Novo Nordisk A/S v. Midwest Aesthetic Management LLC

• Court: District Court, N.D. Illinois
• Decided: August 1, 2025
• Docket: 1:24-cv-11525
• Status: Unknown

Opinion

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-11525 Judge Steven C. Seeger v. MIDWEST AESTHETIC MANAGEMENT LLC, Defendant.

AGREED MOTION FOR ENTRY OF PERMANENT INJUNCTION AND FINAL JUDGMENT BY CONSENT

Plaintiffs Novo Nordisk A/S and Novo Nordisk Inc. (“Novo Nordisk” or “Plaintiffs”), with the agreement of Defendant Midwest Aesthetic Management LLC (“Defendant”), respectfully move this Court to enter a final judgment and a permanent injunction in this action in favor of Plaintiffs. In support of this motion, Plaintiffs state as follows: 1. Novo Nordisk filed this Complaint on November 8, 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) and the Illinois Uniform Deceptive Trade Practices Act, 815 Ill. Comp. Stat. Ann. 510/1 et seq. 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 on Consent (“Final Judgment”). 4. Attached as Exhibit B is Defendant’s signed consent to the Proposed Permanent Injunction on Consent (“Permanent Injunction”).

5. Upon entry of the Final Judgment and Permanent Injunction, the parties respectfully request this case be dismissed without prejudice with leave to reinstate on or before August 1, 2026 – for the sole purpose of ensuring enforcement – after which point the case shall be deemed, without further order of the Court, to be dismissed with prejudice.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: August 1, 2025 Respectfully Submitted,

/s/ Brigid Carmichael /s/ Daniel J. Hoelting Suyash Agrawal Mary Clare Bonaccorsi Hillary W. Coustan Daniel J. Hoelting Brigid Carmichael POLSINELLI PC MASSEY & GAIL LLP 15 N. Riverside Plaza, Suite 3000 50 E. Washington St., Ste. 400 Chicago, IL 60606 Chicago, Illinois 60602 (312) 819 1900 (312) 379-0949 mbonaccorsi@polsinelli.com sagrawal@masseygail.com dhoelting@polsinelli.com hcoustan@masseygail.com bcarmichael@masseygail.com Attorney for Defendant Midwest Aesthetic Management Attorneys for Plaintiffs Novo Nordisk A/S and Novo Nordisk Inc.

1 See Shapo v. Engle, 463 F.3d 641, 646 (7th Cir. 2006): “the district court should state that judgment is being entered in order to allow the parties to enforce it and that the “without prejudice” language shall not allow them to reopen issues resolved by the judgment.”