K2A v. Mona Vie et. al

8/13/2019 K2A v. Mona Vie et. al.

1/24

1

Randall B. Bateman (USB 6482)Sarah W. Matthews (USB 13295)

BATEMAN IP LAW GROUP, P.C.257 East 200 South, Suite 750Salt Lake City, Utah 84111Tel: (801) 533-0320/Fax: (801) 533-0323Email: [email protected], [email protected], [email protected]

Terry E. Welch (USB 5819)PARR BROWN GEE & LOVELESS185 South State Street, Suite 800Salt Lake City, Utah 84111Tel: (801) 532-7840) Fax: (801) 532-7750

Email: [email protected]; [email protected]

UNITED STATES DISTRICT COURTFOR THE DISTRICT OF UTAH, CENTRAL DIVISION

K2A, LLC, a Utah limited liabilitycompany,

Plaintiff,

vs.

MONA VIE, Inc. a Utah corporation;MONAVIE, LLC, a Delaware limitedliability company; and DOES 1-50,

Defendants.

COMPLAINT AND JURY

DEMAND

Case No.: 2:14-cv-00104-PMW

Mag. Judge: Paul M. Warner

Plaintiff K2A, LLC Hereby complains against the defendants as follows:


2/24

2

PARTIES

1.

K2A, LLC (K2A) is a Utah Limited Liability Company having a business address

at 801 South Pleasant Grove, Boulevard, Suite 200, Pleasant Grove, Utah 84062.

2. Defendant Mona Vie, Inc. is a Utah corporation having a business address at10855 South River Front Pkwy Suite 100, South Jordan, UT 84095.

3. Defendant MonaVie, LLC is a Delaware Limited Liability Company having anaddress at 10855 South River Front Pkwy Suite 100, South Jordan, UT 84095.

4. On information and belief, Does 1-50 are agents, employees or distributors ofMonaVie, LLC or the other defendants.

JURISDICTION AND VENUE

5. This is a case for patent infringement pursuant to 35 U.S.C. 271, for falseadvertising pursuant to 15 U.S.C. 1125(a), and for breach of contract.

6. This Court has jurisdiction over the patent claims and false advertising claimsunder 28 U.S.C. 1331 and 1338(a), and supplemental jurisdiction over the breach of contract

claims pursuant to 28 U.S.C. 1367(a).

7. Venue is proper in this district under 28 U.S.C. 1391(b) and 1400 because eachof the named defendants resides in this district and/or because each of the defendants has

conducted business in the state of Utah and has availed itself of the laws and privileges of the

state of Utah with respect to the transactions which give rise to the allegations set forth in the

present action.


3/24

3

BACKGROUND

8.

In about 2003 Dr. Alex Schauss (Schauss) and Ken Murdock (Murdock)

made discoveries regarding nutritional properties of the aai berry which grows in the rainforests

of Brazil.

9. Schauss and Murdock determined that the aai berry was particularly rich inantioxidants and other nutrients which are important for a healthful diet.

10. Moreover, Schauss and Murdock discovered that by freeze-drying the aai berryand the related juara berry (collectively referred to as aai), they could obtain a powder that had

a level of antioxidant activity dramatically higher than any other known fruit.

11. The level of antioxidant activity in food can be described by the Oxygen RadicalAbsorbance Capacity test (ORAC).

12. The freeze-dried aai powder has been known to have an ORAC value which isnearly 10 times that of the fruit having the next highest ORAC value.

13. Schauss and Murdock filed for a patent on the technology in 2003 and assignedthe application to K2A.

14. Dr. Schauss also signed a services agreement with K2A to promote thetechnology covered in the patent application.

15. In late 2004 K2A was introduced to the owners of a new start-up company calledMonarch Health Sciences, Inc. (Monarch).

16. Monarch was setting up a multi-level marketing company but needed a product tomarket and sell. Upon learning of K2As aai berry technology, Monarch started making juice


4/24

4

prepared from freeze-dried aai as their lead product. Monarch used aai as the featured

ingredient in most of their products.

17. Prior to Monarchs launch of its aai products, Monarch orally agreed to pay K2Aa five percent (5%) interest in Monarch for use of K2As technology. Monarch, however, failed

to provide the stock.

18. After several months of Monarchs use of K2As technology, K2A insisted thatMonarch would need to finalize the licensing deal if they wished to market products using

K2As technology. Monarch, however, repeatedly changed the terms under which it would

license K2As technology.

19. During spring and summer of 2006, a license agreement (the LicenseAgreement) was negotiated and signed by the parties.

20. In exchange for an exclusive license in the area network marketing, Monarchagreed to pay K2A licensing fees in two ways. Monarch gave K2A 74,000 shares of stock,

which was purported to be 1% of the company. Monarch also agreed to pay K2A 20% of all

K2A-Related Revenue.

21. K2A-Related Revenue is defined in the License Agreement as all revenuesactually received by Licensee from the sale, use, or other disposition of any promotional items,

products or materials (educational, sales, and/or training aids) that include either (a) the name,

image, likeness, photograph, voice, and signature of Alex Schauss, or (b) any reference to the

Patents, Trademarks, or research, literature, articles or other items produced by K2A, adjusted

only for refunds actually made.


5/24

5

22. The License Agreement also required Monarch to provide K2A with quarterlywritten reports within fifteen (15) days after the end of each quarter during the term of this

Agreement, stating in each such report the number and description of K2A-Related Revenue and

reasonable detail regarding the calculation of such K2A-Related Revenue received by Licensee

during the preceding quarter.

23. The License Agreement was signed on or about July 21, 2006.24. Shortly after the License Agreement was signed, Monarch merged into MonaVie,

Inc.

25. Shortly thereafter, MonaVie, Inc. set up a new operating entity MonaVie, LLC sothat profits from the sales of their products could pass through directly to the shareholders

without being subjected to corporate taxes. (MonaVie, Inc. and MonaVie, LLC are collectively

referred hereafter as MonaVie.)

26. MonaVies sales of products using K2As technology were remarkable.27. MonaVie became the fastest multi-level marketing company to reach 1 billion

dollars ($1,000,000,000) in total sales.

28. In 2008 alone, MonaVies sales were estimated to be over $800 million dollars.29. MonaVie utilized Dr. Schauss extensively, including having Dr. Schauss speak at

MonaVie events worldwide.

30. MonaVie produced numerous educational, sales, and training materials forMonaVie distributors using the name, likeness, photograph, etc., of Dr. Schauss and discussing

his research for K2A.


6/24

6

31. MonaVie also produced promotional items, products or materials, includingeducational, sales and/or training aids, that referred to K2As patents and research, such as the

surprisingly high ORAC values of freeze-dried aai.

32. While MonaVie failed to pay royalties to K2A as required by the LicenseAgreement, it did provide more than $118,000 dollars to Dr. Schauss directly from 2007 to 2009.

33. K2A was under the understanding that the fees were paid to Schauss were forspeaking fees, as MonaVie was not providing reports to K2A as required by the License

Agreement.

34. Only recently did K2A learn that the payments to Schauss were royalties owed toK2A.

35. On or about July 21, 2009, U.S. Patent No. 7,563,465 was issued to K2A forJuara and Aai Fruit-Based Dietary Supplements. The patent includes 14 claims, and covers

both the dietary supplement of freeze-dried aai, as well as the method of freeze-drying the aai.

36. In fall 2009, MonaVie complained to K2A that other companies were utilizingK2As patented technology and therefore violating K2As patents.

37. While the License Agreement left enforcement of the patents to the sole discretionof K2A, K2A indicated that it would be willing to enforce the patent but needed to receive

royalty payments from MonaVie in order to pursue the infringers.

38. MonaVie has not made any royalty payments under the License Agreement toK2A or its principals since at least June of 2009. MonaVie has also failed to provide K2A with

any of the quarterly reports pursuant to the License Agreement.


7/24

7

39. In the summer of 2013, K2A grew frustrated by the lack of any royalties beingpaid pursuant to the License Agreement and began actively investigating the activities of

MonaVie which would necessitate payment of a royalty under the License Agreement.

40. Upon investigation, K2A found that MonaVie was producing materials thatreferenced the patents, Dr. Schauss, and K2As research.

41. These materials referencing the patents and related research were being sold toMonaVie distributors as part of their enrollment kits at prices up to $699.

42. Pursuant to the License Agreement, the revenue from sales of the enrollment kitsis K2A-Related Revenue and K2A is entitled to 20% of the revenue generated.

43. It was also discovered that MonaVie obtained further revenue by sellingmarketing, education and training materials, including publications, brochures, video tapes,

compact disks, digital video disks and other materials which reference Dr. Schauss, K2As

patents, K2A articles and/or K2As research to MonaVie distributors.

44. MonaVie also obtained millions of dollars in revenue by holding conventions andconferences for its distributors wherein Dr. Schauss, K2As patents, K2As articles and/or K2As

research were referenced as part of MonaVies promotion of its products to its distributors and

potential distributors.

45. MonaVie also referenced Dr. Schauss, K2As patents and K2As research on itswebsite and has used these references in association with selling product directly from

MonaVies website.

46. On information and belief, MonaVie has derived tens of millions of dollars inK2A-Related Revenue.


8/24

8

47. MonaVie, however, has consistently failed to provide quarterly reports requiredby the License Agreement and has failed to pay any royalties to K2A or its principals since at

least June of 2009.

48. MonaVie has also impaired K2As patent rights in violation of the LicensingAgreement by repeatedly representing to the public and its distributors that the patents belong to

MonaVie and falsely suggesting that MonaVies founders were the inventors behind K2As

patents .

49. On September 17, 2013, K2A sent a notice of termination of the LicenseAgreement to MonaVie in light of MonaVies repeated material breaches of the agreement.

50. Pursuant to the terms of the License Agreement, K2A gave MonaVie 30 days tocure the breaches.

51. Despite K2As requests, MonaVie failed to provide any reports regarding K2A-Related Revenue as defined by the license agreement from at least June of 2009 through

September of 2013.

52. Moreover, MonaVie affirmatively represented that it owed no royalties to K2Adespite the fact the MonaVie has obtained substantial revenue by using the name and image of

Dr. Schauss, by referencing K2As patents, and by referencing K2As research in its marketing

educational and training materials, at conventions for distributors, and on its website.

53. MonaVie also failed to completely cure its breach of the agreement by continuingto falsely represent to the public that it was the owner of K2As technology, including the patents.

54. On October 18, 2013, K2A confirmed to MonaVies counsel that the licenseagreement was terminated effective October 18, 2013.


9/24

9

55. MonaVie practices K2As patents each and every time it makes the products itsells and each time it promotes and offers them for sale.

56. Yet, remarkably MonaVie claims boththat it has a license to so practice the K2Apatents and that is does notowe K2A any royalties with regard to the agreement that grants them

the license.

57. In its correspondence with MonaVie, K2A reminded MonaVie that the products itmakes, sells or offers for sale utilizing K2As technology were no longer licensed and that

continued manufacture, promotion and sales of those products would constitute willful patent

infringement.

58. K2A has also advised MonaVies counsel that direct sales of product onMonaVies website is not permitted by the License Agreement and therefore infringes K2As

patents.

59. K2A currently has 5 patents on freeze-dried aai and juara.60. MonaVies products are made using the technology claimed in K2As patents and

MonaVie has repeatedly represented to its distributors and to the public that its products are

protected by the patents.

61. Despite the termination of the license agreement on October 18, 2013, MonaViehas continued to sell fruit juice and dietary supplements which utilize freeze-dried aai and/or

juara, thereby infringing K2As patents.

62. MonaVie was fully aware that its products were covered by K2As patents as ithad repeatedly represented to its own distributors and to the public that the products were

protected by the patents.


10/24

10

63. Therefore, MonaVie has willfully infringed the K2A patents.64.

In addition to failing to pay royalties and willfully infringing K2As patents,

MonaVie is still falsely representing to the public that it was MonaVie and/or MonaVies

founders who invented K2As technology regarding juara and aai.

65. For example, more than a month after K2A asked MonaVie to stop representingK2As technology as being owned by MonaVie, MonaVies website still stated: In 2010, the

founders took the incredible antioxidant power of aai a step further by developing and patenting

AaVie.

66. The same webpage identifies the founders as Dallin Larsen, Henry Marsh, andRandy Larsen.

67. On information and belief, Dallin Larsen is not listed as an inventor on any patent.68. On information and belief, Henry Marsh is not listed as an inventor on any patent.69. On information and belief, Randy Larsen is not listed as an inventor on any patent.70. The patents covering AaVie as used by MonaVie were actually patents

granted to K2A.

71. The false claims of ownership and inventorship by MonaVie regarding K2Astechnology harm K2As ability to sell or license its technology to third parties.

/

/

/


11/24

11

FIRST CLAIM FOR RELIEF

PATENT INFRINGMENT

(35 U.S.C. 271)

72. Plaintiff re-alleges the preceding paragraphs as a fully set forth herein and furtheralleges as follows:

73. K2A is the owner by assignment of U.S. Patent Nos. 7,563,465; 7,700,138;7,727,564; 7,799,354 and 8,153,170.

74. On information and belief, in the process or making MonaVies products,including at least one or more of MX, ESSENTIAL, ACTIVE, ACTIVE GEL, PULSE,

(M)MUN, KOSHER, ESSENTIAL, RVL shake mixes, RVL dietary supplements, HDH RPO

protein bars, EMV and EMV LITE, MonaVie makes, uses or sells a dietary supplement as

covered by claim 1, and induces infringement by teaching its distributors and the public to use

freeze-dried aai as covered by at least claims 11 and 13, of U.S. Patent No. 7,563,465.

75. On information and belief, in the process of marketing MonaVies products,including at least one or more of MX, ESSENTIAL, ACTIVE, ACTIVE GEL, PULSE,


protein bars, EMV and EMV LITE, MonaVie teaches its distributors and the public to use

freeze-dried aai as covered by at least claims 1 and 4 of U.S. Patent No. 7,700,138.

76. On information and belief, in the process of marketing MonaVies products,including at least one or more of MX, ESSENTIAL, ACTIVE, ACTIVE GEL, PULSE,



12/24

12

protein bars, EMV and EMV LITE, MonaVie teaches its distributors and the public to use

freeze-dried aai as covered by at least claims 1 and 4 of U.S. Patent No. 7,727,564.

77. On information and belief, in the process of making MonaVies products,including at least one or more of MX, ESSENTIAL, ACTIVE, ACTIVE GEL, PULSE,


protein bars, EMV and EMV LITE, MonaVie makes, uses, or sells a dietary supplement as

covered by at least claims 1and 6, and teaches its distributors and the public to use freeze-dried

aai as covered by at least claim 11, of U.S. Patent No. 7,799,354.

78. On information and belief, in the process or making MonaVies products,including at least one or more of MX, ESSENTIAL, ACTIVE, ACTIVE GEL, PULSE,


protein bars, EMV and EMV LITE, MonaVie makes, uses or sells a dietary supplement as

covered by at least claims 1 and 6 of U.S. Patent No. 8,153,170.

79. MonaVies license to use the patents was terminated on October 18, 2013 due toMonaVies repeated material breaches of the License Agreement, and after MonaVies failure to

cure such breaches pursuant to the terms of the License Agreement.

80. Despite the termination of the License Agreement, MonaVie has continued to sellproducts which infringe K2As patents.

81. Moreover, since at least March of 2013, MonaVie has been selling productdirectly from its website to consumers.


13/24

13

82. The License Agreement only gave MonaVie a license to sell products underK2As patents via network marketing sales through distributors, and did not authorize on-line

sales to end consumers.

83. MonaVie has infringed the patents by selling fruit juice made with freeze-driedaai and/or juara powder and by selling other dietary supplements which include freeze-dried

aai and/or juara powder not authorized by the License Agreement.

84. At the time of the infringing sales, MonaVie was aware that the products it wasselling were not covered by the License Agreement and therefore the infringing sales constituted

willful infringement.

85. On information and belief, Defendants Dallin Larsen, Henry Marsh and RandyLarsen personally directed the infringing activities alleged herein and were aware that they

constituted infringement.

86. Therefore, K2A makes a claim for Patent Infringement against the Defendants.SECOND CLAIM FOR RELIEF

FALSE ADVERTISING

(15 U.S.C. 1125(A))

87. K2A re-alleges the allegations of the preceding paragraphs as fully containedherein and further alleges:

88. MonaVie was a licensee of patents owned by K2A.89. On numerous occasions, MonaVie falsely represented to its own distributors and

to the public that MonaVie owned the patents which covered MonaVies products.


14/24

14

90. On numerous occasions, MonaVie has represented that Dallin Larsen, HenryMarsh, and Randy Larsen were the inventors or creators of technology belonging to K2A.

91. The false representations of fact by MonaVie create a likelihood of confusionamongst MonaVies distributors and the public as to the true owners and true inventors of K2As

technology used by MonaVie and damages K2A.

92. Therefore, K2A sets forth a claim against MonaVie for false advertising under theLanham Act.

THIRD CLAIM FOR RELIEF

TRUTH IN ADVERTISING

(Utah Code 13-11a-3)


94. Neither MonaVie nor any of its employees were inventors of the technology setforth in the K2A Patents.

95. MonaVie has never been assigned any interest in the K2A Patents.96. Despite having no inventorship or ownership in the K2A Patents, MonaVie and

its founders repeatedly represented to their distributors and the public that MonaVie owned the

patents and that the founders were inventors of the subject matter of the K2A Patents.

97. K2A placed MonaVie on notice of its violations, and MonaVie has failed tocorrect the same.


15/24

15

98. Therefore, K2A sets forth a claim against MonaVie under the Utah Truth inAdvertising Act.

FOURTH CLAIM FOR RELIEF

DECLARATORY JUDGMENT

(28 U.S.C. 2201)

99.K2A re-alleges the allegations of the preceding paragraphs as fully contained herein andfurther alleges:

100. MonaVie has failed to provide quarterly reports pursuant to the LicenseAgreement.

101. MonaVie has failed to pay royalty payments to K2A since at least June of 2009.102. MonaVie has repeatedly impaired K2As title to K2As patents by falsely

representing that MonaVie owned the patents or created the technology described therein.

103. MonaVie was placed on notice of the material breaches by a delivery of a letter toMonaVie on September 17, 2013.

104. Despite being provided 30 days to cure the breaches, MonaVie failed to do so.105. MonaVie has continued to use K2As patents, the name and image of Dr. Schauss

and K2As research without payment of the royalty.

106. K2A seeks a declaration that it has effectively terminated the License Agreementand that it is no longer in effect.


16/24

16

FIFTH CLAIM FOR RELIEF

BREACH OF CONTRACT

(Common Law)


108. MonaVie has failed to provide quarterly reports pursuant to the LicenseAgreement.

109. MonaVie has failed to pay royalty payments since at least June of 2009.110. MonaVie has repeatedly impaired K2As title to K2As patents by falsely

representing that MonaVie owned the patents or created the technology described therein.

111. MonaVie was placed on notice of the material breaches by a delivery of a letter toMonaVie on September 17, 2013.

112. Despite being provided 30 days to cure the breaches, MonaVie failed to do so.113. MonaVie has continued to use K2As patents, the name and image of Dr. Schauss

and K2As research without payment of royalty.

114. On information and belief, the past royalties due pursuant to the LicenseAgreement are at least several million dollars.

115. MonaVies failure to provide quarterly reports, failure to pay royalties, and falselyclaiming ownership/inventorship of K2As technology each constitutes a material breach of the

License Agreement.


17/24

17

116. Therefore, K2A makes a claim for breach of contract against MonaVie.

FIFTH CLAIM FOR RELIEF

UNJUST ENRICHMENT

(Common Law)


118. K2A has conferred a benefit on MonaVie by allowing MonaVie to utilize K2Astechnology and to represent to consumers and competitors that it was licensed under K2As

patents.

119. MonaVie has been enriched by using K2As technology and its patents and hasachieved in excess of $2 Billion in sales based on K2As technology.

120. MonaVie has retained the benefit conferred upon it by using K2As technologyand its patents, and has refused to pay K2A a fair portion of its sales.

121. Therefore, K2A makes a claim against MonaVie for unjust enrichment.PRAYER FOR RELIEF

WHEREFORE, K2A prays for an Order, Judgment and Injunction as follows:

A. On each of the Claims for Relief, for a judgment in favor of K2A and againstDefendants, including an award of damages and injunctive relief as determined at trial or

by the Court, including trebled damages, along with additional interest, costs, and

attorney fees.


18/24

18

B. A Declaration that the License Agreement is no longer in effect, having been properlyterminated by K2A due to MonaVies material breaches.

C. Judgment that United States Patent No. 7,563,465 is valid and infringed byDefendants, and

i. For damages for patent infringement in an amount to be determined at trial, suchdamages being not less than a reasonable royalty of at least10% of gross sales;

ii. A finding that Defendants acted willfully in infringement of the 542 Patent andfor an award of treble damages pursuant to 35 U.S.C. 284;

iii. That Defendants, their agents, servants, employees, directors, and those persons inactive concert or participation with them, individually and/or jointly, be enjoined

under 35 U.S.C. 283 from further violation of Plaintiffs patent rights or such

terms as the Court deems reasonable, including, without limitation, that

Defendants cease making, selling, offering for sell, or distributing, the Infringing

Goods and any other products which infringe the 542 Patent;

iv. That Defendants be ordered to file with this Court and serve on Plaintiffs withinthirty (30) days after service on Defendants of the injunction granted herein, or

such extended period as the Court may direct, a report in writing, under oath,

setting forth in detail the manner and form in which Defendants have complied

with the injunction and order of the Court;

v. That Defendants be ordered to pay Plaintiffs attorneys fees and costs anddisbursements for this action under 35 U.S.C. 285; and


19/24


20/24


21/24

21

F. Judgment that United States Patent No. 7,799,354 is valid and infringed byDefendants, and

i. For damages for patent infringement in an amount to be determined at trial, suchdamages being not less than a reasonable royalty of at least 10% of gross sales;


iii. That Defendants, their agents, servants, employees, directors, and those persons inactive concert or participation with them, individually and/or jointly, be enjoined under 35 U.S.C.

283 from further violation of Plaintiffs patent rights or such terms as the Court deems

reasonable, including, without limitation, that Defendants cease making, selling, offering for sell,

or distributing, the Infringing Goods and any other products which infringe the 354 Patent;

iv. That Defendants be ordered to file with this Court and serve on Plaintiffs withinthirty (30) days after service on Defendants of the injunction granted herein, or such extended

period as the Court may direct, a report in writing, under oath, setting forth in detail the manner

and form in which Defendants have complied with the injunction and order of the Court;


vi. That Defendants be required to pay pre-judgment and post-judgment interest untilsuch awards are paid.

G. Judgment that United States Patent No. 8,153,170 is valid and infringed byDefendants, and


22/24

22

i. For damages for patent infringement in an amount to be determined at trial, suchdamages being not less than a reasonable royalty of at least10% of gross sales;


iii. That Defendants, their agents, servants, employees, directors, and those persons inactive concert or participation with them, individually and/or jointly, be enjoined under 35 U.S.C.

283 from further violation of Plaintiffs patent rights or such terms as the Court deems

reasonable, including, without limitation, that Defendants cease making, selling, offering for sell,

or distributing, the Infringing Goods and any other products which infringe the 170 Patent;

iv. That Defendants be ordered to file with this Court and serve on Plaintiffs withinthirty (30) days after service on Defendants of the injunction granted herein, or such extended

period as the Court may direct, a report in writing, under oath, setting forth in detail the manner

and form in which Defendants have complied with the injunction and order of the Court;


vi. That Defendants be required to pay pre-judgment and post-judgment interest untilsuch awards are paid.

H. That Defendants cease using all marketing or advertising materials reflecting theInfringing Goods.

I. That Defendants destroy all materials using or containing the Infringing Goodsand all advertisements in their possession or control.


23/24

23

J. That Defendants recall all labels, signs, prints, packages, advertisements,promotional and/or marketing materials that reflect the Infringing Goods.

K. That Defendants shall notify all affiliates which market or sell the InfringingGoods of this Courts order.

L. Judgment that Defendants have violated 15 U.S.C. 1125(a) and committed falseadvertising by falsely claiming ownership/ inventorship in K2As technology, and:

i. awarding K2A its damages and/or any profits of Defendants and its costs of theaction pursuant to 15 U.S.C. 1117(a); and

ii. finding that this is an exceptional case and award K2A attorneys fees pursuant to15 U.S.C. 1117(a).

M. That Defendants and all other persons participating or acting in concert with them, beenjoined from falsely representing ownership and/or inventorship in K2As technology.

N. That Defendants be ordered to prepare an accounting of all proceeds generated by theDefendants false advertising;

O. That Defendants be ordered to conduct corrective advertising to advise the public thatthey are neither owners nor inventors of K2As technologies.

P. Judgment finding that Defendants violated the Utah Truth in Advertising Act and:i. awarding K2A three times its damages and an amount not less than $2,000 for

violation of the Utah Truth in Advertising Act, Utah Code Ann. 13-11(a)-3; and

ii. awarding injunctive relief, court costs, and attorneys fees pursuant to the UtahTruth in Advertising Act, Utah Code Ann. 13-11(a)-4.


24/24

Documents

K2A v. Mona Vie et. al