AGREED PERMANENT INJUNCTION Page 1

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

PRUVIT VENTURES, INC. § 

§

Plaintiff, § 

§

v. § CIVIL ACTION NO. 4:23-00796-ALM

§

CASEY KIO §

§

§

Defendants. §

AGREED PERMANENT INJUNCTION AND FINAL JUDGMENT

Pending before the Court is Plaintiff Pruvit Ventures, Inc. (“Pruvit” or “Plaintiff”) and 

Defendant Casey Kio (“Kio” or “Defendant”) Joint Application for Entry of Agreed 

Permanent Injunction and Final Judgment (Dkt. #8). The Parties have advised the Court that

they request the Court enter the following Agreed Permanent Injunction (the “Order”) and have 

fully and completely consented to and agreed to be bound by this Order,1

and have reached a 

settlement in this case. 

After considering the application, the record, the relevant authorities, and in light of 

the agreement of the parties, the Court finds that there is good cause to grant this Order. The 

Court further finds that Pruvit is entitled to the Agreed Permanent Injunction in this matter, 

hereby makes all necessary findings to support the entry of this Order, and the parties hereto 

waive any other findings or procedural requirements necessary to support entry of this Order. 

Based on the Parties’ agreement and the Court’s findings, it is ORDERED as follows:

Kio is enjoined and restrained, both directly and from engaging in any of the following: 

1 The parties have stipulated, and the Court now finds, that all parties enjoined by this Order have waived all rights to 

seek judicial review or otherwise challenge or contest the validity of this Order, whether directly or collaterally. 

Case 4:23-cv-00796-ALM Document 9 Filed 12/19/23 Page 1 of 4 PageID #: 80
AGREED PERMANENT INJUNCTION Page 2

a. Through August 9, 2024, Kio shall not induce any existing Pruvit

customer or promoter, whom Kio knows is a Pruvit customer or

promoter, to terminate his/her/its business relationship with Pruvit;

b. Through August 9, 2024, Kio shall not induce any existing Pruvit

promoter, whom Kio knows is a Pruvit promoter, to violate or breach

the terms of his/her/its Pruver Agreement;

c. Through August 9, 2024, Kio shall not directly or indirectly recruit,

any other Pruvit promoters and customers, whom Kio knows is a Pruvit

customer or promoter, for any other direct sales or network marketing

business;

d. Through August 9, 2024, Kio shall not engage, or attempt to engage,

in any transactions relating to the business of Pruvit, including any

soliciting, promotion or selling of any products offered by Pruvit with a

network marketing company other than Pruvit, including but not limited

to nutritional drinks, ketones, electrolytes, collagen, and keto creams;

e. Directly or indirectly disclose or otherwise use, in any manner, any

confidential and/or proprietary information relating to Pruvit or any of

its products and services; and

f. Through August 9, 2024, promote or market Green Compass Inc.’s

products or services utilizing any social media pages utilized by Kio

while she was a Pruvit promoter.

g. Kio shall unfriend and unfollow any person identified in Exhibit A

to the Parties’ Settlement Agreement within seven (7) days after the

filing of this Injunction. Alternatively, Kio can deactivate any social

media accounts she utilized while working for Pruvit and those accounts

must remain deactivated until August 9, 2024. Exhibit A was mutually

agreed upon by Kio and Pruvit. Kio shall not accept friend or follow

requests from any person identified in Exhibit A until August 9, 2024

or a sooner date as identified in Exhibit A, on the social media pages

referenced herein.

If Pruvit believes that there has been a violation of any of the injunctive provisions above, 

then Pruvit shall provide written Notice to Kio. Notice shall be provided to Paul Simon at 

paul@simonpaschal.com. Kio will then have seven (7) days from receipt of the Notice to cure 

the alleged violation (“Cure Period”), to the extent cure is possible. 

Case 4:23-cv-00796-ALM Document 9 Filed 12/19/23 Page 2 of 4 PageID #: 81
AGREED PERMANENT INJUNCTION Page 3

Other than the injunctive relief granted hereby, the Court ORDERS that any other claims 

by and between the parties are DISMISSED WITH PREJUDICE and this case closed.

The Court further ORDERS that it shall retain jurisdiction over this matter solely to 

enforce this Order, hold contempt and other proceedings to enforce this Order, and to issue any 

relief the Court deems appropriate should any of the parties violate this Order. 

This Final Judgment and Agreed Permanent Injunction shall be entered as a final 

judgment under Federal Rule of Civil Procedure 54 and 58(a). 

IT IS SO ORDERED.

Case 4:23-cv-00796-ALM Document 9 Filed 12/19/23 Page 3 of 4 PageID #: 82
AGREED PERMANENT INJUNCTION Page 4

AGREED AS TO FORM AND SUBSTANCE

AND ENTRY REQUESTED:

/s/ Kelly E. Kleist_______________

BYRON K. HENRY

KELLY E. KLEIST

Attorney for Plaintiff

/s/ Paul Simon (With Permission)

PAUL SIMON

Attorney for Defendant

Case 4:23-cv-00796-ALM Document 9 Filed 12/19/23 Page 4 of 4 PageID #: 83