JS-6

2 3 4 5 6 UNITED STATES DISTRICT COURT

7 CENTRAL DISTRICT OF CALIFORNIA

8 MAGNOLIA PEARL, LLC, a Texas) CASE NO.: 8:25-cv-01565-DOC-DFM 9 || limited liability company, 10 Plaintiff, PROPOSED} CONSENT

JUDGMENT

11 v. 12 | HONEY MANCHANDA, an individual; KHUSHI MANCHANDA, an individual; 13 || PANKAJ MANCHANDA, an individual; RIYA MANCHANDA, an individual; and 14 || DOES 1-10, inclusive, 15 Defendants. 16 17 18 =PROPOSEDTGONSENT JUDGMENT 19 This Matter is before the Court on the joint motion of Plaintiff Magnolia Pearl, 20 || LLC (“Magnolia Pearl” or “Plaintiff’) and Defendant Honey Manchanda. 21 WHEREAS, this Consent Judgment as to Honey Manchanda concerns the 22 ||claims between Magnolia Pearl and Honey Manchanda in this Civil Action No. 23 || 8:25-cv-01565-DOC-DFM (the “Litigation’). 24 WHEREAS, Defendant Honey Manchanda represents to the Court that 25 ||Defendants Khushi Manchanda, Pankaj Manchanda, and Riya Manchanda were not 26 || involved in the conduct alleged in the Complaint (Dkt. 1), and on that basis all claims 27 ||against Khushi Manchanda, Pankaj Manchanda, and Riya Manchanda shall be 28 || dismissed with prejudice with respect to all acts that occurred prior to today. ]

1 WHEREAS, Magnolia Pearl represents that it owns the MAGNOLIA PEARL 2 || trademarks with Reg Nos. 4178784, 5642383, and 5246047. 3 WHEREAS, Magnolia Pearl alleged in the Litigation that Honey Manchanda 4 ||infringed its trademarks among other allegations through the importation o 5 unauthorized Magnolia Pearl-branded goods; 6 WHEREAS, Honey Manchanda admits she imported and sold products bearing 7 |}one or more of the MAGNOLIA PEARL Marks without authorization, and agrees that 8 || the MAGNOLIA PEARL Marks are valid and enforceable; 9 WHEREAS, Honey Manchanda admits that she alone was responsible for the 10 |icomplained of acts in Plaintiff's Complaint (Dkt. 1), and not the other Defendants 11 || Khushi Manchanda, Pankaj Manchanda, and Riya Manchanda; 12 WHEREAS, Honey Manchanda admits that Magnolia Pearl would be 13 ||irreparably harmed if Honey Manchanda was not enjoined from infringing or 14 || otherwise misusing the MAGNOLIA PEARL Marks; 15 WHEREAS, Magnolia Pearl requested that this Court enter a permanent 16 |/injunction enjoining Honey Manchanda from infringing or otherwise misusing the 17 ||] MAGNOLIA PEARL Marks; 18 WHEREAS, Magnolia Pearl and Honey Manchanda have reached an agreement 19 finally settle the Litigation, with the monetary terms to be kept confidential; 20 WHEREAS, Magnolia Pearl and Honey Manchanda request that the Court have 21 || the authority to enforce the terms of their settlement as an Order of the Court; 22 WHEREAS, Magnolia Pearl and Honey Manchanda consent to personal 23 || jurisdiction in California for purposes of enforcing the settlement; 24 IT IS HEREBY ORDERED, DECREED, and ADJUDGED as follows: 25 1. Magnolia Pearl and Honey Manchanda hereby agree that this case has been 26 settled as between them, and that all issues and controversies between them 27 have been resolved to their mutual satisfaction. Magnolia Pearl and Honey 28 Manchanda request the Court to retain jurisdiction to enforce the terms o

1 their settlement under the authority of Kokkonen v. Guardian Life Ins. Co. o 2 Am., 511 U.S. 375, 381-82 (1994). 3 2. The Court has jurisdiction over Magnolia Pearl, LLC and Honey Manchanda, 4 as well as the subject matter of this Litigation. 5 3. Honey Manchanda acknowledges that the MAGNOLIA PEARL Marks are 6 valid and enforceable. 7 4. While Honey Manchanda initially believed that she could sell the accused 8 Magnolia Pearl-branded products lawfully, she now acknowledges that her 9 importing, advertising, offering to sell, and selling of the products accused o 10 infringement in the Litigation violated Magnolia Pearl’s exclusive rights as 11 the trademark owner. 12 5. Honey Manchanda states that she has no knowledge beyond the information 13 she has already provided to Magnolia Pearl and cannot verify the origin o 14 goods prior to her handling. 15 6. Honey Manchanda represents that she has provided information responsive 16 to the Plaintiff's requests to the best of her ability and based on the records 17 available to her. 18 7. The parties shall comply with the settlement, including that: 19 a. Honey Manchanda shall permanently cease importing, offering for sale, 20 or selling any products bearing the MAGNOLIA PEARL Marks or any 21 marks/designs confusingly similar thereto; 22 b. Honey Manchanda shall permanently refrain from using “Magnolia Pearl” 23 or any confusingly similar designation in any titles, descriptions, hashtags, 24 alt-text, metadata, or keywords on any online or physical sales channel; 25 c. Honey Manchanda shall, within 30 days, to the best of her ability delete 26 or remove all ended or sold listings, pages, and images referencing 27 Magnolia Pearl products from any platform under their control, and 28 request removal or suppression from platform operators where deletion is

] unavailable; 2 d. Honey Manchanda shall comply with supplier contact duties, which 3 requires her to contact her supplier to inquire about upstream suppliers o 4 the accused products; 5 e. Honey Manchanda shall produce purchaser information for the accused 6 products to the extent that the information can be retrieved; 7 f. Honey Manchanda shall sign an affidavit under oath stating who she 8 purchased the accused products from, the dates of purchase, the location 9 of purchase, any contact information she has for the seller, and a listing o 10 the items purchased. 11 8. The parties shall maintain the confidentiality of the settlement amount, which 12 shall be provided confidentially to the Court, and the Court has the authority 13 to enforce payment of the settlement amount according to the terms agreed to 14 by the parties. 15 9. The parties expressly waive their rights under Federal Rule of Civil 16 Procedure 65(d) to the extent Rule 65(d) requires this order to be specific in 17 terms or to describe in reasonable detail the act or acts to be restrained. 18 10.By consent of the parties, the Court shall retain jurisdiction for the purposes 19 of enforcing the terms of this Consent Judgment and the settlement. 20 11.Except as necessary to enforce the terms of this Consent Judgment and the 21 settlement, this case as between Magnolia Pearl and Defendants Honey 22 Manchanda, Khushi Manchanda, Pankaj Manchanda, and Riya Manchanda is 23 hereby dismissed with prejudice. Each of those parties shall bear its own 24 costs and attorneys’ fees. 25 26 27 28 4A

DATED: December 8, 2025 _ By: ANheaHl (ude 2 Hon. David O. Carter 3 Contral District of Cal fornia 4 5 6 7 Ad: 5 10 Josh Sebaye Riley Lasdee™ LL

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14 HONEY MANCIANDA 15 16 17 18 19 20 21 22 23 24 25 26 27 28 .