IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

Case Number: 4:23-cv-00251

GS HOLISTIC, LLC, 

Plaintiff,

v.

RR2K LLC d/b/a MEEN GREEN VAPOR 

SMOKE and KAPIL BHANDARI,

Defendants.

___________________________________/

COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES

The Plaintiff, GS HOLISTIC, LLC (hereinafter referred to as “GS”), by and through its

undersigned counsel, hereby files this, its Complaint against the Defendants, RR2K LLC d/b/a

MEEN GREEN VAPOR SMOKE and KAPIL BHANDARI, and alleges, as follows:

Jurisdictional Allegations

1. This is a civil action against the Defendants for trademark infringement, 

counterfeiting, and false designation of origin and unfair competition, under the Lanham Act (15 

U.S.C. § 1051 et. seq.).

2. This Court has subject matter jurisdiction over the claims in this action that relate 

to trademark infringement, counterfeiting, and false designation of origin and unfair competition 

pursuant to the provisions of 15 U.S.C. § 1121 and 28 U.S.C. §§ 1331 and 1338(a). 

Venue

3. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) in that the 

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Defendants reside in this district and the cause of action occurred in this district.

Parties

4. GS HOLISTIC, LLC is a Delaware Limited Liability Corporation that has its 

principal place of business at 7162 Beverly Boulevard, #207, Los Angeles, California 90036. GS 

is the registered owner of the “G PEN” trademarks. 

5. RR2K LLC d/b/a MEEN GREEN VAPOR SMOKE (hereinafter referred to as 

“MEEN GREEN”) is a limited liability company that was formed in Texas, and has its principal 

place of business at 1067 E McKinney St, #700, Denton, TX 76209. MEEN GREEN is a citizen 

of Texas. 

6. KAPIL BHANDARI is a resident of Euless, Texas, and is sui juris. KAPIL 

BHANDARI is a citizen of Texas. 

Facts Common to All Counts

The History of The G Pen Brand. 

7. Since 2012, GS has marketed and sold products using the trademark “G Pen.” The

G Pen branded products, such as portable vaporizers and accessories related thereto, are widely 

recognized nationally and internationally. Indeed, the G Pen brand is one of the leading companies 

in the industry, known for the high quality of the products at an achievable price point for all. 

8. GS is also known for its Charity Series whereby the company teams up with 

nonprofit organizations to donate net proceeds from each purchase to the organization. 

9. For nearly ten years, GS has worked to distinguish the G Pen brand as the premier 

manufacturer of vaporizers by emphasizing the brand’s unwavering use of quality materials and 

focusing on scientific principles which facilitate a superior smoking experience. G Pen branded

products embody a painstaking attention to detail, which is evident in many facets of authentic G 

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Pen branded products. It is precisely because of the unyielding quest for quality and unsurpassed 

innovation that G Pen branded products have a significant following and appreciation amongst 

consumers in the United States and internationally.

10. As a result of the continuous and extensive use of the trademark “G PEN,” Grenco 

Science was granted valid and subsisting federal statutory and common law rights to the G Pen

trademark. Grenco Science then assigned to GS all the rights associated with the G PEN trademark

and other marks associated with the different products sold by GS. The assignment to GS was 

duly recorded with the United States Patent and Trademark Office on May 24, 2016. 

11. GS is the owner of United States trademarks which are registered on the Principal 

Register and have become incontestable within the meaning of Section 15 of the Lanham Act, 15 

U.S.C. § 1065. The following is a list of GS’s federally registered trademarks:

a. U.S. Trademark Registration Number 4,390,645 for the standard character

mark “G Pen” in association with goods further identified in registration in international 

class 010.

b. U.S. Trademark Registration Number 5,368,594 for the word mark “G Pen” 

and its logo in association with goods further identified in the registration in international 

class 010.

c. U.S. Trademark Registration Number 4,462,090 for the standard character

mark “MicroG” in association with goods further identified in the registration in 

international class 010.

d. U.S. Trademark Registration Number 4,470,963 for the standard character

mark “Grenco Science” in association with goods further identified in the registration in 

international class 010.

e. U.S. Trademark Registration Number 4,616,071 for the standard character

mark “Grenco” in association with goods further identified in the registration in 

international class 010.

f. U.S. Trademark Registration Number 4,466,586 for the word mark “G” and 

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its logo in association with goods further identified in the registration in international class

010.

g. U.S. Trademark Registration Number 5,264,986 for the standard character

mark “G Pen Elite” in association with goods further identified in the registration in 

international class 034.

h. U.S. Trademark Registration Number 5,264,988 for the design plus words 

mark “G Pen Elite” and its logo in association with goods further identified in the 

registration in international class 034.

i. U.S. Trademark Registration Number 5,368,591 for the standard character

mark “G Slim” in association with goods further identified in the registration in 

international class 010.

j. U.S. Trademark Registration Number 5,368,593 for the word mark “G 

Slim” and its logo in association with goods further identified in the registration in 

international class 010.

k. U.S. Trademark Registration Number 5,363,580 for the word mark “GIO” 

and its logo in association with goods further identified in the registration in international 

class 010.

l. U.S. Trademark Registration Number 5,363,581 for the standard character

mark “GIO” in association with goods further identified in the registration in international 

class 010.

m. U.S. Trademark Registration Number 5,405,360 for the word mark “G 

Grenco Science” and its logo in association with goods further identified in the registration 

in international class 010.

n. U.S. Trademark Registration Number 5,405,361 for the word mark “G 

Grenco Science” and its logo in association with goods further identified in the registration 

in international class 010.

o. U.S. Trademark Registration Number 5,906,587 for the standard character

mark “G Pen Nova” in association with goods further identified in the registration in 

international class 010.

p. U.S. Trademark Registration Number 5,906,588 for the design plus words 

mark “G Pen Nova” and its logo in association with goods further identified in the 

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registration in international class 010.

q. U.S. Trademark Registration Number 6,032,396 for the standard character

mark “Roam” in association with goods further identified in the registration in international 

class 010.

r. U.S. Trademark Registration Number 6,032,397 for the design plus words 

mark “Roam” and its logo in association with goods further identified in the registration in 

international class 010.

s. U.S. Trademark Registration Number 6,202,143 for the standard character

mark “G Pen Dash” in association with goods further identified in the registration in 

international class 010.

t. U.S. Trademark Registration Number 6,202,144 for the design plus words 

mark “Dash” and its logo in association with goods further identified in the registration in 

international class 010. 

u. U.S. Trademark Registration Number 6,904,354 for the design plus words 

mark “M MICRO+” and its logo in association with goods further identified in the 

registration in international class 034. 

12. The above U.S. registrations are valid, subsisting and in full force and effect. 

The G Pen Brand in the United States. 

13. Pursuant to the trademark assignment between Grenco Science, Inc. and GS 

Holistic, LLC (hereinafter the “License Agreement”), GS has used the G Pen Marks in commerce 

throughout the United States continuously since 2016, in connection with the manufacturing of 

vaporizing products.

14. The G Pen Marks are distinctive to both the consuming public and the Plaintiff’s

trade. GS’s G Pen branded products are made from superior materials. The superiority of G Pen

branded products is not only readily apparent to consumers, but to industry professionals as well. 

15. Plaintiff’s Trademarks are exclusive to Plaintiff and appear clearly on Plaintiff’s 

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Products, as well as on the packaging and advertisements related to such products. Plaintiff has 

expended substantial time, money, and other resources in developing, advertising, and otherwise 

promoting and protecting Plaintiff’s Trademarks. As a result, products bearing Plaintiff’s 

Trademarks are widely recognized and exclusively associated by consumers, the public, and the 

trade as being high-quality products sourced from Plaintiff. Plaintiff’s Products have become some 

of the most popular of their kind in the world and have also been the subject of extensive 

unsolicited publicity resulting from their high-quality and innovative designs. Because of these 

and other factors, the GS brand and Plaintiff’s Trademarks are famous throughout the United 

States.

16. Since 2016, GS has worked to build significant goodwill in the G Pen brand in the 

United States. GS has spent substantial time, money, and effort in developing consumer 

recognition and awareness of the G Pen brand via point of purchase materials and displays, through 

their websites, by attending industry trade shows, and through social media promotion. 

17. In fact, Plaintiff’s Products have been praised and recognized by numerous online 

publications, as well as publications directed to the general public, including articles in NewsWeek, 

Complex, TechCrunch, NY Times, USA Today, LA Weekly, Fortune Magazine, and SFGate.

18. Due to the high quality of the brand and products, GS has collaborated with 

numerous celebrities and companies to create collaborations.

19. GS sells its products under the G Pen Marks to authorized stores in the United 

States, including in Texas. GS has approximately 6,000 authorized stores nationwide. As such, 

G Pen branded products reach a vast array of consumers throughout the country. 

20. It is because of the recognized quality and innovation associated with the G Pen

Marks that consumers are willing to pay higher prices for genuine G Pen branded products. For 

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example, a G Pen brand vaporizer ranges in price from $70 to $250, while a non-G Pen branded

product of equivalent size and technology will usually sell from $11 to $20. As such, sales of 

products bearing the G Pen Marks in the United States have been approximately twenty million 

dollars ($20,000,000) for the last five years. 

21. It is exactly because of their higher sales value that G Pen branded products are

targeted by counterfeiters. These unscrupulous people and entities tarnish the G Pen brand by 

unlawfully selling vaporizers that have identical, or nearly identical, versions of the G Pen Marks 

affixed to products that are made with inferior materials and technology, thereby leading to 

significant illegitimate profits by store owners, such as KAPIL BHANDARI.

22. In essence, KAPIL BHANDARI misleads consumers by selling them low grade 

products that free ride on the goodwill of the G Pen brand, and in turn, KAPIL BHANDARI reaps 

substantial ill-gotten profits. KAPIL BHANDARI’s conduct contributes to the complete flooding 

of the marketplace with counterfeit products, which results in lost sales and damages to GS and 

irreparable harm to the G Pen brand’s image. 

23. Unfortunately, the current U.S. marketplace is saturated with counterfeit products 

– like those KAPIL BHANDARI through his store, MEEN GREEN, has sold. As such, GS has

been forced to scrupulously enforce its rights in order to protect the G Pen Marks against 

infringement. By exercising its Enforcement Rights, GS has proactively and successfully policed 

the unauthorized use of the G Pen Marks and/or counterfeit G Pen branded products nationwide. 

GS has had to bear great expense to seek out and investigate suspected counterfeiters in their 

attempt to clean up the marketplace.

Defendants’ Offering for Sale Counterfeit Goods

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24. The Defendants have, and they continue to, offer for sale counterfeit G Pen products 

with the G Pen trademark and without the consent of GS. In fact, they offer counterfeit glass 

infusers bearing imitations of the G Pen Trademarks that were not made or authorized by GS. 

These are hereinafter the “Counterfeit Goods”.

25. Nevertheless, the Defendants have and continue to offer for sale in commerce the 

Counterfeit Goods, specifically, the Defendants offer for sale reproductions, counterfeits, copies 

and/or colorable imitations of one or more of the G Pen Marks (hereinafter the “Infringing 

Marks”), detailed below:

a. U.S. Trademark Registration Number 4,390,645 for the standard character

mark “G Pen” in association with goods further identified in registration in international 

class 010.

b. U.S. Trademark Registration Number 4,470,963 for the standard character

mark “Grenco Science” in association with goods further identified in the registration in 

international class 010.

c. U.S. Trademark Registration Number 4,616,071 for the standard character

mark “Grenco” in association with goods further identified in the registration in 

international class 010.

d. U.S. Trademark Registration Number 4,466,586 for the word mark “G” and 

its logo in association with goods further identified in the registration in international class

010.

26. The Defendants have, without the consent of GS, continued to offer for sale in their 

store, the Counterfeit Goods bearing the Infringing Marks, bearing the likeness of the G Pen 

Trademarks in the United States. 

27. The marks affixed to the Counterfeit Goods that the Defendants have offered for 

sale are spurious marks which are identical with, or substantially indistinguishable from, the G Pen

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Trademarks. The marks on the Counterfeit Goods are in fact counterfeit marks as defined in 15 

U.S.C. § 1116(d).

28. In the ongoing investigation into the sales of counterfeit products bearing the G Pen 

Marks, MEEN GREEN offered for sale Counterfeit Goods. 

29. Specifically, on February 9, 2023, GS’s investigator attended MEEN GREEN’s 

location, which was open to the public, and observed that it had an excess of vaporizers which 

displayed the G Pen Trademarks. The investigator purchased a Snoop Dogg Vaporizer with a G 

Pen Mark affixed to it, from MEEN GREEN, for a cost of $43.29, charged to the account of GS’s

investigator, and it was a Counterfeit product in that it displayed the Infringing Marks.

30. KAPIL BHANDARI authorized, directed, and/or participated in MEEN GREEN’s 

offer for sale, in commerce, of the Counterfeit Goods. KAPIL BHANDARI’s acts were a moving, 

active, and/or conscious force behind MEEN GREEN’s infringement of the G Pen Trademarks. 

31. The Defendants’ use of the counterfeit G Pen Trademarks began long after the 

registration of the G Pen Trademarks. GS nor any of its authorized agents have consented to the 

Defendants’ use of the G Pen Trademarks, or any use of reproductions, counterfeits, copies and/or 

colorable imitations thereof. 

32. The unauthorized offering for sale by MEEN GREEN, under the authority, 

direction and/or participation of KAPIL BHANDARI, of the Counterfeit Good(s) was an unlawful 

act in violation of the Lanham Act. 

33. The offer for sale by the Defendants of the Counterfeit Good(s) bearing GS’s 

Trademarks has caused GS to suffer losses and has caused damage to the goodwill and reputation 

associated with the G Pen Trademarks, which are owned by GS.

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34. MEEN GREEN’s use of the G Pen Marks includes displaying to offer for sale

unauthorized copies of Counterfeit G Pen branded products. MEEN GREEN’s offering to sell the 

G Pen counterfeit products, bearing the Infringing Marks in this manner, was, and is, likely to 

cause confusion or to cause mistake and/or deceive consumers who purchase the Counterfeit 

Goods

35. MEEN GREEN used images and names identical to or confusingly similar to the 

G Pen Marks, to confuse customers and aid in the promotion and sales of Counterfeit Goods under 

the Infringing Mark. 

36. The Infringing Mark affixed to the Counterfeit Goods that MEEN GREEN has 

manufactured, distributed, provided, marketed, advertised, promoted, offered for sale, and/or sold,

is confusingly identical or similar to the G Pen Marks that GS affixes to its vaporizers.

37. The vaporizers MEEN GREEN sells and offers for sale under the Infringing Mark 

are made of substantially inferior materials and inferior technology as compared to genuine G Pen

brand products. 

38. MEEN GREEN has distributed, provided, marketed, advertised, promoted, offered 

for sale, and sold its vaporizers under the Infringing Mark through its retail convenience store. 

39. MEEN GREEN has marketed, advertised, and promoted its Counterfeit Goods

under the Infringing Mark through point of purchase displays, and/or its website, and/or via social 

media promotion. 

40. MEEN GREEN and KAPIL BHANDARI’s infringing acts as alleged herein have 

caused and are likely to cause confusion, mistake, and deception among the relevant consuming 

public as to the source or origin of the Counterfeit Goods sold by MEEN GREEN, and are likely 

to deceive, and have deceived, the relevant consuming public into mistakenly believing that the 

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Counterfeit Goods sold by MEEN GREEN originate from, are associated or affiliated with, or 

otherwise authorized by GS.

41. MEEN GREEN and KAPIL BHANDARI’s acts are willful with the deliberate 

intent to trade on the goodwill of the G Pen Marks, cause confusion and deception in the 

marketplace, and divert potential sales of GS’s vaporizers to MEEN GREEN.

42. MEEN GREEN and KAPIL BHANDARI’s acts are causing and, unless restrained, 

will continue to cause damage and immediate irreparable harm to GS, the G Pen Marks, and to its 

valuable reputation and goodwill with the consuming public for which GS has no adequate remedy 

at law.

43. As a proximate result of the unfair advantage accruing to KAPIL BHANDARI and

MEEN GREEN’s business from deceptively trading on GS’s advertising, sales, and consumer 

recognition, KAPIL BHANDARI and MEEN GREEN have made and will continue to make 

substantial profits and gains to which they are not in law or equity entitled. 

44. The injuries and damages sustained by GS has been directly and proximately 

caused by MEEN GREEN’s wrongful advertisement, promotion, distribution, sale and offers for 

sale of their goods bearing infringements or counterfeits of the G Pen Marks. 

45. Through such business activities, KAPIL BHANDARI and MEEN GREEN

purposefully derived direct benefits from their interstate commerce activities by targeting 

foreseeable purchasers in the State of Texas, and in doing so, have knowingly harmed GS. 

46. Furthermore, the sale and distribution of Counterfeit Goods by MEEN GREEN has 

infringed upon the above-identified federally registered trademarks. 

47. The spurious marks or designations used by MEEN GREEN in interstate commerce 

are identical with, or substantially indistinguishable from, the G Pen Marks on goods covered by 

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the G Pen Marks. Such use therefore creates a false affiliation between MEEN GREEN, GS, and 

the G Pen Marks. 

48. Due to the actions of MEEN GREEN, GS has been forced to retain the undersigned 

counsel and pay the costs of bringing an action forward. KAPIL BHANDARI and MEEN GREEN

should be responsible for paying GS’s reasonable costs of the action. 

49. KAPIL BHANDARI and MEEN GREEN’s acts have damaged, and will continue 

to damage GS, and GS has no adequate remedy at law. 

50. Moreover, MEEN GREEN’s and KAPIL BHANDARI’s wrongful acts will 

continue unless enjoined by the Court. Accordingly, KAPIL BHANDARI and MEEN GREEN

must be restrained and enjoined from any further counterfeiting or infringement of the G Pen

Marks.

Count One

Federal Trademark Counterfeiting and Infringement, 15 U.S.C. § 1114

51. The Plaintiff avers Paragraphs 1 through 50, which are stated above and incorporate 

the allegations therein, as though they are fully restated and incorporated in this Count by 

reference.

52. GS owns the federally registered G Pen Trademarks, as set forth in more detail in 

the foregoing paragraphs. 

53. The Defendants, without authorization from GS, have used in commerce spurious 

designations that are identical with, or substantially indistinguishable from, the G Pen Trademarks 

on the same goods covered by the G Pen Trademarks. 

54. The Defendants’ unauthorized use of counterfeit marks of the registered G Pen

Trademarks on and in connection with the Defendants’ offer(s) for sale in commerce is likely to 

cause confusion or mistake in the minds of the public.

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55. The Defendants’ conduct as alleged herein is willful and intended to cause 

confusion, mistake, or deception as to the affiliation, connection, or association of the Defendants, 

with GS or the G Pen Trademarks. 

56. The Defendants’ acts constitute willful trademark infringement in violation of 

Section 32 of the Lanham Act, 15 U.S.C. § 1114. 

57. The Defendants’ actions constitute the use by the Defendants of one or more 

“counterfeit mark(s)” as defined in 15 U.S.C. § 1116(d)(1)(B). 

58. The Defendants’ use in commerce of the counterfeit G Pen Trademarks has resulted 

in lost profits and business to GS which are difficult to determine, caused considerable damage to 

the goodwill of the G Pen Trademarks, and diminished the brand recognition of the G Pen

Trademarks by introducing counterfeit products into the marketplace.

59. By reason of the foregoing, the Plaintiff is entitled to, among other relief, injunctive 

relief, an award of statutory damages, and costs of the action under Sections 34 and 35 of the 

Lanham Act, 15 U.S.C. §§ 1116, 1117, together with prejudgment and post-judgment interest. 

WHEREFORE, the Plaintiff, GS HOLISTIC, LLC, respectfully requests that this Court 

find in favor of the Plaintiff and against the Defendant jointly and severally for OWNER, and other 

officers, and directors, for the knowing participation in the counterfeiting activities of 

TAXPAYER NAME, awarding the Plaintiff statutory damages pursuant to 15 U.S.C. § 1117, 

treble damages pursuant to 15 U.S.C. § 1117(b), the costs of suit, and any further relief that this 

Court may deem just and proper.

Count Two

Federal False Designation of Origin and Unfair Competition, 15 U.S.C. § 1125(a)

60. The Plaintiff avers Paragraphs 1 through 50, which are stated above and incorporate 

the allegations therein, as though they are fully restated and incorporated in this Count by 

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reference.

61. GS owns the federally registered G Pen Trademarks, as set forth in more detail in 

the foregoing paragraphs. 

62. The Defendants, without authorization from GS, have used in commerce spurious 

designations that are identical with, or substantially indistinguishable from, the G Pen Trademarks 

on the same goods covered by the G Pen Trademarks. 

63. The Defendants’ unauthorized use of counterfeit marks of the registered G Pen

Trademarks on and in connection with the Defendants’ offers for sale in commerce is likely to 

cause confusion or mistake in the minds of the public.

64. The Defendants’ unauthorized use in commerce of the G Pen Trademarks as alleged 

herein constitutes use of a false designation of origin and misleading description and representation 

of fact in violation of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a).

65. The Defendants’ conduct as alleged herein is willful and is intended to, and is likely 

to, cause confusion, mistake, or deception as to the affiliation, connection, or association of the 

Defendants, with GS or the G Pen Trademarks. 

66. The Defendants’ conduct as alleged herein is causing immediate and irreparable 

harm and injury to GS, and to the goodwill and reputation of the G Pen Trademarks and will 

continue to both damage GS and confuse the public unless enjoined by this Court. GS has no 

adequate remedy at law.

67. By reason of the foregoing, the Plaintiff is entitled to, among other relief, injunctive 

relief, an award of statutory damages, and costs of the action under Sections 34 and 35 of the 

Lanham Act, 15 U.S.C. §§ 1116, 1117, together with prejudgment and post-judgment interest.

WHEREFORE, the Plaintiff, GS HOLISTIC, LLC, respectfully requests that this Court 

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find in favor of the Plaintiff and against the Defendant jointly and severally for OWNER, and other 

officers, and directors, for the knowing participation in the counterfeiting activities of 

TAXPAYER NAME, awarding the Plaintiff statutory damages pursuant to 15 U.S.C. § 1117, 

treble damages pursuant to 15 U.S.C. § 1117(b), the costs of suit, and any further relief that this 

Court may deem just and proper.

PRAYER FOR RELIEF

WHEREFORE, the Plaintiff, GS HOLISTIC, LLC, respectfully requests the following 

relief against the Defendants, as follows:

1. With regard to Plaintiff’s Count I for trademark infringement:

a. Actual damages or statutory damages under 15 U.S.C. § 1117;

b. Treble damages under 15 U.S.C. § 1117(b); 

c. Costs of suit; and

d. Joint and several liability for KAPIL BHANDARI, and other officers, and 

directors, for the knowing participation in the counterfeiting activities of RR2K 

LLC. 

2. With regard to Plaintiff’s Count II for false designation and unfair competition:

a. Actual damages or statutory damages under 15 U.S.C. § 1117;

b. Treble damages under 15 U.S.C. § 1117(b); 

c. Costs of suit; and

d. Joint and several liability for KAPIL BHANDARI, and other officers, and 

directors, for the knowing participation in the counterfeiting activities of RR2K 

LLC.

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3. Preliminarily and permanently enjoining RR2K LLC and its agents, employees, 

officers, directors, owners, representatives, successor companies, related companies, and all 

persons acting in concert or participation with it from:

a. The import, export, making, manufacture, reproduction, assembly, use, 

acquisition, purchase, offer, sale, transfer, brokerage, consignment, 

distribution, storage, shipment licensing, development, display, delivery, 

marketing, advertising or promotion of the counterfeit G Pen product identified 

in the Complaint and any other unauthorized G Pen product, counterfeit, copy 

or colorful imitation thereof;

4. Pursuant to 15 U.S.C. § 1116(a), directing RR2K LLC to file with the Court and 

serve on the Plaintiff’s within thirty (30) days after issuance of an injunction, a report in writing 

and under oath setting forth in detail the manner and form in which RR2K LLC has complied with 

the injunction;

5. For an order from the Court requiring that the Defendants provide complete 

accountings and for equitable relief, including that the Defendants disgorge and return or pay their 

ill-gotten gains obtained from the illegal transactions entered into and/or pay restitution, including 

the amount of monies that should have been paid if the Defendants had complied with their legal 

obligations, or as equity requires;

6. For an order from the Court that an asset freeze or constructive trust be imposed on 

all monies and profits in the RR2K LLC’s possession, which rightfully belong to the Plaintiff;

7. Pursuant to 15 U.S.C. § 1118 requiring that the Defendants and all others acting 

under the Defendants’ authority, at its cost, be required to deliver up to the Plaintiff for destruction 

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all products, accessories, labels, signs, prints, packages, wrappers, receptacles, advertisements, and 

other material in their possession, custody or control bearing any of the G Pen Trademarks;

8. For such other and further relief as the Court may deem just and equitable.

Date: March 27, 2023

Respectfully submitted,

/s/ Sanjay K. Minocha

Sanjay K. Minocha

Texas Bar # 24065763

Minocha Law Firm PLLC

3300 Oak Lawn Avenue

Suite 700

Dallas, Texas 75219

Serv604@LegalBrains.com

Telephone: 561-232-2222

Attorney for the Plaintiff

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