under the Juvalips name. Thousands of Juvalips’ patented lip
suction devices are now in use in the U.S. and around the world.
PATENT INFRINGEMENT BY MEXI
13. Mexi has offered for sale, sold, and continues to sell in the United States
products with a design covered by the ‘222 patent. These infringing products, which have
a shape, color scheme and overall appearance plainly copied from Juvalips’ own lip
plumper device, include the “Lip Plumper Device” (“Mexi Lip Plumper”) shown in the
following Illustration A. This illustration (taken from a Mexi online product listing)
depicts the Mexi Lip Plumper.
Illustration A
14. Mexi Lip Plumpers have been offered for sale in Minnesota via online
4
commercial channels, one of which is found at
https://www.amazon.com/dp/B07C1M982X/. On information and belief, Defendant has
sold units of the Mexi Lip Plumpers in Minnesota.
15. On information and belief, the Mexi Lip Plumper is being sold by other sellers
or in combination with other sellers on Amazon including Shenzhen Winkion Industrial
Co., Ltd. and Fernida.
16. Juvalips has not authorized or licensed Mexi (nor any of Mexi’s agents,
officers, or affiliates) to offer to sell or sell products with a design covered by the ‘222
patent. Mexi does not have any license or authorization to do so.
17. Mexi has infringed and continues to infringe the ‘222 patent by selling and/or
offering to sell the infringing products without Juvalips’ authorization or license.
18. Unauthorized sales of products covered by the ‘222 Patent cause direct
economic harm to Juvalips.
19. On May 31, 2018, Juvalips mailed, via Priority Mail, a letter to the office
address of Mexi expressing its patent infringement concerns and demanding that Mexi
cease all such conduct. Juvalips provided a copy of the ‘222 Patent with the demand
letter. Mexi has denied infringement and has not ceased sales.
UNFAIR COMPETITION BY MEXI
20. Mexi has utilized numerous false and misleading advertising claims regarding
safety and performance in the sale of its Mexi Lip Plumpers. Mexi has made the following
5
statements about its own products:
• “Strictly passed all the testing like CE, ROHS and FDA, these international
standards to ensure every our customer feel free to use it.” (Amazon
product page);
• “….this product has passed strict testing with all the certificate like: CE,
ROHS, FCC, FDA and etc. It is the most basic thing to keep safety for our
customer…” (Amazon product page); and
• Use of the mark on the Mexi Lip Plumper product box.
21. On information and belief, the Mexitop Lip Plumpers have not been the
subject of any FDA or CE mark testing or certifications. On further information and belief,
there are no FDA or CE certification standards for motorized lip plumpers. The
representation that the Mexitop Lip Plumper product has passed FDA or CE product
testing requirements is, on information and belief, an egregious false statement on product
safety and a violation of FDA and CE regulations.
22. Mexi has also made the following safety claims about its product:
• “Intelligent Pause & Shut Off Function Design for Safety, Easy to Use with
LED Lights Indication. Unlike other full lips device, you have to go
through all the process to stop the device” (Amazon product page);
• “Do not use the device for more than one or two of the timed 60 second
applications during the first few times you try the device.” (Mexi Product
6
User Guide); and
• “It is automatically timed and will stop after 20 minutes” (Mexi Product
User Guide).
23. Mexi is stating that its product has an “intelligent pause” and then, in the same
user guide, is stating the timed pause and shutoff length is 60 seconds and that the timed
pause and shutoff length is 20 minutes.
24. On information and belief, the statement that the product has a 60-second
safety pause and shutoff is wholly false. That statement is in a section of text in the Mexi
User Guide that was copied identically from the user guide for Juvalips’ own lip product,
which does have a 60-second safety shutoff. This is an act of copyright infringement that
further results in a false product safety claim.
25. Mexi’s statement that “Unlike other full lips device, you have to go through
all the process to stop the device” is, on information and belief, an effort at a false
statement that the Juvalips lip plumper either does not have a safety pause and shutoff or
that it cannot be stopped manually during operation and must complete a timed cycle. In
either instance, the statement is a grossly false statement that the Juvalips lip plumper is
unsafe for the user and amounts to product disparagement that has directly damaged sales
of the Juvalips product.
7
COUNT 1:
INFRINGEMENT OF THE
‘222 PATENT
26. Juvalips incorporates by reference and realleges herein the foregoing
paragraphs of this Complaint.
27. Mexi has made, used, sold, offered to sell, or imported into the United States,
the Mexi Lip Plumper, which infringe the ‘222 patent.
28. Mexi will continue to infringe the ‘222 patent unless enjoined by the Court.
29. On information and belief, Mexi’s infringement has been intentional and
willful. Juvalips has placed Mexi on actual notice of the ‘222 Patent and demanded that
Mexi cease further infringement. However, on information and belief, Mexi continues to
sell its infringing Mexi Lip Plumper.
30. Due to Mexi’s infringement of the ‘222 patent, Juvalips has suffered, is
suffering, and will continue to suffer irreparable injury.
31. As a result of Mexi’s infringement, Juvalips has suffered damages. Juvalips is
entitled to recover damages against Mexi, which may take the form of its lost profits as a
result of Mexi’s infringement or a reasonable royalty, both under 35 U.S.C. § 284, or
alternatively, Mexi’s profits under 35 U.S.C. § 289.
COUNT 2:
UNFAIR COMPETITION UNDER
THE LANHAM ACT, 15 U.S.C. § 1125(b)
32. Juvalips incorporates by reference and realleges herein the foregoing
8
paragraphs of this Complaint.
33. Mexi has made numerous false and misleading statements and representations
regarding the nature and characteristics of its Mexi Lip Plumper device as well as the
Juvalips lips plumper device. These include false and misleading statements regarding
regulatory approval and product safety.
34. Mexi’s advertising and promotion of the Mexi Lip Plumper with the false
advertising and product misrepresentations contravenes the provisions of 15 U.S.C. §
1125(b).
35. Mexi will continue its acts of false advertising and unfair competition unless
enjoined by the Court.
36. On information and belief, Mexi’s acts of false advertising and unfair
competition have been intentional and willful.
37. Mexi’s false advertising and unfair competition have caused and will continue
to cause Juvalips damages in an amount to be determined at trial.
PRAYER FOR RELIEF
WHEREFORE, Juvalips, LLC respectfully prays for:
A. Judgment against Shenzhen Mexi Technology Co., Limited
(“Mexi”) that it has infringed the ‘222 patent in violation of 35 U.S.C. § 271(a) by selling
or offering to sell the Mexi Lip Plumper;
B. Judgment against Mexi that such infringement was willful;
9
C. An injunction pursuant to 35 U.S.C. § 283 against further
infringement of the ‘222 patent by Mexi and its agents, servants, employees, officers and
all others controlled by Mexi;
D. An award of damages adequate to compensate Juvalips for the
patent infringement that has occurred pursuant to 35 U.S.C. § 284, subject to trebling for
willful infringement by Mexi, or an award of Mexi’s profits from its infringement
pursuant to 35 U.S.C. § 289, whichever is greater;
E. An assessment of costs, including reasonable attorney’s fees,
including but not limited to fees available under 35 U.S.C. § 285, with prejudgment
interest;
F. Judgment against Mexi that it has committed acts of false
advertising and unfair competition in violation of 15 U.S.C. § 1125(b) by importing,
selling or offering to sell the Mexi Lip Plumper with the use of false advertising claims;
G. Judgment against Mexi that such unfair competition was willful;
H. An injunction under 15 U.S.C. § 1116(a) against further acts of
unfair competition by Mexi and its agents, servants, employees, officers, affiliates and all
others controlled by Mexi;
I. An award of damages adequate to compensate Juvalips for the
unfair competition that has occurred pursuant to 15 U.S.C. § 1117(a), including Juvalips’
lost profits and Mexi’s profits, together with prejudgment interest and costs;
10
J. An accounting for any acts of patent infringement and unfair
competition that occur between the finding of infringement and unfair competition and
the entry of an injunction;
K. Such other and further relief as this Court deems just and proper.
JURY DEMAND
Juvalips demands a trial by jury.
Dated: July 3, 2018 GRUMBLES LAW PLLC
By s/Ernest W. Grumbles/
Ernest W. Grumbles (No. 274793)
287 6th St. E, Suite 140

Saint Paul, Minnesota 55101
Telephone: (612) 465-8090
LAWDER LAW, PLLC
By s/Joseph S. Lawder/
Joseph S. Lawder (No. 236147)
413 Wacouta St., Suite 250

Saint Paul, Minnesota 55101
Telephone: (651) 252-1955
ATTORNEYS FOR PLAINTIFF

JUVALIPS, LLC
11
CASE 0:18-cv-01872 Document 1-1 Filed 07/03/18 Page 1 of 7
UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
Juvalips, LLC,
) Civil Action No: TBD
Plaintiff, )
v. )
)
Shenzhen Mexi Technology )
Co., Limited, )
)
Defendant. )
)
)
PLAINTIFF JUVALIPS, LLC’S COMPLAINT EXHIBIT A

‘222 PATENT
1
JS 44 (Rev. 06/17) CIVIL
CASE 0:18-cv-01872 COVER
Document 1-2SHEET
Filed 07/03/18 Page 1 of 2
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Juvalips, LLC Shenzhen Mexi Technology Co., Limited
(b) County of Residence of First Listed Plaintiff Anoka County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Ernest W. Grumbles Joseph S. Lawder
Grumbles Law PLLC Lawder Law, PLLC
th
287 6 St. E, Ste. 140 413 Wacouta St., Ste. 250
St. Paul, MN 55101 St. Paul, MN 55101
612-465-8090 651-252-1955
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards 861 HIA (1395ff) 490 Cable/Sat TV
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 862 Black Lung (923) 850 Securities/Commodities/
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management 863 DIWC/DIWW (405(g)) Exchange
195 Contract Product Liability 360 Other Personal Property Damage Relations 864 SSID Title XVI 890 Other Statutory Actions
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 865 RSI (405(g)) 891 Agricultural Acts
362 Personal Injury - Product Liability 751 Family and Medical 893 Environmental Matters
Medical Malpractice Leave Act 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation FEDERAL TAX SUITS Act
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 870 Taxes (U.S. Plaintiff 896 Arbitration
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act or Defendant) 899 Administrative Procedure
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRS—Third Party Act/Review or Appeal of
240 Torts to Land 443 Housing/ Sentence 26 USC 7609 Agency Decision
245 Tort Product Liability Accommodations 530 General 950 Constitutionality of
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION State Statutes
Employment Other: 462 Naturalization Application
446 Amer. w/Disabilities - 540 Mandamus & Other -465 Other Immigration
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)

1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. Sec. 271; 15 U.S.C. Sec. 1125(b)
VI. CAUSE OF ACTION Brief description of cause:
Patent infringement and unfair competition claims seeking injunction and damages.
Monetary and
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $
injunctive relief
CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P.
JURY DEMAND: Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
07/03/2018 s/Joseph S. Lawder/
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

JS 44 Reverse (Rev. 06/17) CASE 0:18-cv-01872 Document 1-2 Filed 07/03/18 Page 2 of 2
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.
V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.

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CASE 0:18-cv-01872 Document 1 Filed 07/03/18 Page 1 of 11

UNITED STATES DISTRICT COURT

COMPLAINT FOR PATENT INFRINGEMENT

Co., Limited (“Mexi”):

NATURE OF THE ACTION

2. Plaintiff Juvalips, LLC (“Juvalips”) is a Limited Liability Company formed in

internationally, including in this judicial district.

3. On information and belief, Mexi is a Chinese corporation with its principal

place of business at F/6, Unit 1, Tangzheng Technology Park, No.152, Shenzhen,

Guangdong, China 518000.

JURISDICTION AND VENUE

4. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331

(actions arising under patent infringement and unfair competition statutes).

citizens of the State of Minnesota.

6. Venue is proper under 28 U.S.C. §§ 1391 and 1400. On information and

resident in the United States may be sued in any judicial district.

PATENT INFRINGEMENT BY MEXI

depicts the Mexi Lip Plumper.

commercial channels, one of which is found at

https://www.amazon.com/dp/B07C1M982X/. On information and belief, Defendant has

sold units of the Mexi Lip Plumpers in Minnesota.

or in combination with other sellers on Amazon including Shenzhen Winkion Industrial

Co., Ltd. and Fernida.

patent. Mexi does not have any license or authorization to do so.

offering to sell the infringing products without Juvalips’ authorization or license.

economic harm to Juvalips.

UNFAIR COMPETITION BY MEXI

statements about its own products:

customer…” (Amazon product page); and

• Use of the mark on the Mexi Lip Plumper product box.

safety and a violation of FDA and CE regulations.

User Guide); and

pause and shutoff length is 20 minutes.

further results in a false product safety claim.

of the Juvalips product.

26. Juvalips incorporates by reference and realleges herein the foregoing

paragraphs of this Complaint.

the Mexi Lip Plumper, which infringe the ‘222 patent.

sell its infringing Mexi Lip Plumper.

suffering, and will continue to suffer irreparable injury.

31. As a result of Mexi’s infringement, Juvalips has suffered damages. Juvalips is

result of Mexi’s infringement or a reasonable royalty, both under 35 U.S.C. § 284, or

alternatively, Mexi’s profits under 35 U.S.C. § 289.

32. Juvalips incorporates by reference and realleges herein the foregoing

paragraphs of this Complaint.

regulatory approval and product safety.

advertising and product misrepresentations contravenes the provisions of 15 U.S.C. §

enjoined by the Court.

competition have been intentional and willful.

to cause Juvalips damages in an amount to be determined at trial.

PRAYER FOR RELIEF

WHEREFORE, Juvalips, LLC respectfully prays for:

A. Judgment against Shenzhen Mexi Technology Co., Limited

or offering to sell the Mexi Lip Plumper;

B. Judgment against Mexi that such infringement was willful;

C. An injunction pursuant to 35 U.S.C. § 283 against further

all others controlled by Mexi;

D. An award of damages adequate to compensate Juvalips for the

willful infringement by Mexi, or an award of Mexi’s profits from its infringement

pursuant to 35 U.S.C. § 289, whichever is greater;

E. An assessment of costs, including reasonable attorney’s fees,

F. Judgment against Mexi that it has committed acts of false

advertising and unfair competition in violation of 15 U.S.C. § 1125(b) by importing,

G. Judgment against Mexi that such unfair competition was willful;