NOVO NORDISK A/S v. LV SOLUTIONS INC. D/B/A 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 E Washington St., Ste. 400 Tel.: (212) 908.6207 Chicago, Illinois 60602 Fax: (212) 309.1100 (312) 379-0949 Email: [email protected] [email protected] [email protected] Attorney for Defendant [email protected] 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).