Novo Nordisk A/S v. Plastic and Reconstructive Surgery Center, S.C.

• Court: District Court, N.D. Illinois
• Decided: May 13, 2025
• Docket: 1:24-cv-12788
• Status: Unknown

Opinion

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

NOVO NORDISK A/S AND NOVO NORDISK INC.,

Plaintiffs, Case No. 1:24-cv-12788 v.

PLASTIC AND RECONSTRUCTIVE SURGERY CENTER S.C., 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 Plastic and Reconstructive Surgery Center S.C. (“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: May 13, 2025 Respectfully Submitted, /s/ Suyash Agrawal /s/ Dean J. Caras Suyash Agrawal Dean J. Caras Hillary W. Coustan CARAS LAW GROUP, P.C. Brigid Carmichael 320 West Illinois St., Ste. 2312 MASSEY & GAIL LLP Chicago, IL 60654 50 E Washington St., Ste. 400 dean.caras@deancaras.com Chicago, Illinois 60602 (312) 379-0949 sagrawal@masseygail.com hcoustan@masseygail.com bcarmichael@masseygail.com

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).