Lokai Holdings v. Twin Tiger - Complaint

7/26/2019 Lokai Holdings v. Twin Tiger - Complaint

1/102

{Client/082577/25/01063079.DOCX;1}

Mark J. RosenbergAmy B. GoldsmithTARTER KRINSKY & DROGIN LLP1350 BroadwayNew York, New York 10018

Telephone: 212-216-8000Facsimile: [email protected]@tarterkrinsky.com

Attorneys for Lokai Holdings LLC

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

LOKAI HOLDINGS LLC,

Plaintiff,

v.

TWIN TIGER USA LLC, TWIN TIGERWORLD MARKETS LTD., RORYCOPPOCK and TROY COPPOCK,

Defendants.

Case No. 15-CV-9363

THIRD AMENDED COMPLAINT

JURY TRIAL DEMANDED

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.

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


2/102

{Client/082577/25/01063079.DOCX;1} 2

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,



3/102

{Client/082577/25/01063079.DOCX;1} 3

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



4/102

{Client/082577/25/01063079.DOCX;1} 4

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



5/102

{Client/082577/25/01063079.DOCX;1} 5

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.



6/102

{Client/082577/25/01063079.DOCX;1} 6

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



7/102

{Client/082577/25/01063079.DOCX;1} 7

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



8/102

{Client/082577/25/01063079.DOCX;1} 8

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.



9/102

{Client/082577/25/01063079.DOCX;1} 9

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



10/102

{Client/082577/25/01063079.DOCX;1} 10

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.



11/102

{Client/082577/25/01063079.DOCX;1} 11

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.



12/102

{Client/082577/25/01063079.DOCX;1} 12

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



13/102

{Client/082577/25/01063079.DOCX;1} 13

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.



14/102

{Client/082577/25/01063079.DOCX;1} 14

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



15/102

{Client/082577/25/01063079.DOCX;1} 15

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:



16/102

{Client/082577/25/01063079.DOCX;1} 16

Making, having made, importing, selling, and offering to sell1.

infringing products practicing the 000 Patent and from otherwise

infringing, contributing to infringement of, and actively inducing

infringement of the 000 Patent;

Using the Infringing Trade Dress, the LOKAI Trade Dress or any2.

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;

Infringing the LOKAI Trade Dress;3.

Unfairly competing with Lokai; and4.

Using in connection with the sale of any goods or services or the5.

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;



17/102

{Client/082577/25/01063079.DOCX;1} 17

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 YorkFebruary 1, 2016

TARTER KRINSKY & DROGIN LLP

By: /s/ Mark J. RosenbergMark J. RosenbergAmy B. Goldsmith

1350 BroadwayNew York, New York 10018(212) [email protected]@tarterkrinsky.com



18/102

EXHIBIT 1

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


19/102



20/102

EXHIBIT 2



21/102

Your Classic Lokai Bracelet Today

//mylokai.com/shop/lokai-bracelet-clear.html[11/30/2015 11:33:30 AM]

Follow Us

classic Limited-Edition Pack

Limited-Edition Pack

ogin | cart(0) |ShopSelect a Page

classic lokai

$18 USD

lokai donates 10% of net profits to charity partners.

Each lokai is infused with elements from the highest a

lowest points on Earth. The bracelets white bead carriwater from Mt. Everest, and its black bead contains m

from the Dead Sea. These extreme elements are a

reminder to the wearer to live a balanced life stayin

humble during lifes peaks and hopeful during its lows

S M L XL

SELECT THE SIZE :

Medium - 6 1/2" (16.5cm)

Usually fits teenage boys and the average woman.

(measurements represent circumference)

QTY:



22/102

Your Classic Lokai Bracelet Today

//mylokai.com/shop/lokai-bracelet-clear.html[11/30/2015 11:33:30 AM]

Newsletter:

All content and the hantag are copyrighted. Holdings LLC 2015. Thbrands and symbols artrademarks of LokaiHoldings. | Privacy PolTerms & ConditionsWebsite Designed byPollen Brands

add classic 3-stack+

Add to Cart

GivingBackokai dedicates 10% of

net profits to givingback via a variety of

charitable alliances.

Help

Returns & Exchanges

Shipping

Customer Service

Track an Order

GeneralAbout - Our Story

Authenticity

Retailer Inquiries

Accounts

My Account

Sign-up

Questions/Contact

FAQs

Contact Us

Press

[email protected]

Subscribe

1



23/102

EXHIBIT 3



24/102

Balancing Life (#ArtofY) | Alex Schattner

www.huffingtonpost.com/alex-schattner/lokai-balancing-life-arto_b_5686719.html[11/30/2015 11:36:12 AM]

Business Small Business Success Stories News and Trends What's Working: Small Businesses Build A Biz C-Suite Financial Education Small Business Voices

ADVERTISEMENT

FRONT PAGE POLITICS WORLDPOST BUSINESS TECH MEDIA GREEN SPORTS SCIENCE ARTS HUFFPOST LIVE ALL SECTIONS

Alex Schattner Become a fan

Writer/illustrator

Posted: 08/26/2014 2:32 pm EDT Updated: 10/26/2014 5:59 am EDT

Lokai: Balancing Life (#ArtofY)

"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 Lokaiin 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.

71

Share Tweet

0 0

Comment

PRESENTED BY HALLMARK STUDIO INK

Featuring fresh takes and real-time analysis

from HuffPost's signature lineup of contributorsCharles Ferguson Patricia Ward Kelly

Dr. James Hansen Richard Branson

HOT ON THE BLOG

November 30, 2015

Edition: U.S. Follow Newsletters Huffington Post Search

Small Business Tools iOS app Android app More Log in Create Account



25/102



SUGGESTED FORYOU

13 Real-Life Occasions That

Totally Deserve Greeting CardsQuick Read | Comments |

11.19.2015

If You Checked Your Regular Mail

Like You Check Your Email

4 Tips For A Safe Cyber Monday

AIDS Is Leading Cause Of Death

For African Teens: UN

Adding The USWNT To FIFA 16

Was Enormously Successful

Write Your Own Version Of Cher's

Iconic 'Clueless' Speech

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 onearth, 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.

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.

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



26/102



FOLLOW HUFFPOST

Climate Pact Is An 'Act Of

Defiance' After Paris Attacks,

Obama Says

Mom Struck And Killed Crossing

Highway Moments After Surviving

Car Crash

Watch What Happens When A

Dust Devil Strikes This Music

Festival

Pope Francis: 'Christians And

Muslims Are Brothers And Sisters'

Christmas Tree Shopping? Here's

What You Need To Know

AROUND THE WEB

15 Hollywood

Celebrities You

Didnt Know Went to

Short And Sweet:

Hollywood's 15

Shortest Actresses

10 Actors That

Came Out Of The

Closet#3 Will

by Gravity

Promoted by Healthy Diet Base Promoted by Starpulse Promoted by The Webtrovert

MORE:

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.

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.

Learn more aboutLokaiat: mylokai.com

Read more entrepreneurial stories! Catch up on #ArtofY:

Good-Time Sunglasses (#ArtofY)

Big Dreams Over Broadway

Socially Conscious Cashmere

Public Art in Digital Space

Customized Costume Jewelry

Yogurt Culture

Wine in a Box?

Local Manufacturing

Space for a Natural Energy Drink?

The Art of Y(vonne) Sangudi: The Next Great Songstress

'JewDate', Finding Farce in eLove

Redefining the Music Industry

An Interview With Fashion Designer Catherine Litke

Follow Alex Schattner on Twitter:www.twitter.com/alexschattner

Lokai, Dead Sea, Inspiration, Health, Balance, Life Journey, Mount Everest, Healthy

Living,

The Morning Email Small Bus iness

Get top stories and blog posts emailed to me each day.

Newsletters may offer personalized content or

advertisements.Learn more.

Email Address Sign meup!



27/102

EXHIBIT 4



28/102

rs Who Are Obsessed with Lokai Bracelets - Twist

//www.twistmagazine.com/posts/7-stars-who-are-obsessed-with-lokai-bracelets-45678/photos/topper-63510[11/30/2015 12:34:35 PM]

Beauty + Health Fashion Shopping Guys We Love

Advice

Win It

TwitterPinterestFacebookInstagram

TwitterPinterest

Trending: 7 Stars Who Are

Obsessed with LokaiBracelets

omments: 0AGGED:

JUSTIN BIEBER

ASHLEY BENSONBRACELETS

BUZZ

LOKAI

ILED UNDER:

Fashion

NOV 8, 2014 7:00AM BY JENNIFER MALDONADO

LEB NEWS FUN STUFF STAR STYLE GAMES FAN FICTION LOLZ BLINGEE FAN SHOP LOG IN



29/102

rs Who Are Obsessed with Lokai Bracelets - Twist

//www.twistmagazine.com/posts/7-stars-who-are-obsessed-with-lokai-bracelets-45678/photos/topper-63510[11/30/2015 12:34:35 PM]

SHARE TWEET

you have ever wondered what a piece of jewelry made from elements taken from Mt. Everest and the Dead Sea would look like, thou're in luck! Lokai braceletsare the answer you've been waiting for! These bracelets, made wih clear beads and one black bead iniddle, are infused with elements from the highest and lowest points on Earth to serve as a reminder to always stay balanced in life!

ot only do these bracelets have a wonderful meaning behind them, but they're being worn by some of your favorite celebs! Pretty Liarsstar Ashley Bensonhas just bought one of these elegant bracelets and couldn't stop gushing over it on her Instagram account. Won't blame her the bracelet is so nice!

lick through the gallery, featuring stars like Justin Bieber and Shawn Mendes, and tell us in the comments if you love theseracelets too!

1 OF 8

Articles and Offers

Celebs you didn't know passedaway: #17 is Shocking

Your Daily Dish

New Rule in New York LeavesDrivers Furious and Shocked

US Quote

15 Huge Mansions of NFL Playe(You Wont Believe Tom Brady's

Grizly

Ads by Ad



30/102

rs Who Are Obsessed with Lokai Bracelets 2 - Twist

//www.twistmagazine.com/posts/7-stars-who-are-obsessed-with-lokai-bracelets-45678/photos/ashley-benson-63498#photo-anchor[11/30/2015 12:35:44 PM]

SHARE TWEET


ot only do these bracelets have a wonderful meaning behind them, but they're being worn by some of your favorite celebs! Pretty Liarsstar Ashley Bensonhas just bought one of these elegant bracelets and couldn't stop gushing over it on her Instagram account. W

on't blame her the bracelet is so nice!


Credit:

Ashley Benson

Instagram

2 OF 8

Articles and Offers Ads by Ad



31/102


//www.twistmagazine.com/posts/7-stars-who-are-obsessed-with-lokai-bracelets-45678/photos/justin-bieber-63500#photo-anchor[11/30/2015 12:37:07 PM]

SHARE TWEET





Credit:

Justin Bieber

Getty

3 OF 8




32/102


//www.twistmagazine.com/posts/7-stars-who-are-obsessed-with-lokai-bracelets-45678/photos/shawn-mendes-63499#photo-anchor[11/30/2015 12:37:48 PM]

SHARE TWEET





Credit:

Shawn Mendes

Instagram

4 OF 8




33/102


//www.twistmagazine.com/posts/7-stars-who-are-obsessed-with-lokai-bracelets-45678/photos/christina-perri-63501#photo-anchor[11/30/2015 12:38:39 PM]

SHARE TWEET





Credit:

Christina Perri

Getty

5 OF 8




34/102


//www.twistmagazine.com/posts/7-stars-who-are-obsessed-with-lokai-bracelets-45678/photos/victoria-justice-63502#photo-anchor[11/30/2015 12:39:20 PM]

SHARE TWEET





Credit:

Victoria Justice

Twitter

6 OF 8




35/102


//www.twistmagazine.com/posts/7-stars-who-are-obsessed-with-lokai-bracelets-45678/photos/ashley-greene-63503#photo-anchor[11/30/2015 12:40:13 PM]

SHARE TWEET





Credit:

Ashley Greene

Getty

7 OF 8




36/102


//www.twistmagazine.com/posts/7-stars-who-are-obsessed-with-lokai-bracelets-45678/photos/emma-roberts-63504#photo-anchor[11/30/2015 12:40:42 PM]

SHARE TWEET





Credit:

Emma Roberts

Splash News

8 OF 8




37/102

EXHIBIT 5



38/102

ars Obsessed With Lokai Bracelets 2 - J-14

//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

TumblrTwitterPinterestFacebook

Instagram

9 Stars TotallyDEC 17, 2014 3:00PM BY HEATHER THOMPSON

One Direction

Justin Bieber

Taylor Swift

Selena Gomez

Ariana Grande

MoreOne DirectionJustin BieberTaylor SwiftSelena GomezAriana GrandeCody SimpsonVictoria Justice

Austin MahoneBella ThorneZendayaBig Time RushDemi LovatoMiley CyrusJennifer Lawrence

Customize

LEB NEWS FUN STUFF STAR STYLE GAMES FAN FICTION LOLZ BLINGEE FAN SHOP LOGWin prizes

J-14 WINI



39/102

ars Obsessed With Lokai Bracelets - J-14

//www.j-14.com/...ars-totally-obsessed-with-their-lokai-bracelets-48011/photos/bella-thorne-lokai-69885#photo-anchor[11/30/2015 12:26

Obsessed With TheirLokai BraceletsComments: 8

AGGED:

BELLA THORNE

VICTORIA JUSTICE

JUSTIN BIEBER

ASHLEY BENSON

VANESSA HUDGENS

ASHLEY GREENECHRISTINA PERRI

EIZA GONZALEZ

SHAWN MENDES

Credit:

Bella Thorne

Instagram



40/102

ars Obsessed With Lokai Bracelets - J-14

//www.j-14.com/...ars-totally-obsessed-with-their-lokai-bracelets-48011/photos/bella-thorne-lokai-69885#photo-anchor[11/30/2015 12:26

SHARE TWEET

he hottest bracelet to have this holiday season is the Lokai bracelet, which is infused with elements from the highnd lowest points on the planet. The bracelet features a white ball that holds water from Mt. Everest, and a black bhat holds mud from the Dead Sea.

he 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 starsotally obsessed with obtaining balance in their life, and sporting Lokai bracelets to remind themselves that theirourney is unique!

Keep up with Justin Bieber in the pages of J-14 bysubscribing now!

1 OF 9

Articles and Offers

Try this quick, healthy &

delicious SlimFast recipe: CinfulIced Latte Mocktail.

SlimFast

Father and Son Take the Same

Photo for 30 Years and the LastOne Will Amaze You

Grizly

Celebs you didn't know pass

away: #17 is ShockingYour Daily Dish

They took the same photo 28years in a row. The last photo

will blow your mind!Answers

New York: Homeowners are infor a big surprise in the next

few monthsThrifty Homeowners

15 Famous Celebs Who HavCommitted Horrible Crimes

Buzzlie

Ads by Adb



41/102




AGGED:

BELLA THORNE

VICTORIA JUSTICE

JUSTIN BIEBER

ASHLEY BENSON

VANESSA HUDGENS


EIZA GONZALEZ

SHAWN MENDES

Credit:

Justin Bieber

Getty Images



42/102



SHARE TWEET





2 OF 9

Articles and Offers

Celebs you didn't know passed




Grizly

Shocking Photos Of Hollywoo

Sexiest Stars That Packed OnTon Of Weight

OMGHype



15 Famous Celebs Who HaveCommitted Horrible Crimes!

Buzzlie

Try this quick, healthy &delicious SlimFast recipe: Sas

Strawberry Colada MocktaiSlimFast

Ads by Adb



43/102


//www.j-14.com/...-totally-obsessed-with-their-lokai-bracelets-48011/photos/ashley-benson-lokai-69878#photo-anchor[11/30/2015 12:25


AGGED:

BELLA THORNE

VICTORIA JUSTICE

JUSTIN BIEBER

ASHLEY BENSON

VANESSA HUDGENS


EIZA GONZALEZ

SHAWN MENDES

Credit:

Ashley Benson

Instagram



44/102


//www.j-14.com/...-totally-obsessed-with-their-lokai-bracelets-48011/photos/ashley-benson-lokai-69878#photo-anchor[11/30/2015 12:25

SHARE TWEET





3 OF 9

Articles and Offers


delicious SlimFast recipe:Chocoalte Mint Oasis Mocktail.

SlimFast



Grizly

New York: Homeowners are

for a big surprise in the nexfew months

Thrifty Homeowners

21 Celebrities You Had No IdeaAre Black!

Buzzlie


Buzzlie

75 UNREAL Rare Photos ThaWill Make You Second Gues

Yourself.OMGHype

Ads by Adb



45/102


//www.j-14.com/...s-totally-obsessed-with-their-lokai-bracelets-48011/photos/christina-perri-lokai-69879#photo-anchor[11/30/2015 12:27


AGGED:

BELLA THORNE

VICTORIA JUSTICE

JUSTIN BIEBER

ASHLEY BENSON

VANESSA HUDGENS


EIZA GONZALEZ

SHAWN MENDES

Credit:

Christina Perri

Instagram



46/102


//www.j-14.com/...s-totally-obsessed-with-their-lokai-bracelets-48011/photos/christina-perri-lokai-69879#photo-anchor[11/30/2015 12:27

SHARE TWEET





4 OF 9

Articles and Offers



Grizly

Shocking Photos Of Hollywood's

Sexiest Stars That Packed On ATon Of Weight

OMGHype

Top 15 Celebrities You Didn

Know are BlackPop Hitz


Buzzlie



Try this quick, healthy &delicious SlimFast recipe:

Chocoalte Mint Oasis MocktaSlimFast

Ads by Adb



47/102


//www.j-14.com/...-totally-obsessed-with-their-lokai-bracelets-48011/photos/victoria-justice-lokai-69880#photo-anchor[11/30/2015 12:28


AGGED:

BELLA THORNE

VICTORIA JUSTICE

JUSTIN BIEBER

ASHLEY BENSON

VANESSA HUDGENS


EIZA GONZALEZ

SHAWN MENDES

Credit:

Victoria Justice

Twitter



48/102


//www.j-14.com/...-totally-obsessed-with-their-lokai-bracelets-48011/photos/victoria-justice-lokai-69880#photo-anchor[11/30/2015 12:28

SHARE TWEET





5 OF 9

Articles and Offers



Grizly


delicious SlimFast recipe: CinfulIced Latte Mocktail.

SlimFast

15 Famous Celebs Who Hav

Committed Horrible CrimesBuzzlie

Shocking Photos Of Hollywood'sSexiest Stars That Packed On A

Ton Of WeightOMGHype



Celebs you didn't know passaway: #17 is Shocking

Your Daily Dish

Ads by Adb



49/102

ars Obsessed With Lokai Bracelets 6 - J-14#photo-anchor#photo-anchor

//www.j-14.com/...-totally-obsessed-with-their-lokai-bracelets-48011/photos/shawn-mendes-lokai-69881#photo-anchor[11/30/2015 12:29


AGGED:

BELLA THORNE

VICTORIA JUSTICE

JUSTIN BIEBER

ASHLEY BENSON

VANESSA HUDGENS


EIZA GONZALEZ

SHAWN MENDES

Credit:

Shawn Mendes

Instagram



50/102

ars Obsessed With Lokai Bracelets 6 - J-14#photo-anchor#photo-anchor

//www.j-14.com/...-totally-obsessed-with-their-lokai-bracelets-48011/photos/shawn-mendes-lokai-69881#photo-anchor[11/30/2015 12:29

SHARE TWEET





6 OF 9

Articles and Offers

15 Huge Mansions of NFL

Players (You Wont Believe TomBrady's)

Grizly

15 Famous Celebs Who Have

Committed Horrible Crimes!Buzzlie Gossip

Celebs you didn't know pass


Top 15 Celebrities You Didn'tKnow are Black

Pop Hitz

Try this quick, healthy &delicious SlimFast recipe:Winter Warmer Mocktail.

SlimFast

35 Once Famous Celebs ThaHave Aged Horribly Over Th

Years (SEE PHOTOS)VeryHangry

Ads by Adb



51/102


//www.j-14.com/...tally-obsessed-with-their-lokai-bracelets-48011/photos/vanessa-hudgens-lokai-69882#photo-anchor[11/30/2015 12:30


AGGED:

BELLA THORNE

VICTORIA JUSTICE

JUSTIN BIEBER

ASHLEY BENSON

VANESSA HUDGENS


EIZA GONZALEZ

SHAWN MENDES

Credit:

Vanessa Hudgens

Instagram



52/102


//www.j-14.com/...tally-obsessed-with-their-lokai-bracelets-48011/photos/vanessa-hudgens-lokai-69882#photo-anchor[11/30/2015 12:30

SHARE TWEET





7 OF 9

Articles and Offers

They took the same photo 28

years in a row. The last photowill blow your mind!

Answers


Committed Horrible Crimes!Buzzlie

75 UNREAL Rare Photos Tha

Will Make You Second GuesYourself.OMGHype

Try this quick, healthy &delicious SlimFast recipe: Tall,Dark and Handsome Mocktail.

SlimFast

21 Celebrities You Had No IdeaAre Black!

Buzzlie

Celebrity Twins: 20 Stars YoDidnt Know Were Twins!

Your Daily Dish

Ads by Adb



53/102


//www.j-14.com/...s-totally-obsessed-with-their-lokai-bracelets-48011/photos/ashley-greene-lokai-69883#photo-anchor[11/30/2015 12:30


AGGED:

BELLA THORNE

VICTORIA JUSTICE

JUSTIN BIEBER

ASHLEY BENSON

VANESSA HUDGENS


EIZA GONZALEZ

SHAWN MENDES

Credit:

Ashley Greene

Instagram



54/102


//www.j-14.com/...s-totally-obsessed-with-their-lokai-bracelets-48011/photos/ashley-greene-lokai-69883#photo-anchor[11/30/2015 12:30

SHARE TWEET





8 OF 9

Articles and Offers


delicious SlimFast recipe:Peanut Butter Banana

Smoothie.SlimFast

Shocking Photos Of Hollywood's

Sexiest Stars That Packed On ATon Of Weight

OMGHype

Father and Son Take the Sam

Photo for 30 Years and the LaOne Will Amaze You

Grizly


Buzzlie

Celebs you didn't know passedaway: #17 is Shocking

Your Daily Dish

New York: Homeowners are for a big surprise in the nex


Ads by Adb



55/102

ars Obsessed With Lokai Bracelets 9 - J-14#photo-anchor

//www.j-14.com/...rs-totally-obsessed-with-their-lokai-bracelets-48011/photos/eiza-gonzalez-lokai-69884#photo-anchor[11/30/2015 12:3


AGGED:

BELLA THORNE

VICTORIA JUSTICE

JUSTIN BIEBER

ASHLEY BENSON

VANESSA HUDGENS


EIZA GONZALEZ

SHAWN MENDES

Credit:

Eiza Gonzalez

Instagram



56/102

ars Obsessed With Lokai Bracelets 9 - J-14#photo-anchor

//www.j-14.com/...rs-totally-obsessed-with-their-lokai-bracelets-48011/photos/eiza-gonzalez-lokai-69884#photo-anchor[11/30/2015 12:3

SHARE TWEET





9 OF 9

Articles and Offers


Committed Horrible Crimes!Buzzlie



Grizly

Top 15 Celebrities You Didn

Know are BlackPop Hitz

Try this quick, healthy &delicious SlimFast recipe:Winter Warmer Mocktail.

SlimFast



Celebs you didn't know passaway: #17 is Shocking

Your Daily Dish

Ads by Adb



57/102

EXHIBIT 6



58/102

hake | Good Finds That Give Back | Inspired by Lokai Arm Candy: Finding Balance in 2015

/www.getmilkshake.com/inspired_by_lokai_arm_candy_finding_balance_in_2015[11/30/2015 11:41:57 AM]

Global Kids About / Subscribe / Contact / Press

SHOPPING GRUB MOVERS & SHAKERS EXPLORE ECO CAUSES

Join the Milkshake movement!Subscribe to our free

email dedicated to finding the good in everything:

Terms and Conditions / Privacy Policy

ts 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

ake a page out of Steven Izens book and start seeking wholeness. Balance. A life full

f highs, lows, and everything in between.

Inspired by Lokai Arm Candy:Finding Balance in 2015

Havent heard of Steven Izen? Thats okay, because hes not a celebrity or a high-profile guru or

nything like that. Izen is the founder of Lokai, a company that makes simple, pretty bracelets that

Put a Little Good in

Everyone's life

ec 22 2014 SHOPPING FASHION TweetComment Like

You like thisBe the first of your friends to like th

Get Milkshake8,846 likes

Like Page Liked Share

Search

Enter Your Email

1



59/102



SHOPPING FASHION ALL F INDS

More Milkshake: Share the Good:

How do you plan to live a more balanced life in

2015?

ontain water from the snows of Mount Everest, and mud from the shores of the Black Sea, the

ighest and lowest points on earth, respectively. And while these bracelets have some very

amous fans, thats not the real reason were digging them; 10 percent of the net profits from

okai are donated to fantastic charitable organizations like Pencils of Promise, charity: water,

he Cure Alzheimers Fund, and others.

he message of the flexible, wear-anywhere accessory is as simple as its design: When youve

eached a high point, stay humble, and when youre reached a low point, stay hopeful. Inspired by

zens 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.

veryones life is filled with some wonderful joys, but on the other side of the coin, every life also

as moments of sorrow.

n the spirit of the Lokai bracelent, in 2015 we will try to find balance and gratitude in every

xperience. A whole life is made up of both good and bad, high and low, light and dark. Lets look

or wholenessa more complicated matter than happiness, but one worth striving for.

SPONSORED

our Cable Company Doesnt

Want You To Know This

Python Eats A Huge Porcupine

Then Something Surprising

Happens

Python Eats A Porcupine

Whole, Then The Unexpected

Happens

lderly Couple Takes A Photo

our Times A Year. Try Not To

Cry. Last Photo Is A Tearjerker

When Eagles Attack. Amazing

Photos Of Them In Action!

Two Savings Accounts That

Pay 10 TIMES What Your Bank

Pays

he Motley Fool

Lolboom Lolboom

olboom

Showmethescience

Wiser Saver

Comment Milkshake Login1



60/102



Get your milkshake everyday and be a part

of all that's good - products, travel, music,

eco, people, causes and companies that

give back and make a difference:

Milkshake Global

Milkshake Kids

Deals

GOOD FINDS

Shopping

Grub

Movers & Shakers

Explore

Eco

Causes

All Finds

ABOUT MILKSHAKE

About Us

Advertising/Media Kit

Contact Us

FAQ's

Jobs

Press

Help

SUBSCRIBE

Subscribe

Unsubscribe

Invite a Friend

Terms & Conditions

Privacy Policy

Editorial Policy

SOCIAL

Copyright 2013

Milkshake, LLC.

ake A Stand To End Gun

iolence + A Letter From

ur Co- Founder

Celebrate Love! Eco-

Engagement Rings for Every

Couple

Get Cheeky At Target For A

Good Cause

Share Sort by Newest

Join the discussion

Maureen Absten 9 months ago

Help more toward real health which needs to be natural

Recommend

MOST RECENT FINDS



61/102



62/102



63/102



64/102



65/102



66/102



67/102



68/102



69/102



70/102



71/102



72/102



73/102

EXHIBIT 10



74/102

d: The Beaded Bracelet We Keep Spotting on Celebrities - SELF

/www.self.com/flash/charity/2015/03/lokai-world-water-day-bracelet[11/30/2015 11:58:00 AM]

PLAY WITH SOUND

SUBSC

The 10BestStretchesFor

BetterFlexibility

ReimagineMySelfSponsoredContent:

Biogen

27InsanelyAwesomeStocking

StuffersUnder$15

BoHaIs HTo

YoFit5MinWitThWoVid

2015

Mar 44:57 PM

CHARITY

By Sara Gaynes Levy

Found: The Beaded Bracelet We Keep Spotting on Celebrities

FLASH WHAT'S NEW NOW

46



75/102



What's the new accessory that keeps popping up on celebrity Instagram feeds? Remember this name: Lokai. These bracelets' white be

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 holida

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:

12 months agojuleshough Follow



76/102



58.3k likes 958 comments

12 months agoshaym Follow

347.3k likes 3,490 comments

12 months agoemmaroberts Follow



77/102



96.3k likes 1,353 comments

10 months agotorlykid Follow

23 likes 0 comments



78/102



14 months agolivelokai Follow

12.8k likes 220 comments

Content unavailable



79/102



For more information on how you can get involved with

Documents

Lokai Holdings v. Twin Tiger - Complaint