Lokai Holdings v. Twin Tiger - Complaint

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 1 of 17
Mark J. Rosenberg
Amy B. Goldsmith
TARTER KRINSKY & DROGIN LLP
1350 Broadway
New York, New York 10018
Telephone: 212-216-8000
Facsimile: 212-216-8001
mrosenberg@tarterkrinsky.com
agoldsmith@tarterkrinsky.com
Attorneys for Lokai Holdings LLC
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
LOKAI HOLDINGS LLC,

Case No. 15-CV-9363
Plaintiff,
THIRD AMENDED COMPLAINT
v.
TWIN TIGER USA LLC, TWIN TIGER
WORLD MARKETS LTD., RORY
COPPOCK and TROY COPPOCK,
JURY TRIAL DEMANDED
Defendants.
Lokai Holdings LLC (Lokai), by its attorneys, Tarter Krinsky & Drogin LLP, for its
Third Amended Complaint against Defendants Twin Tiger USA LLC, Twin Tiger World
Markets Ltd., Rory Coppock and Troy Coppock (collectively, Defendants) alleges as follows:
NATURE OF THE ACTION
1.
This is an action for design patent infringement arising under the Patent Act, 35
U.S.C. 101 et seq., and trade dress infringement and unfair competition arising under the
provisions of the Trademark Act of 1946, 15 U.S.C. 1051 et seq., particularly under 15 U.S.C.
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1125(a) and the common law.

JURISDICTION AND VENUE
2.
This Court has jurisdiction over the subject matter of this action pursuant to 15
U.S.C. 1121; and 28 U.S.C. 1331, 1338 and 1367. Venue is proper in this judicial district
pursuant to 28 U.S.C. 1391. Defendants are transacting and doing business within this judicial
district, are committing the acts complained of herein within this judicial district, have otherwise
directed their illegal conduct complained of herein to this judicial district and are subject to the
jurisdiction of this Court pursuant to Rule 4 of the Federal Rules of Civil Procedure.
THE PARTIES
3.
Lokai is a limited liability company organized and existing under the laws of the
State of Delaware, having a principal place of business at 36 East 31st Street, Suite 602, New
York, New York.
4.
Upon information and belief, defendant Twin Tiger USA LLC (Tiger USA) is a
limited liability company with a place of business at 520 Esplanade, #B, Redondo Beach,
California.
5.
Upon information and belief, defendant Twin Tiger World Markets Ltd. (Tiger
World Markets) is a limited liability company with a place of business at 520 Esplanade, #B,
Redondo Beach, California.
6.
Upon information and belief, defendants Rory Coppock and Troy Coppock are
individuals who have a place of business in Redondo Beach, California, are the principals and
owners of both Tiger USA and Tiger World Markets and direct and control the activities of Tiger
USA and Tiger World Markets including the infringing activities alleged herein.
7.
Upon information and belief, Defendants regularly do business in this District by,
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among other things, offering and selling products, including the infringing products alleged
herein, to persons located within this District.
Lokai and Its Business
8.
Lokai is a socially responsible lifestyle brand that represents the importance of
finding balance along lifes journey. Cornell University Cum Laude Graduate, Steven Izen,
launched the company in 2013, on the heels of a deeply emotional and transformative
experience. Realizing that life is a cycle of highs and lows, he grew to appreciate the importance
of remaining both humble and hopeful. The company infuses its trademarked bracelets with
elements sourced from the highest and lowest points on Earth - water from Mt. Everest and mud
from the Dead Sea. The Lokai lifestyle is devoted to finding balance, sharing success during
lifes peaks and gaining perspective during lows. Lokai supports this message by donating 10%
of their net profits to various charitable organizations.
9.
Commencing in 2013, long prior to the acts of the Defendants complained of
herein, all of the beaded bracelets offered and sold by Lokai have featured the same distinctive
trade dress which includes substantially spherical silicon beads of substantially the same size and
color integrated with each other at opposite poles with a single pair of contrasting colored beads
diametrically opposed to each other, with each of the contrasting beads embossed with the Lokai
teardrop
design mark, and a circular cardboard hangtag affixed to the bracelet by an
integrated horizontal cardboard looping member (collectively, the LOKAI Trade Dress)
(collectively, the LOKAI Trade Dress). Photographs showing the LOKAI Trade Dress are
attached hereto as Exhibit 1.
10.
The contrasting beads of the LOKAI Trade Dress are intended to represent
balance and the cycle of life with the dark bead filled with mud from the Dead Sea, the lowest
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point on earth, and the light colored bead filled with water from Mount Everest, the highest point
on earth. Since June 2013, the symbolism embodied by the LOKAI Trade Dress has been
described on Lokais www.myLokai.com website (the Lokai Website), which states [e]ach
lokai is infused with elements from the highest and lowest points on Earth. The bracelets white
bead carries water from Mt. Everest, and its black bead contains mud from the Dead Sea. These
extreme elements are a reminder to the wearer to live a balanced life staying humble during
lifes peaks and hopeful during its lows. True and correct copies of the relevant portions of the
Lokai Website are attached hereto as Exhibit 2.
11.
Since June 2013, the symbolism of balance has been prominently featured on the
hangtags affixed to bracelets bearing the LOKAI Trade Dress. These hangtags state in large
letters, FIND YOUR BALANCE.
12.
In order to ensure that Lokais message of balance and charity is not diminished
during the sales process, Lokai carefully selects the distributors of its bracelets bearing the
LOKAI Trade Dress and avoids those which may adversely affect Lokais message and
reputation.
13.
Since being introduced to the public in 2013, sales and the renown of bracelets
bearing the LOKAI Trade Dress quickly grew. By 2014, bracelets bearing the LOKAI Trade
Dress enjoyed substantial sales and wide recognition by the purchasing public, the trade and the
media. Among other things, by 2014, Lokais bracelets bearing the LOKAI trade dress were
offered at over 1,000 locations throughout the United States and on the Internet on Lokais
www.myLokai.com website (the Lokai Website) as well as websites operated by authorized
third party distributors, generating many millions of dollars of sales. In 2014 alone, the Lokai
Website and Lokais LiveLokai Instagram account, both of which feature photographs of
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bracelets bearing the LOKAI Trade Dress and persons wearing these bracelets had, respectively,
millions of visits and over 300,000 followers; and bracelets bearing the LOKAI Trade Dress
were featured in the media including in the Huffington Post, Twist, J-14 and Milkshake.
Attached hereto as Exhibits 3-6 are true and correct copies of a representative sample of media
mentions featuring the LOKAI Trade Dress in 2014.
14.
The rapid success of the Lokais bracelets bearing the LOKAI Trade Dress
continued into 2015, with the bracelets now being distributed at over 2,500 locations throughout
the United States and through additional websites, generating many millions of dollars in
additional sales. In conjunction with the sales success of Lokais bracelets bearing the LOKAI
Trade Dress came additional public recognition, with millions of additional visits to the Lokai
Website, and exponential growth of the number of followers of the LiveLokai Instagram account
rising to 500,000 followers in March, 2015, over 1 million followers by September, 2015, and
presently over 1.3 million followers. In addition, many more media and social media outlets
featured articles describing or displaying bracelets bearing the LOKAI Trade Dress prior to May
2015 including The Wall Street Journal, Self, US, The Daily Mail, Christianity Today, Star,
Foxs Good Day LA, and Kourtney Kardashians Instagram account, which at the time had
over 1.2 million followers. In addition, in 2014 and early 2015, the media and social media
featured photographs of celebrities wearing Lokais bracelets bearing the LOKAI Trade Dress.
These celebrities included Justin Bieber, Diane von Furstenberg, Jeremy Piven, Emma Roberts,
Zac Efron, Catherine Zeta Jones, Victoria Justice, Ashley Green, Vanessa Hudgens, Bella
Thorne and Kris Jenner. Attached hereto as Exhibits 7-12 are true and correct copies of a
representative sample of media and social media mentions featuring the LOKAI Trade Dress in
early 2015.
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15.
The quick growth and fame of Lokai and its bracelets bearing the LOKAI trade
dress has enabled Lokai to make good on its mission to make substantial donations to charity.
These charities have included the Susan G. Komen Foundation, the Word Wildlife Fund, Cure
Alzheimer's Fund and Charity:Water.
16.
By virtue of the wide renown acquired by the LOKAI Trade Dress, coupled with
the extensive distribution and sales of bracelets offered under the LOKAI Trade Dress
throughout the United States along with the widespread media and social media presence and
advertising of bracelets bearing the LOKAI Trade Dress, the LOKAI Trade Dress, prior to the
acts of the Defendants complained of herein, became famous and developed a secondary
meaning and significance in the minds of the purchasing public, such that bracelets bearing this
trade dress were and continue to be immediately identified by the purchasing public with a single
source, namely Lokai.
17.
Bracelets bearing the LOKAI Trade Dress are widely recognized by the
purchasing public throughout the United States to be of the highest quality, offered and sold
under superior customer service conditions. As a result thereof, the LOKAI Trade Dress and the
goodwill associated therewith are of inestimable value to Lokai.
18.
On January 26, 2016, United States Design Patent No. D748,000 (the 000
Patent) was duly and legally issued by the United States Patent and Trademark Office. The 000
patent has remained in force since that time and continues to be in force. A true and correct copy
of the 000 Patent is attached hereto as Exhibit 15.
19.
Lokai is the owner by assignment of the 000 Patent.
20.
The 000 Patent covers the ornamental design of a bracelet. Lokai has practiced
and continues to practice the 000 Patent in connection with its marketing and sales of its LOKAI
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bracelets, representative samples of which are shown hereto as Exhibit 1.

Defendants Unlawful Activities
21.
Upon information and belief, in or about mid-2015, two years after Lokais
adoption and commencement of use of the LOKAI Trade Dress and after this trade dress had
become famous and acquired secondary meaning, Defendants, in an attempt to piggyback off of
the fame and success of Lokai and its LOKAI Trade Dress, began using unauthorized imitations
of the LOKAI Trade Dress in connection with the offering and sale of silicon beaded bracelets.
22.
In particular, in or about mid-2015, Defendants, without Lokais authorization,
began offering and selling bracelets constructed of substantially spherical silicon beads of
substantially of the same size and color integrated with each other at opposite poles with a single
pair of contrasting colored beads diametrically opposed to each other, with one of the contrasting
beads embossed with the ankh symbol,
which is also known as the breath of life, and a
circular cardboard hangtag affixed to the bracelet by an integrated horizontal cardboard looping
member (collectively, the Infringing Trade Dress). A true and correct copy of a photograph of
Defendants products, marketed as Life Bracelets, bearing the Infringing Trade Dress,
(collectively, the Infringing Products), are attached hereto as Exhibit 13.
23.
Not satisfied with simply the copying LOKAI Trade Dress, Defendants aped the
symbolism of balance and the cycle of life embodied in the LOKAI Trade Dress. Among other
things,
A.
In verbiage paraphrased from the Lokai Website, Defendants, on their

website at www.balanceyourlifebracelet.com, (Defendants Website),
state [e]ach Life Bracelet has properties from the highest & lowest points
on earth. The grey bead has earth from below sea level. The green bead
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has water from the mountains. Our life bracelet elements are a reminder to
the wearer to be grounded & live a well & balanced life. A true and
correct copy of the relevant portion of Defendants Website is attached
hereto as Exhibit 14.
B.
Some of the hangtags for some of the Infringing Products prominently

state, Live a balanced life; while other hangtags state Balance
Bracelet. (See Exhibit 13).
C.
Until recently, the pages of Defendants Website, which includes the tag
line balance your life in its domain name, features pages that are
prominently titled, whats your balance?; live a balanced life and
balance.
24.
Given Defendants (i) use of a design for the Infringing Products that is nearly
identical to the LOKAI Trade Dress, (ii) infusion of mud and water from, respectively, the
lowest and highest points on earth into the contrasting beads of the Infringing Products, (iii)
copying of the balance symbolism embodied by the Lokai bracelets bearing the LOKAI Trade
Dress; and (iv) paraphrasing of portions of the Lokai Website, Defendants, upon information and
belief, prior to commencing their infringing activities complained of herein knew of Lokai, the
LOKAI Trade Dress and Lokais rights therein.
25.
None of the Defendants have Lokais consent, written or otherwise, to use the
LOKAI Trade Dress or the design claimed in the 009 Patent.

26.
Upon information and belief, defendants Rory Coppock and Troy Coppock
directed Tiger USA and Tiger Marketing to use and display the Infringing Products including on
the Defendants Website and on the website located at www.twintigerusa.com.
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27.
Upon information and belief, defendants Rory Coppock and Troy Coppock
directed and continue to direct the design, development, marketing and sales of the Infringing
Products.
28.
The Infringing Trade Dress is nearly identical to the LOKAI Trade Dress. The
Infringing Products offered in connection with the Infringing Trade Dress are identical, related,
complementary or similar to bracelets services offered by Lokai under the LOKAI Trade Dress.
29.
The Infringing Products, like the design claimed in the 000 Patent, consist of
substantially spherical beads of substantially the same size arranged in a circle with a single pair
of contrasting colored beads diametrically opposed to each other.
30.
The Infringing Products embody the design claimed in the 000 Patent.
31.
A side-by-side comparison of the design claimed in the 000 Patent, a
representative Infringing Product and a LOKAI bracelet is shown below:

U.S.PatentNo.D748,000
InfringingProduct
LOKAIBracelet
32.
As shown in the above comparison, the design of the Infringing Products is the
same or substantially the same as the design claimed in the 000 Patent and reflected in LOKAI
bracelets. The designs are so similar as to be nearly identical such that an ordinary observer,
giving such attention as a purchaser usually gives, would be so deceived by the substantial
similarity between the designs so as to be induced to purchase the Infringing Products believing
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them to be substantially the same as the bracelet design protected by the 000 Patent.
33.
Lokai has not granted a license or any other authorization to Defendants to make
use, offer for sale, sell or import bracelets that embody the design patented in the 000 Patent
which is proprietary to Lokai.
34.
Upon information and belief, the Infringing Products are of lesser quality than
Lokais bracelets bearing the LOKAI Trade Dress.

35.
This unauthorized use of the Infringing Trade Dress is likely to create and foster
the false impression that Defendants business and the products they offer originate from are
authorized by or affiliated with Lokai.
36.
By letter dated May 1, 2015, Lokai put Defendants on notice of their infringing
conduct and demanded that they cease and desist from their violation of Lokais rights in and to
the LOKAI Trade Dress. Defendants failed to comply with these demands.
37.
Upon information and belief, Defendants selected and decided to use and
commenced using the Infringing Trade Dress with knowledge or in reckless disregard of the
LOKAI Trade Dress.
38.
Defendants adoption and use of the Infringing Trade Dress was and continues to
be without permission or authority of Lokai.

39.
Upon information and belief, the Infringing Products are directly competitive with
the Lokais products bearing the LOKAI Trade Dress and are offered and sold to some of the
same consumers to whom products bearing the LOKAI Trade Dress are offered and sold.
40.
Defendants use of the Infringing Trade Dress is without permission or authority
of Lokai and such use has been and continues to be in a manner that is likely to cause confusion,
mistake and to deceive.
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10
41.
Defendants use of the Infringing Trade Dress is likely to lead others to
mistakenly believe that bracelets offered in connection with the Infringing Trade Dress originate
from or are in some way associated with, sponsored, authorized or endorsed by, or related to
Lokai.
AS AND FOR A FIRST CAUSE OF ACTION
Patent Infringement under 35 U.SC. 271
42.
Lokai repeats and realleges the allegations of paragraphs 1 through 41 as if fully
set forth herein.

43.
This claim arises under the provisions of the Patent Laws, particularly under 35
U.S.C. 271, and alleges the infringement of a design patent.

44.
Defendants have infringed, and continue to infringe the 000 Patent by,inter alia,
making, having made, importing, offering to sell, or selling in this District, and elsewhere in the
United States, the Infringing Products, the design of which is substantially the same as the
ornamental design claimed in the 000 Patent.
45.
Defendants actions constitute infringement of the 000 Patent in violation of 35
U.S.C. 271 because, inter alia, in the eye of an ordinary observer, giving such attention as a
purchaser usually gives, the design of the Infringing Products and the design claimed in the 000
Patent are substantially the same, the resemblance being such as to deceive such an ordinary
observer, inducing him to purchase one supposing it to be the other.
46.
Defendants acts of infringement set forth herein were undertaken without
authority, permission or license from Lokai.

47.
Defendants infringement has damaged and continues to damage and injure
Lokai. The injury to Lokai is irreparable and will continue unless and until Defendants are
enjoined from further infringement.
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11
48.
Lokai is entitled to a complete accounting of all revenue and profits derived by
Defendants from the unlawful conduct alleged herein, including without limitation, Defendants
total profit pursuant to 35 U.S.C. 289.
49.
Defendants have engaged and are engaged in willful and deliberate infringement
of the 000 Patent. Such willful and deliberate infringement justifies an increase of three times
the damages to be assessed pursuant to 35 U.S.C. 284 and further qualifies this action as an
exceptional case supporting an award of reasonable attorney's fees pursuant to 35 U.S.C. 285.
50.
Lokai is entitled to a permanent injunction preventing Defendants from further
infringing the 000 Patent.

AS AND FOR A SECOND CAUSE OF ACTION
Unfair Competition under 15 U.S.C. 1125(a)
51.
Lokai repeats and realleges the allegations of paragraphs 1 through 50 as if fully
set forth herein.

52.
This claim arises under the provisions of the Trademark Act of 1946, 15 U.S.C.
1051 et seq., particularly under 15 U.S.C. 1125(a), and alleges the use in commerce of false
designations of origin, false descriptions and false representations.
53.
Prior to the acts of the Defendants complained of herein, Lokai extensively
marketed, promoted and used the LOKAI Trade Dress throughout the United States to identify
its products and to distinguish them from those provided by others. By reason of the
distinctiveness of the LOKAI Trade Dress, this trade dress indicates to customers, potential
customers and the trade that bracelets bearing the LOKAI Trade Dress are offered and provided
by Lokai.
54.
As a result of Lokais marketing, promotion and substantial sales of bracelets
bearing the LOKAI Trade Dress, the LOKAI Trade Dress has developed and has a secondary
{Client/082577/25/01063079.DOCX;1}
12
and distinctive meaning to customers, potential customers and the trade so that bracelets bearing
this trade dress are known and understood to originate from a single source, namely Lokai.
55.
Upon information and belief, Defendants, have used the Infringing Trade Dress
with the express intent to cause confusion and mistake, to deceive and mislead the purchasing
public, to trade upon the reputation of Lokai and to improperly appropriate Lokais valuable
trade dress rights.
56.
Defendants use and continued use of the Infringing Trade Dress will cause and is
likely to cause confusion, mistake or deception in the minds of the trade and purchasing public
and create the erroneous impression that Defendants use of the Infringing Trade Dress and the
provision of the Infringing Products under that trade dress are authorized, endorsed, sponsored,
authorized or approved by Lokai or, alternatively, that the offering of bracelets bearing the
LOKAI Trade Dress are provided, authorized, endorsed, sponsored, authorized or approved by
Defendants.
57.
Defendants use of the Infringing Trade Dress constitutes a use in interstate
commerce of a false designation of origin and a false and misleading description and
representation of goods in commerce, with knowledge of the falsity, which has and is likely to
cause confusion, mistake and deception and a use in commercial advertising and promotion
which misrepresents the nature, characteristics, qualities and origin of the Defendants goods and
commercial activities, all within the meaning and in violation of 15 U.S.C. 1125(a).
58.
Defendants use and continued use of the Infringing Trade Dress is causing and,
unless enjoined, will continue to cause irreparable harm and damage to Lokai and its business,
reputation and goodwill and has caused Lokai to suffer monetary damages in an amount not thus
far determined.
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13
59.
Unless restrained and enjoined, the Defendants aforesaid acts will cause Lokai
irreparable harm and damage for which there is no adequate remedy at law.
AS AND FOR A THIRD CAUSE OF ACTION
Common Law Unfair Competition
60.
Lokai repeats and realleges the allegations contained in Paragraphs 1-59 as if fully
set forth herein.

61.
This claim arises under the common law of this District relating to trade dress
infringement and unfair competition.

62.
As more fully set forth above, the LOKAI Trade Dress has come to have a
secondary meaning indicative of origin, relationship, authorization, sponsorship and/or

association with Lokai. As a result, the purchasing public and the trade are likely to attribute to
Lokai Defendants use of the Infringing Trade Dress as a source of origin, authorization and/or
sponsorship of Defendants products, and therefore, to purchase Defendants products based on
that erroneous belief or, alternatively, attribute to Defendants the authorized use of the LOKAI
Trade Dress as a source of origin, authorization and/or sponsorship of Lokais goods, and
therefore, to purchase Lokais goods based on that mistaken belief.
63.
Upon information and belief, Defendants intentionally appropriated the LOKAI
Trade Dress and the goodwill associated therewith with the intent of causing confusion, mistake,
and deception as to the source of origin, relationship, sponsorship, and/or association of
Defendants goods, and with the intent to palm off its goods as those of Lokai, and, as such,
Defendants has committed unfair competition under the common law.
64.
The Defendants use and continued use of the LOKAI Trade Dress has caused, is
causing and, unless enjoined, will continue to cause irreparable harm and damage to Lokai and
its business, reputation and goodwill and has caused Lokai to suffer monetary damages in an
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14
amount not thus far determined.

65.
By reason of such infringement, unfair competition and misappropriation and by
Defendants promotion and offering of the Infringing Products bearing the Infringing Trade
Dress, Defendants have caused, and unless restrained and enjoined will continue to cause,
irreparable injury to Lokais reputation and goodwill and otherwise damage Lokai in an amount
not thus far determined.
66.
Defendants conduct in intentionally misappropriating Lokais goodwill and
engaging in unfair competition was intended to wrongfully enrich Defendants and to deliberately
and willfully injure Lokai in wanton disregard of Lokais rights and Defendants legal
obligations. Lokai is therefore entitled to an award of punitive damages in an amount of no less
than $10,000,000.
67.
Unless restrained and enjoined, Defendants continuing acts of infringement and
unfair competition will cause irreparable harm and damage to Lokai for which there is no
adequate remedy at law.
PRAYER FOR RELIEF
WHEREFORE, Lokai respectfully request that this Court enter a judgment against the
Defendants as follows:
A.
That Defendants and their officers, directors, partners, employees, agents,

servants and attorneys and those persons in active concert or participation
with them are preliminarily and permanently enjoined from:
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15
1.
Making, having made, importing, selling, and offering to sell

infringing products practicing the 000 Patent and from otherwise
infringing, contributing to infringement of, and actively inducing
infringement of the 000 Patent;
2.
Using the Infringing Trade Dress, the LOKAI Trade Dress or any
colorable imitation thereof in connection with the offering, selling,
advertising or promoting the sale of any goods or services or from
otherwise using the LOKAI Trade Dress or any marks confusingly
similar thereto;
3.
Infringing the LOKAI Trade Dress;
4.
Unfairly competing with Lokai; and
5.
Using in connection with the sale of any goods or services or the

dissemination or distribution of advertising, promotional or
marketing materials, a false or misleading description or
representation including words or other symbols tending to deceive
or cause confusion with Lokai or the LOKAI Trade Dress;
B.
That Defendants be required to account to Lokai for all profits resulting

from Defendants infringing activities and unfair competition and that
such award of profits to Lokai be increased by the Court as provided for
under 15 U.S.C. 1117(b) and 35 U.S.C. 285;
C.
That Lokai have a recovery from Defendants of all damages sustained by

Lokai resulting from Defendants infringing activities and unfair
competition;
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16
D.
That Lokai have a recovery from Defendants of the costs of this action
and Lokais reasonable counsel fees pursuant to 15 U.S.C. 1117;
E.
That Lokai have a recovery from Defendants of the costs of this action and
Lokais reasonable counsel fees pursuant to 35 U.S.C. 285.
F.
That Defendants be ordered to deliver up to Lokai for destruction the

Infringing Products, signs, labels, stickers, prints, packages, wrappers,
receptacles, advertisements and other written or printed material in their
possession, custody or control which bear LOKAI Trade Dress, alone or in
combination with any other words, marks or other elements; and
G.
That Lokai have all other and further relief as the Court may deem just and
proper under the circumstances.
Dated: New York, New York

February 1, 2016
TARTER KRINSKY & DROGIN LLP
By:
/s/ Mark J. Rosenberg

Mark J. Rosenberg
Amy B. Goldsmith
1350 Broadway
New York, New York 10018
(212) 216-8000
mrosenberg@tarterkrinsky.com
agoldsmith@tarterkrinsky.com
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17
Case 1:15-cv-09363-ALC Document 19-1 Filed 02/01/16 Page 1 of 2
EXHIBIT 1
EXHIBIT 2
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EXHIBIT 3
Lokai: Balancing Life (#ArtofY) | Alex Schattner

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Posted: 08/26/2014 2:32 pm EDT
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Comment
"You have to stay hopefully in the low times, and humble in the high
times?" Those are the words on which Steven Izen, 23, founded Lokai in 2013. I sat
down with Steven to learn about his personal journey, Lokai's beginnings, and the
bracelet he hopes will inspire others.
Steven Izen with a Lokai display

(photo by author)
Where did you go to school? How did it prepare you for Lokai?
Steven Izen: I graduated from Cornell University's undergraduate business
program, where I learned "there are no shortcuts to success." Coursework and case
studies were helpful, but I've learned the most from the real life experience of
building Lokai. I was working with my advisors to create a schedule where I'd have
days without classes so I could take the Cornell Bus into Manhattan and meet with
web designers and other team members.
http://www.huffingtonpost.com/alex-schattner/lokai-balancing-life-arto_b_5686719.html[11/30/2015 11:36:12 AM]
PRESENTED BY HALLMARK STUDIO INK
What was the inspiration behind Lokai?

I came up with the idea after freshman year of college. I was on the beach with
family and friends, and thinking about how lucky I was to be there, while at the
same time I had just found out that my beloved grandfather was diagnosed with
Alzheimer's. That was a really tough time for me, because I had always been
extremely close with him -- I credit him with instilling an entrepreneurial spirit in
me; he also taught me how to play pool, golf etc. The feelings of helplessness
towards my grandfather's diagnosis were in stark contrast to the happiness and
gratitude for my life that I felt that day on beach. I realized that life is a cycle of
highs and lows, and it's important to remain humble and grateful at the same time
as you're experiencing everything.
I love the notion of preserving feelings and memories through physical objects. (I
collect memorabilia from all of the places that I travel to, including Tanzania,
England, Hong Kong.) So, I was thinking about how I could take the contrasting
feelings I had from that day on the beach, and translate them into a tangible object.
I thought about incorporating elements from the highest and the lowest points on
earth, Mt. Everest and the Dead Sea. My dad, who's also an entrepreneur said,
"Great idea. Now go execute it."
I decided to make a bracelet, because it's something you can wear and take with
you. There are two beads at either end of the bracelet. The black one is injected with
mud from the Dead Sea. The white ball is filled with water from Mt. Everest.
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How did you gather the natural

resources, and produce the bracelets?
Setting up a company to source materials from
such far-reaching places in the world while
pursuing my degree wasn't easy, but I was very
motivated to make Lokai a reality and I looked
at these challenges as opportunities. We work
with local organizations and community
members to collect our resources, including
native Sherpas from Mount Everest.
AIDS Is Leading Cause Of Death

For African Teens: UN
We give back to these communities, too. Lokai

donates 10 percent of its net profits to various charities. This past April there was an
avalanche on Mount Everest, and 16 sherpas were buried. It was the biggest tragedy
in the mountain's history, and we were able to donate money to the Sherpa Family
Fund and help them quickly reach their goal.
How did you get the product to market?
When we first launched, it was all word-of-mouth, talking to friends, friends of
friends etc. Then, I literally took a display (pictured at top) around to retail stores
and said, "Hi, my name is Steven Izen, and I would love to tell you about my
product, and I think it would fit well in your store." It was hard at first. I only got 1
out of every 30 stores to take a chance. If I didn't believe in Lokai, it would have
been easy to let the discouragement get the best of me. It was the passion that kept
me going. It's amazing how much you can get done, if you make the right
connections and just go for it. Everyone you speak to is just a person like you. If
you're passionate about what you do, people will listen. And now we're in over 88
countries, and 300 boutiques around the US.
What was a pivotal challenge you faced?
As we are young and growing fast, it seems there's a new challenge every day to
address. As an example, once there was an unprecedented flood of website traffic, it
crashed and people weren't able to place orders. I had to scramble to find a solution,
but those are the challenges that really excite me about being an entrepreneur--even
Adding The USWNT To FIFA 16

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if it is a rocky path.
What caused the site crash?
A few celebrities, like Ashley Greene, have drawn attention to Lokai. This is a good
problem to have, but you still have to deal with it right away.
Climate Pact Is An 'Act Of

Defiance' After Paris Attacks,
Obama Says
What do you attribute the company's early success to?

I think one of the reasons Lokai has been successful is that we're not afraid to ask
for help as a company. For me personally, I'm 23 years old, and this is the first real
company that I've started. I think one of the smartest things you can do is to
recognize the areas you're not well-versed in, and be able to ask for help when
needed. I've had an amazing team around me that has lent their maturity,
experience and creative expertise, and I learn from them every day.
What's the next step?
Things have changed so much in the past year, I don't think I can tell you exactly
where we'll be a year from now! But I can say that we're working extremely hard to
get our brand and mission out, and we couldn't be more excited for what's ahead.
We plan on creating other products and building the brand, while staying true to
our core message.
Mom Struck And Killed Crossing

Highway Moments After Surviving
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Learn more about Lokai at: mylokai.com

Read more entrepreneurial stories! Catch up on #ArtofY:
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Follow Alex Schattner on Twitter: www.twitter.com/alexschattner

MORE: Lokai, Dead Sea, Inspiration, Health, Balance, Life Journey, Mount Everest, Healthy
Living,
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EXHIBIT 4
7 Stars Who Are Obsessed with Lokai Bracelets - Twist

CELEB NEWS
FUN STUFF
STAR STYLE
GAMES
FAN FICTION
LOLZ
BLINGEE
FAN SHOP
LOG IN SIG
Twitter
Pinterest
Facebook
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Advice
NOV 8, 2014 7:00AM BY JENNIFER MALDONADO
7 Stars Who Are

Obsessed with Lokai
Bracelets
Trending:
Comments: 0
TAGGED:
JUSTIN BIEBER
ASHLEY BENSON
BRACELETS
BUZZ
LOKAI
FILED UNDER:
Fashion
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7 Stars Who Are Obsessed with Lokai Bracelets - Twist
SHARE
1 8
TWEET
OFever wondered what a piece of jewelry made from elements taken from Mt. Everest and the Dead Sea would look like, then
If you have
you're in luck! Lokai bracelets are the answer you've been waiting for! These bracelets, made wih clear beads and one black bead in the
middle, are infused with elements from the highest and lowest points on Earth to serve as a reminder to always stay balanced in life!
Not only do these bracelets have a wonderful meaning behind them, but they're being worn by some of your favorite celebs! Pretty Little
Liars star Ashley Benson has just bought one of these elegant bracelets and couldn't stop gushing over it on her Instagram account. We
don't blame her the bracelet is so nice!
Click through the gallery, featuring stars like Justin Bieber and Shawn Mendes, and tell us in the comments if you love these
bracelets too!
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away: #17 is Shocking
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7 Stars Who Are Obsessed with Lokai Bracelets 2 - Twist
Ashley Benson
Credit:
Instagram
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2 8
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If you have
bracelets too!
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Justin Bieber
Credit:
Getty
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If you have
bracelets too!
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Shawn Mendes
Credit:
Instagram
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If you have
bracelets too!
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Christina Perri
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If you have
bracelets too!
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Victoria Justice
Credit:
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If you have
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Ashley Greene
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If you have
bracelets too!
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Emma Roberts
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EXHIBIT 5
9 Stars Obsessed With Lokai Bracelets 2 - J-14

CELEB NEWS
FUN STUFF
STAR STYLE
GAMES
FAN FICTION
LOLZ
BLINGEE
FAN SHOP
Win LOG
prizes at
IN
J-14 WINIT!
Tumblr
Twitter
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Facebook
Instagram
One Direction
Justin Bieber
Taylor Swift
Selena Gomez
Ariana Grande
More
One Direction
Justin Bieber
Taylor Swift
Selena Gomez
Ariana Grande
Cody Simpson
Victoria Justice
Austin Mahone
Bella Thorne
Zendaya
Big Time Rush
Demi Lovato
Miley Cyrus
Jennifer Lawrence
Customize
DEC 17, 2014 3:00PM BY HEATHER THOMPSON
9 Stars Totally
http://www.j-14.com/posts/9-stars-totally-obsessed-with-their-lokai-bracelets-48011/photos/justin-bieber-lokai-69877[11/30/2015 12:23:02 PM]
9 Stars Obsessed With Lokai Bracelets - J-14
Obsessed With Their

Lokai Bracelets
Comments: 8
TAGGED:
BELLA THORNE
VICTORIA JUSTICE
JUSTIN BIEBER
ASHLEY BENSON
VANESSA HUDGENS
ASHLEY GREENE
CHRISTINA PERRI
EIZA GONZALEZ
SHAWN MENDES
Bella Thorne
Credit:
Instagram
http://www.j-14.com/...ars-totally-obsessed-with-their-lokai-bracelets-48011/photos/bella-thorne-lokai-69885#photo-anchor[11/30/2015 12:26:15 PM]
9 Stars Obsessed With Lokai Bracelets - J-14
SHARE
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TWEET
The hottestOF
bracelet to have this holiday season is the Lokai bracelet, which is infused with elements from the highest
and lowest points on the planet. The bracelet features a white ball that holds water from Mt. Everest, and a black ball
that holds mud from the Dead Sea.
The bracelet is meant to signify "that throughout life's circular journey, your path is your own."
We love the meaning behind the Lokai bracelet, and lots of celebs do too! Click through the gallery to see 9 stars
totally obsessed with obtaining balance in their life, and sporting Lokai bracelets to remind themselves that their
journey is unique!
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Obsessed With Their

Lokai Bracelets
Comments: 8
TAGGED:
BELLA THORNE
VICTORIA JUSTICE
JUSTIN BIEBER
ASHLEY BENSON
VANESSA HUDGENS
ASHLEY GREENE
CHRISTINA PERRI
EIZA GONZALEZ
SHAWN MENDES
Justin Bieber
Credit:
Getty Images
SHARE
2 9
TWEET
The hottestOF
journey is unique!
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few months
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delicious SlimFast recipe: Sassy
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Obsessed With Their

Lokai Bracelets
Comments: 8
TAGGED:
BELLA THORNE
VICTORIA JUSTICE
JUSTIN BIEBER
ASHLEY BENSON
VANESSA HUDGENS
ASHLEY GREENE
CHRISTINA PERRI
EIZA GONZALEZ
SHAWN MENDES
Ashley Benson
Credit:
Instagram
http://www.j-14.com/...-totally-obsessed-with-their-lokai-bracelets-48011/photos/ashley-benson-lokai-69878#photo-anchor[11/30/2015 12:25:02 PM]
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3 9
TWEET
The hottestOF
journey is unique!
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Articles and Offers

Father and Son Take the Same
delicious SlimFast recipe:
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21 Celebrities You Had No Idea

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75 UNREAL Rare Photos That

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Yourself.
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Buzzlie
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Obsessed With Their

Lokai Bracelets
Comments: 8
TAGGED:
BELLA THORNE
VICTORIA JUSTICE
JUSTIN BIEBER
ASHLEY BENSON
VANESSA HUDGENS
ASHLEY GREENE
CHRISTINA PERRI
EIZA GONZALEZ
SHAWN MENDES
Christina Perri
Credit:
Instagram
http://www.j-14.com/...s-totally-obsessed-with-their-lokai-bracelets-48011/photos/christina-perri-lokai-69879#photo-anchor[11/30/2015 12:27:23 PM]
SHARE
4 9
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The hottestOF
journey is unique!
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Father and Son Take the Same Shocking Photos Of Hollywood's

Photo for 30 Years and the Last Sexiest Stars That Packed On A
One Will Amaze You
Ton Of Weight
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Buzzlie

few months
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Top 15 Celebrities You Didn't

Know are Black
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Obsessed With Their

Lokai Bracelets
Comments: 8
TAGGED:
BELLA THORNE
VICTORIA JUSTICE
JUSTIN BIEBER
ASHLEY BENSON
VANESSA HUDGENS
ASHLEY GREENE
CHRISTINA PERRI
EIZA GONZALEZ
SHAWN MENDES
Victoria Justice
Credit:
Twitter
http://www.j-14.com/...-totally-obsessed-with-their-lokai-bracelets-48011/photos/victoria-justice-lokai-69880#photo-anchor[11/30/2015 12:28:06 PM]
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5 9
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The hottestOF
journey is unique!
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Photo for 30 Years and the Last delicious SlimFast recipe: Cinful
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9 Stars Obsessed With Lokai Bracelets 6 - J-14#photo-anchor#photo-anchor
Obsessed With Their

Lokai Bracelets
Comments: 8
TAGGED:
BELLA THORNE
VICTORIA JUSTICE
JUSTIN BIEBER
ASHLEY BENSON
VANESSA HUDGENS
ASHLEY GREENE
CHRISTINA PERRI
EIZA GONZALEZ
SHAWN MENDES
Shawn Mendes
Credit:
Instagram
http://www.j-14.com/...-totally-obsessed-with-their-lokai-bracelets-48011/photos/shawn-mendes-lokai-69881#photo-anchor[11/30/2015 12:29:34 PM]
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journey is unique!
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Brady's)
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Obsessed With Their

Lokai Bracelets
Comments: 8
TAGGED:
BELLA THORNE
VICTORIA JUSTICE
JUSTIN BIEBER
ASHLEY BENSON
VANESSA HUDGENS
ASHLEY GREENE
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SHAWN MENDES
Vanessa Hudgens
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Obsessed With Their

Lokai Bracelets
Comments: 8
TAGGED:
BELLA THORNE
VICTORIA JUSTICE
JUSTIN BIEBER
ASHLEY BENSON
VANESSA HUDGENS
ASHLEY GREENE
CHRISTINA PERRI
EIZA GONZALEZ
SHAWN MENDES
Ashley Greene
Credit:
Instagram
http://www.j-14.com/...s-totally-obsessed-with-their-lokai-bracelets-48011/photos/ashley-greene-lokai-69883#photo-anchor[11/30/2015 12:30:52 PM]
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9 Stars Obsessed With Lokai Bracelets 9 - J-14#photo-anchor
Obsessed With Their

Lokai Bracelets
Comments: 8
TAGGED:
BELLA THORNE
VICTORIA JUSTICE
JUSTIN BIEBER
ASHLEY BENSON
VANESSA HUDGENS
ASHLEY GREENE
CHRISTINA PERRI
EIZA GONZALEZ
SHAWN MENDES
Eiza Gonzalez
Credit:
Instagram
http://www.j-14.com/...rs-totally-obsessed-with-their-lokai-bracelets-48011/photos/eiza-gonzalez-lokai-69884#photo-anchor[11/30/2015 12:31:36 PM]
9 Stars Obsessed With Lokai Bracelets 9 - J-14#photo-anchor
SHARE
9 9
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The hottestOF
journey is unique!
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Buzzlie

Photo for 30 Years and the Last
One Will Amaze You
Grizly

Know are Black
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Your Daily Dish
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EXHIBIT 6
Milkshake | Good Finds That Give Back | Inspired by Lokai Arm Candy: Finding Balance in 2015

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Inspired by Lokai Arm Candy:

Finding Balance in 2015
Dec 22 2014
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Its tempting to begin crafting resolutions as soon as the calendar turns over to
December. But this year, instead of focusing on self-improvement, weve decided to
take a page out of Steven Izens book and start seeking wholeness. Balance. A life full
of highs, lows, and everything in between.
Put a Little Good in

Everyone's life
Get Milkshake
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1
You like thisBe the first of your friends to like this
Havent heard of Steven Izen? Thats okay, because hes not a celebrity or a high-profile guru or
anything like that. Izen is the founder of Lokai, a company that makes simple, pretty bracelets that
http://www.getmilkshake.com/inspired_by_lokai_arm_candy_finding_balance_in_2015[11/30/2015 11:41:57 AM]

contain water from the snows of Mount Everest, and mud from the shores of the Black Sea, the
highest and lowest points on earth, respectively. And while these bracelets have some very
famous fans, thats not the real reason were digging them; 10 percent of the net profits from
Lokai are donated to fantastic charitable organizations like Pencils of Promise, charity: water,
the Cure Alzheimers Fund, and others.
The message of the flexible, wear-anywhere accessory is as simple as its design: When youve
reached a high point, stay humble, and when youre reached a low point, stay hopeful. Inspired by
Izens own experience of hitting a terrible low point after receiving the news that his grandfather
was ill with Alzheimers, the bracelet is a symbol of the cyclical nature of happiness and pain.
Everyones life is filled with some wonderful joys, but on the other side of the coin, every life also
has moments of sorrow.
In the spirit of the Lokai bracelent, in 2015 we will try to find balance and gratitude in every
experience. A whole life is made up of both good and bad, high and low, light and dark. Lets look
for wholenessa more complicated matter than happiness, but one worth striving for.
How do you plan to live a more balanced life in

2015?
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EXHIBIT 10
Found: The Beaded Bracelet We Keep Spotting on Celebrities - SELF
SUBSCRIB
PLAY WITH SOUND
The 10
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Stretches
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Better
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FLASH
2015
Mar 4
4:57 PM
Reimagine
MySelf
Sponsored
Content:
Biogen
WHAT'S NEW NOW
CHARITY
By Sara Gaynes Levy
Found: The Beaded Bracelet We Keep Spotting on Celebrities

46
http://www.self.com/flash/charity/2015/03/lokai-world-water-day-bracelet[11/30/2015 11:58:00 AM]
27
Insanely
Awesome
Stocking
Stuffers
Under
$15
Bob
Harper
Is Here
To Get
You
Fitter In
5
Minutes
With
This
Workou
Video
What's the new accessory that keeps popping up on celebrity Instagram feeds? Remember this name: Lokai. These bracelets' white beads
hold water from the highest point on EarthMount Everestand the black beads hold mud from the lowest pointthe Dead Seato
remind wearers to live a balanced life. Now, Lokai is launching their first charity-partnership for World Water Day.
The World Water Day version ($18), as seen below on Zoe Saldana, is tinted blue, and $3 from every sale between now and the holiday
on March 22nd will go to charity: water, which works to bring clean drinking water to 10,000 Ethiopians. The bracelets are a cool way to
support the causeand we love that celebs like Alessandra Ambrosio (above) are getting in on the act. Take a look at how other stars
styled theirs:
juleshough
12 months ago
Follow
58.3k likes
shaym
958 comments
12 months ago
347.3k likes
emmaroberts
Follow
3,490 comments
12 months ago
Follow
96.3k likes
1,353 comments
torlykid 10 months ago
23 likes
Follow
0 comments

livelokai 14 months ago
12.8k likes
Follow
220 comments
Content unavailable
For more information on how you can get involved with charity: waters mission and World Water Day, visit charitywater.org.
Image Credit: Michael Simon, Startraks; Instagram
RELATED:
This Bracelet Will TOTALLY Make You Go to the Gym (or Else)
Zoe Saldana Looks Absolutely Stunning Sans Makeup
KEYWORDS: BRACELETS,CHARITY,CHARITY: WATER,EMMA ROBERTS,JULIANNE HOUGH,LIVE LOKAI,LOKAI,SHAY MITCHELL,WORLD WATER DAY,ZOE SALDANA
46
EXHIBIT 11
Kourtney Kardashian holds Scott Disick's hand as they wear matching bracelets | Daily Mail Online
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latestshot
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star
Star
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October
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Site
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SN 90: Broncos top Patriots;

Richt out at UGA; Kobe...
United front! Kourtney Kardashian

holds Scott Disick's hand as they
wear matching bracelets in Instagram
snap from family ski trip
By MAILONLINE REPORTER
shares
1:06
Sara Jane Harris with the top headlines on

SportingNews.com.
PUBLISHED: 22:18 EST, 25 February 2015 | UPDATED: 05:59 EST, 26 February 2015
48
PLAY
25
View comments
+ More Videos
They have certainly had their highs and lows in their relationship since they started dating 9 years
ago.
But on Wednesday Kourtney Kardashian posted an Instagram shot of her hand clasped over her
partner Scott Disick's, reaffirming her bond with the father of her three children.
In the snap the two wear matching bracelets containing mud from the Dead Sea and infused with
elements from the highest and lowest places on Earth.
Scroll down for video
http://www.dailymail.co.uk/...wbiz/article-2969426/Kourtney-Kardashian-holds-Scott-Disick-s-hand-wear-matching-bracelets-Instagram-snap-family-ski-trip.html[11/30/2015 11:59:09 AM]
Like
Daily Mail Celeb
Follow
@DailyMailCeleb
Follow
Daily Mail Celeb
+1
Daily Mail Celeb
FEMAIL TODAY
'I've never felt more

beautiful. I love my
body': Amy Schumer
poses topless for
Annie Leibovitz's
'completely
different' 2016 Pirelli
calendar
Pirelli with fewer
nudes: Serena
Williams, Patti Smith
and Amy Schumer
pose for iconic
calendar as it
abandons naked
supermodels for
'women of
achievement'
+7
Holding hands: Kourtney Kardashian posted a snap of her and Scott Disick wearing matching
bracelets which contain mud from the Dead Sea and water from Mount Everest
Kourtney and Scott show

their unity and love with
matching Lokai bracelets
Kourtney and Scott show their
fans how dedicated they are to
each other with a picture of
them wearing matching Lokai
bracelets.
Each lokai is infused with
elements from the highest and
lowest points on Earth. The
bracelets white bead carries
water from Mt. Everest, and its
black bead contains mud from
the Dead Sea. These extreme
elements are a reminder to the
The Lokai Bracelet
No hiding it now!
Gigi Hadid holds
hands with Zayn
Malik as the pair
step out in matching
looks after yet
another date night
After Joe Jonas split
Joe Jonas
unfollows ex Gigi
Hadid on Instagram
as romance with
Zayn Malik heats
up... after he
DELETES 'squad'
snap with former 1D
star
Sex, stars and
scandal:
Controversial
celebrity
photographer Terry
Richardson
celebrates 20 years
of his most
provocative pictures
in a new book
wearer to live a balanced life

staying humble during lifes
peaks and hopeful during its
lows. We also love that there's a
giving back aspect to the
bracelet and 10% of the
proceeds goes to the company's
charitable partners.
Get it directly from

Lokai and show your
love like Kourtney
Visit site
We think this is a great way to express your love for

another or most of all yourself. This design is so simple
that it will stack really well just like the way Kourtney is
doing with her Cartier love bracelets.
Check out the Lokai bracelet to the right or if they're sold
out, we have some very similar suggestions to try so you
can stack away.
* PRICES MAY NOT BE AS ADVERTISED
...NOW GET ONE LIKE IT OR MORE TO STACK ON
Sydney Evan 8mm

Chalcedony Beaded Bracelet
with Hamsa Charm
Visit site
David Yurman Spiritual Beads Domo Beads Mala Bracelet |

Bracelet with White Agate
White Howlite / Magenta
Tassel
Visit site
Visit site
She finds any

excuse to show off
her body! Bethenny
Frankel takes dip in
Atlantic Ocean even
though it's freezing
outside as she
admits she's 'crazy'
'I don't regret
anything': Katie
Holmes reveals she
'has learned from
everything' as nine
year wedding
anniversary to Tom
Cruise passes
They divorced in 2012
Pregnant Ivanka
Trump shows off a
barely-there bump
as she shares sweet
snapshots of her
family's
Thanksgiving in Mara-Lago
Expecting her third child
Saying goodbye to
paradise! Christie
Brinkley, 61, cannot
resist sharing a few
last bikini snaps as
she wraps up her
tropical island
getaway
Cara Delevingne
and underwear-clad
Kendall Jenner put
on a seductive
display in festive
mash-up as Love
magazine tease
2015 advent
calendar
Kourtney, 35, and Scott, 31, who have been enjoying some family time in Big Sky, Montana with Kim
and Kylie, both wore matching black and white beaded Lokai bracelets on their right wrists in the
photo.
The unusual bracelets, which Kourtney described as cool, cost $18 and are infused with elements
from the highest and lowest points on Earth which are said to serve as a reminder to stay humble
during lifes peaks and hopeful during its lows.
Wearing the Lokai jewellery could be a nod to their tempestuous relationship, which seems to have
settled down since moving into a new home last year and welcoming a new baby.
Is Adriana Lima set

to swap fashion for
film? Victoria's
Secret model says
her goal is to move
into movies, as she
channels old
Hollywood glamour
for shoot
Oh Baby! Justin
Bieber's model
'friend' Yovanna
Ventura parades her
curves in a VERY
skimpy bikini as she
hits the beach in
Miami
+7
Ice ice baby: The on-off couple are enjoying a relaxing break in snowy Montana with their
children
Property problems?
Tyga fails to close
deal on $10million
new home near
girlfriend Kylie
Jenner due to
money issues
Can't purchase property
Kim Zolciak steals
Khloe Kardashian's
best friend Malika
Haqq to take in an
Atlanta Falcons
game in Georgia
The Real Housewives
star has a new BFF
No wonder she's
smiling! Grinning
Gigi Hadid jets into
London in sexy
thigh-high boots as
new romance with
Zayn heats up
Dressed down model
+7
Balanced: The couple hit the slopes after posting a picture wearing the unusual bracelets,
which are said to keep the wearer balanced and humble
'Clothes feel a little

tight': Jessie James
Decker speaks out
on her body after
baby and why she's
losing weight the
slow way
Just had second child
Eva Longoria wears
stunning optical
illusion dress as she
talks about her life
The beaded monochrome bands are said to signify that life is full of joy and sadness, and serve as a
reminder to the wearer to live a centered and balanced life.
Mud from the Dead Sea, the lowest point on Earth, is contained in the black bead, which signifies
lifes most difficult moments.
The white bead of the Lokai bracelet carries water sourced by sherpas from the heights of Mount
Everest to represent lifes highest moments, when youre feeling on top of the world.
in the spotlight at
the Oxford Union
The actress stunned in a
Stella McCartney dress
'What you're doing
is not rap': Host
Erykah Badu takes
aim at Iggy Azalea
at the BET Soul
Train Awards
The blonde Australian
rapper was critiscized
'Give me my
space!' Lupita
Nyong'o recalls how
Ralph Fiennes blew
her off when she
was an assistant
She had to escort him to
and from the film set
Her lucky day!
Taylor Swift pulls
her car over to meet
young fan after
spotting the girl
wearing one of her
concert T-shirts as
she walked down
the street
+7
Peace out: Kourtney shared this black and white snap to her Instagram page
She's so jet set!

Taylor Swift dines
out in New Zealand
with her crew
following whirlwind
48 hour trip to
Australia
The singer has been
touring Down Under
'I'm really worried':
Kim Kardashian
fears she could have
diabetes as her
hands and feet swell
up after jet-setting
the globe to satisfy
her pregnancy
cravings
Parenting is a walk
in the park! Lauren
Bush Lauren and

husband David pose
alongside newborn
baby James in sweet
family photo
Bonded with newborn
Chloe Sevigny is
terrifying as Stephen
King's Carrie on the
front of Paper - while
Lucy Hale, Paris
Hilton and Marc
Jacobs' dog Neville
also land covers
+7
+7
Home sweet home: Scott was spotted arriving into LAX airport on Wednesday afternoon
The Keeping Up with the Kardashians star posted to her 14.6 million Instagram followers, I
my
@livelokai because in addition to cool jewelry they are donating to @Musicbeatshearts. Lets help the
kids by sharing the gift of music. #keepthebeatgoing#livelokai
Her sister Kim jetted out of the resort on Wednesday with daughter North West to attend the Brit
Awards in London, leaving the couple to get some family time with their three adorable children,
Mason, Penelope and Reign.
The brood hit the ski slopes straight away, where they will no doubt hope the bracelets keep them
balanced in a more literal sense too.
Delighted daughterin-law! Jennifer

Garner shares a
laugh with Ben
Affleck's mom as
they spend time
together
Still on good terms with
her in-laws despite split
'It's a respect
thing': Cynthia Bailey
and Porsha Williams
get into a physical
fight on a boat trip
on The Real
Housewives Of
Atlanta
The claws were out
Pregnant Anne
Hathaway wraps up
her growing bump
under a chic cream
coat as she heads to
dinner with husband
Adam Shulman
Expecting her first child
'I've been bullied
my whole life': Kylie
Jenner explains how
fame has attracted
naysayers as she
talks about the I Am
More campaign on
The Ellen DeGeneres
Show
EXHIBIT 12
Kris Jenner on Twitter: "Loving my @livelokai bracelets even more because they are donating to musicbeatshearts ! Let's help https://t.co/oFpQ0jJf...

Have an account? Log in
Kris Jenner
Follow
@KrisJenner
Loving my @livelokai bracelets even more

because they are donating to
musicbeatshearts ! Let's help
instagram.com/p/ziyqLLm-JB/
https://
RETWEETS
LIKES
63
280
4:04 PM - 25 Feb 2015

Kris Jenner
@KrisJenner
Kris Jenner
@KrisJenner
MOM, MANAGER, MOMAGER,
LOVER OF LIFE, LOVER OF CHRIST
Joined March 2009
dana.dorrell@aol.com @DanaDorrell Feb 25
@KrisJenner @livelokai
1
2015 Twitter About
Help Terms Privacy
Cookies Ads info
dana.dorrell@aol.com @DanaDorrell Feb 25

@KrisJenner
Adore you Kris..#GreatMom
1
Elijah Howard @ElijahHoward Feb 26

Check out my Comedy Clip on YouTube:
http://
youtu.be/9olXkixqZfk
1
https://twitter.com/krisjenner/status/570736243274866688[11/30/2015 12:01:22 PM]
View media
Malum @JocySwag Feb 25

@KrisJenner @livelokai i loved!! Kris you're the best woman
1
your real name @want2goeverywhe Feb 27

@KrisJenner you look stunning!
Shawn Paul Lopez @shawnpaullopez1 Feb 26

@KrisJenner @livelokai I heard you have a new man in your life. Is that true. ")
Vikki @VikkDavies Feb 25

@KrisJenner @livelokai @sophiesbriers Kris only does things if she is paid to
do it. She won't follow u unless ur famous or are paying her
Vikki @VikkDavies Feb 25

@KrisJenner @livelokai how much is ur family being paid to promote
@livelokai??
shawnthomasminnier @onedragon333 Feb 25

@KrisJenner momager I need you please it is a crisis dang it don't leave me any
more :) real help
Sophie Briers @sophiesbriers Feb 25

fhRDngdngfzndzgngzdndgzntdznzdtntzdntzdngzfnzfgnfgzngfznfgzngfznzgfnzgfng
fznzfgnfgznfzgnyfNyzfnfysmsyf,

@KrisJenner @livelokai life goal is to get a follow

@KrisJenner @livelokai me again follow

@KrisJenner @livelokai press the follow button I love you

@KrisJenner @livelokai still here


@KrisJenner @livelokai FOLLOW

@KrisJenner @livelokai follow


2015 Twitter About Help Terms Privacy Cookies Ads info
EXHIBIT 13
EXHIBIT 14
Balance Your Life Bracelet

USD
MY CART
HOME / GLITTER LIFE

Each Life Bracelet has properties from the highest & lowest points on earth.
The grey bead has earth from below sea level. The green bead has water from
the mountains. Our life bracelet elements are a reminder to the wearer to be
grounded & live a well & balanced life.
BALANCE YOUR LIFE
BALANCE YOUR LIFE
BLUE GLITTER LIFE
JADE GLITTER LIFE
$9.99
$9.99
http://balanceyourlifebracelet.com/[11/30/2015 12:08:14 PM]
BALANCE YOUR LIFE
BALANCE YOUR LIFE
NAVY BLUE GLITTER LIFE
ORANGE GLITTER LIFE
$9.99
$9.99
BALANCE YOUR LIFE
BALANCE YOUR LIFE
PINK GLITTER LIFE
RED GLITTER LIFE
$9.99
$9.99
10% off

BALANCE YOUR LIFE
BALANCE YOUR LIFE
SKY BLUE GLITTER LIFE
WHITE GLITTER LIFE
$9.99
$9.99
BALANCE YOUR LIFE
YELLOW GLITTER LIFE

$9.99
SHOWING ITEMS 1 - 9 OF 9.
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COPYRIGHT 2015 TWIN TIGER WORLD MARKETS USA CREATED BY PR

ULTIMATE POWERED BY SHOPIFY
EXHIBIT 15

Lokai Holdings v. Twin Tiger - Complaint

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Lokai Holdings v. Twin Tiger - Complaint

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Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 1 of 17

LOKAI HOLDINGS LLC,

JURY TRIAL DEMANDED

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 2 of 17

1125(a) and the common law.

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 3 of 17

Lokai is a socially responsible lifestyle brand that represents the importance of

Commencing in 2013, long prior to the acts of the Defendants complained of

design mark, and a circular cardboard hangtag affixed to the bracelet by an

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 4 of 17

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 5 of 17

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 6 of 17

Lokai is the owner by assignment of the 000 Patent.

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 7 of 17

bracelets, representative samples of which are shown hereto as Exhibit 1.

In particular, in or about mid-2015, Defendants, without Lokais authorization,

which is also known as the breath of life, and a

In verbiage paraphrased from the Lokai Website, Defendants, on their

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 8 of 17

Some of the hangtags for some of the Infringing Products prominently

LOKAI Trade Dress or the design claimed in the 009 Patent.

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 9 of 17

A side-by-side comparison of the design claimed in the 000 Patent, a

representative Infringing Product and a LOKAI bracelet is shown below:

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 10 of 17

Lokais bracelets bearing the LOKAI Trade Dress.

be without permission or authority of Lokai.

Defendants use of the Infringing Trade Dress is without permission or authority

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 11 of 17

Defendants use of the Infringing Trade Dress is likely to lead others to

Lokai repeats and realleges the allegations of paragraphs 1 through 41 as if fully

set forth herein.

U.S.C. 271, and alleges the infringement of a design patent.

Defendants actions constitute infringement of the 000 Patent in violation of 35

Defendants acts of infringement set forth herein were undertaken without

authority, permission or license from Lokai.

Defendants infringement has damaged and continues to damage and injure

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 12 of 17

Lokai is entitled to a complete accounting of all revenue and profits derived by

Lokai is entitled to a permanent injunction preventing Defendants from further

infringing the 000 Patent.

Lokai repeats and realleges the allegations of paragraphs 1 through 50 as if fully

set forth herein.

Prior to the acts of the Defendants complained of herein, Lokai extensively

As a result of Lokais marketing, promotion and substantial sales of bracelets

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 13 of 17

Defendants use of the Infringing Trade Dress constitutes a use in interstate

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 14 of 17

set forth herein.

infringement and unfair competition.

secondary meaning indicative of origin, relationship, authorization, sponsorship and/or

Upon information and belief, Defendants intentionally appropriated the LOKAI

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 15 of 17

amount not thus far determined.

By reason of such infringement, unfair competition and misappropriation and by

Defendants conduct in intentionally misappropriating Lokais goodwill and

Unless restrained and enjoined, Defendants continuing acts of infringement and

That Defendants and their officers, directors, partners, employees, agents,

Case 1:15-cv-09363-ALC Document 19 Filed 02/01/16 Page 16 of 17

Making, having made, importing, selling, and offering to sell

Infringing the LOKAI Trade Dress;

Unfairly competing with Lokai; and

Using in connection with the sale of any goods or services or the

That Defendants be required to account to Lokai for all profits resulting