Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 1 of 14

1 KELLEY DRYE & WARREN LLP

Michael J. Zinna (admission pending)
2 [email protected]
Tiffany Arosemena (admission pending)
3 [email protected]
101 Park Avenue
4 New York, New York 10178
Telephone: (212) 808-7800
5
LANG & KLAIN, P.C.
6 6730 N. SCOTTSDALE RD., SUITE 101
SCOTTSDALE, ARIZONA 85253
TELEPHONE (480) 534-4900
7 Please e-serve filings on:
8 [email protected]

9 WILLIAM G. KLAIN, #015851

[email protected] (not for e-service)
10 GEORGE H. KING, #013287
[email protected] (not for e-service)
11 Attorneys for Plaintiff
12
13 UNITED STATES DISTRICT COURT

14 DISTRICT OF ARIZONA

15 Pso-Rite.com LLC, Case No.:

16 Plaintiff, COMPLAINT

17 v.

18 Exerscribe, Inc.,

19 Defendant.

20 Plaintiff, Pso-Rite.com LLC (“Pso-Rite” or “Plaintiff”), for its Complaint against

21 Defendant Exerscribe, Inc. (“Exerscribe” or “Defendant”), hereby alleges as follows:
22 NATURE OF THE ACTION
23 1. This is a civil action arising under the patent and trademark laws of the United
24 States, under 28 U.S.C. § 100, et seq., and 35 U.S.C. § 100, et seq., and state laws prohibiting
25 trademark infringement and unfair competition, all arising from Exerscribe’s manufacture, use,
26 offer to sell, sale and/or importing into the United States its Hip-Hero massager product (“Hip-
27 Hero” or “Infringing Product”).
28
 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 2 of 14

1 THE PARTIES
2 2. Plaintiff Pso-Rite.com LLC is a Delaware limited liability company having its
3 principal place of business at 1815 Purdy Avenue, Miami Beach, Florida 33139.
4 3. Upon information and belief, Defendant Exerscribe is an Arizona corporation with
5 a principal place of business at 9939 E. Acacia Dr., Scottsdale, Arizona 85260.
6 JURISDICTION AND VENUE
7 4. This Court has subject matter jurisdiction, inter alia, pursuant to 28 U.S.C. §§ 1331
8 and 1338(a) because this is an action arising under the patent and trademark laws of the United
9 States, 28 U.S.C. § 100, et seq., and 35 U.S.C. § 100, et seq.
10 5. This Court has personal jurisdiction over the Defendant because (a) upon
11 information and belief, Exerscribe is an Arizona corporation transacting business in Arizona
12 through the sale of products into Arizona, and (b) because Exerscribe has committed, and
13 continues to commit, tortious acts within the state of Arizona giving rise to this action.
14 6. Venue is proper under 28 U.S.C. §§ 1391(b) and/or 1400(b) because Exerscribe is
15 subject to personal jurisdiction in this district, and Exerscribe has committed infringing acts
16 including acts of patent infringement in this district.
17 THE PATENT-IN-SUIT
18 7. On July 17, 2018, United States Design Patent No. 823,479 (“the ‘479 Patent”),
19 entitled “Massager,” was duly and legally issued by the U.S. Patent and Trademark Office
20 (“USPTO”). A true and correct copy of the ‘479 Patent is attached as Exhibit A. The ‘479 Patent
21 is valid, enforceable and currently in full force and effect.
22 8. Plaintiff is the owner and assignee of all substantial rights, title, and interest in the
23 ‘479 Patent, including the right to bring this action and enforce the ‘479 Patent against infringers,
24 and to collect damages for all relevant time periods.
25 THE TRADEMARK-IN-SUIT
26 9. Plaintiff owns seven U.S. trademark registrations for use in connection with its
27 products. These include U.S. Reg. No. 5,553,179 (“the ‘179 Registration”) which covers the 2-D
28

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 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 3 of 14

1 silhouette of the Pso-Rite® (the “Silhouette Mark”) for use in connection with massage
2 apparatuses for personal use, as shown below.
3
4
5
6
 
7
8 FACTUAL BACKGROUND

9 10. Founded in 2016, Plaintiff Pso-Rite.com LLC is an innovator in the area of personal

10 massage devices. Plaintiff makes, sells, and promotes its massage devices in the U.S. and in

11 several foreign countries. The designs of Plaintiff’s massagers are covered by a total of seven

12 patents in the U.S. and abroad, as well as several other patent applications that are currently

13 pending.

14 11. The ‘479 Patent covers the standard-size of Plaintiff’s first massage product, called

15 a Pso-Rite® a smaller version of the product called a Pso-Mini®, and the smallest version of the

16 product that can be attached to a key chain, called the Pso-Key®. The products are marketed and

17 sold throughout the United States and internationally through the company’s website, www.pso-

18 rite.com, and through third party resellers such as Amazon.com. The Pso-Rite®, Pso-Mini® and

19 Pso-Key® are marked with the ‘479 Patent.

20 12. Plaintiff’s products have been featured on the Joe Rogan Experience and used by

21 renowned athletes in the fields of mixed martial arts, dance and Jiu Jitsu, among others.

22 13. Defendant offers for sale a personal massage device under the name “Hip-Hero”

23 through the website www.hip-hero.com (see Exhibit B), which upon information and belief is

24 owned and operated by Defendant, and through third party retailers not owned and operated by

25 Defendant - on which Plaintiff’s products are also sold - such as www.amazon.com (see Exhibit

26 C).

27 14. Upon information and belief, Defendant began selling the Infringing Product on or

28 about January 14, 2020, at least through www.amazon.com.

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1 15. Upon information and belief, Defendant also attempts to obtain sales of its product
2 on Amazon’s website by associating the Infringing Product with “key words” that a purchaser
3 might use when it is looking for a Pso-Rite® massage product, such as “pso rite.” The intention
4 would be that, when a potential purchase types “pso rite” into the search bar on Amazon, the
5 returned search results would include not just Plaintiff’s products, but the Infringing Product.
6 16. A side-by side comparison reveals that Defendant’s Infringing Product is
7 substantially similar to and has misappropriated the design covered by the ‘479 Patent.
8
The ‘479 Patent Exerscribe’s Hip-Hero
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The ‘479 Patent Exerscribe’s Hip-Hero

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23 17. The Infringing Product is also approximately the same size as the Pso-Rite®. The
24 Pso-Rite® is 5 inches wide; upon information and belief, the Infringing Product is 5.24 inches
25 wide. The Pso-Rite® is 5.3 inches high at its peak; upon information and belief, the Infringing
26 Product is 5.79 inches high at its peak. The space between the peaks of the Pso-Rite® at their
27 highest point is 5.5 inches; upon information and belief, the Infringing Product can be adjusted so
28 that the space between its peaks at the highest point is 5.2 inches or 5.6 inches. The Pso-Rite® is
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1 10.7 inches in length; upon information and belief, the Infringing Product is 16.69 inches in length,
2 only to account for the adjustability of the peaks of the Infringing Product.
3 18. The Infringing Product is also offered in at least one of the same colors as the Pso-
4 Rite® and the Pso-Mini®, a bright red. Despite the myriad of colors Defendant could have chosen
5 for its product, it chose one of the five colors Plaintiff uses for its massage products in an attempt
6 to more easily call to mind Pso-Rite® products in the minds of consumers when they see the
7 Infringing Product.
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19. Defendant is also trying to gain sales from creating a false association with Pso-
18
Rite® in more surreptitious ways. In fact, a comparison of the Pso-Rite® website and Defendant’s
19
website reveals that Defendant copied exact verbiage from the Pso-Rite® website when
20
describing its Infringing Product.
21
20. The “FAQs” section of the Pso-Rite® website describes the Pso-Rite® as a patented
22
design that “mimics the hand and elbow of a massage therapist” which makes the product “way
23
more effective for pressing deep into muscles than any other massage tool”. Similar verbiage and
24
the comparison to the hands and elbows of a massage therapist is repeated throughout the Pso-
25
Rite® website, including on the homepage and the Pso-Rite® “How To Manual.”
26
21. In an attempt to mislead consumers into assuming a connection between the
27
Infringing Product and Pso-Rite®, Defendant also specifically chooses to compare its Infringing
28
Product to a “massage therapist” and goes further by adding that its Infringing Product “simulates
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 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 7 of 14

1 the hand or elbow of an expert massage therapist” which is the exact same comparison featured
2 on the Pso-Rite® website.
3 22. There are other ways for Defendant to describe the effects of its product without
4 plagiarizing language from the Pso-Rite® website. Defendant is calculatedly making these
5 marketing choices to create a false association with, and call to mind, Pso-Rite® and its products.
6 23. There are numerous ways to design a device that is meant to release/massage the
7 psoas and other muscles without misappropriating Plaintiff’s patented design. The following are
8 examples of products offered for sale on www.amazon.com that purport to serve these purposes,
9 and they do not infringe the ‘479 Patent (Exhibit D):
10
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23 24. Aside from patenting its innovative massager designs, Plaintiff has also spent
24 substantial time, money and effort in promoting its brand using its Silhouette Mark in connection
25 with massage apparatuses for personal use.
26 25. As a result of Plaintiff’s efforts, the consuming public has become familiar with and
27 identifies the innovative shape of the Pso-Rite® and its Silhouette Mark as being associated with
28 Plaintiff and its massage apparatuses. The consuming public understands and expects that the

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 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 8 of 14

1 massage apparatuses in the design covered by the ‘479 Patent and shape shown in the Silhouette
2 Mark as affiliated or associated with Plaintiff.
3 26. Plaintiff is and will continue to be damaged by the continued use by Defendant of
4 photos and other graphics used in Defendant’s marketing of the Infringing Product that are
5 substantially similar to and likely to be confused with the Silhouette Mark:
6
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16 27. There are other ways for Defendant to photograph and show its product without

17 calling to mind the Silhouette Mark. Again, Defendant is calculatedly making these marketing

18 choices to create a false association with, and call to mind, Plaintiff and its products.

19 28. Plaintiff sent Defendant a letter on September 10, 2020 asking Defendant to cease

20 and desist from its infringing behavior and putting Defendant on notice of the ‘479 Patent and the

21 ‘179 Registration (attached as Exhibit E).

22 CLAIMS FOR RELIEF

23 FIRST CLAIM FOR RELIEF

(INFRINGEMENT OF THE ‘479 PATENT)
24
29. Plaintiff hereby incorporates by reference paragraphs 1-28 as if fully set forth
25
herein.
26
30. In the eye of the ordinary observer familiar with the relevant prior art, giving such
27
attention as a purchaser usually gives, the claimed design of the ‘479 Patent and the design of the
28

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 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 9 of 14

1 Infringing Product are substantially the same, such that the ordinary observer would be deceived
2 into believing that the Infringing Product is the design claimed in the ‘479 Patent, and would be
3 induced into purchasing one supposing it to be the other.
4 31. Plaintiff did not give Defendant a license or other authorization to make, use, offer
5 to sell, sell or import the Infringing Product into the United States.
6 32. Defendant has directly infringed, and continues to directly infringe, the ‘479 Patent
7 by making, using, offering to sell and/or selling the Infringing Product in violation of 35 U.S.C.
8 §§ 271(a) and 289.
9 33. Upon information and belief, Defendant also induced, and continues to induce,
10 others to infringe the ‘479 patent by encouraging and promoting the use and/or sale by others of
11 the Infringing Product in violation of 35 U.S.C. § 271(b).
12 34. Upon information and belief, Defendant has had actual knowledge of the ‘479
13 Patent since at least September 10, 2020.
14 35. Upon information and belief, Defendant knew or should have known that the
15 making, using, offering to sell, and selling of the Infringing Products would directly infringe the
16 ‘479 Patent.
17 36. Defendant’s direct and indirect infringement of the ‘479 Patent has caused and will
18 continue to cause damage to Plaintiff.
19 37. Defendant’s direct and induced infringement has also caused and will continue to
20 cause irreparable harm to Plaintiff unless and until such infringing conduct is enjoined pursuant
21 to 35 U.S.C. § 283 and/or the equitable powers of this Court.
22 38. Upon information and belief, Defendant’s acts of infringement have been
23 undertaken with knowledge of the ‘479 Patent. Therefore, such acts constitute willful
24 infringement and make this case exceptional pursuant to 35 U.S.C. §§ 284 and 285, and entitle
25 Plaintiff to enhanced damages and reasonable attorney fees.
26
27
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 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 10 of 14

SECOND CLAIM FOR RELIEF

1 (UNFAIR COMPETITION UNDER ARIZONA LAW)
2 39. Plaintiff hereby incorporates by reference paragraphs 1-38 as if fully set forth
3 herein.
4 40. Plaintiff has substantial protectable rights in the ‘479 Patent, its Silhouette Mark,
5 and it has established substantial goodwill in its business, its products and its branding.
6 41. Defendants actions, including but not limited to Defendant’s misappropriating
7 Plaintiff’s patented product design and Silhouette Mark, both of which were intended to create
8 and do actually create the false impression that Plaintiff approves of, endorses or is otherwise
9 associated with Defendant and its products, constitutes unfair competition under the common law
10 of Arizona and elsewhere.
11 THIRD CLAIM FOR RELIEF
(FEDERAL TRADEMARK INFRINGEMENT)
12
42. Plaintiff hereby incorporates by reference paragraphs 1-41 as if fully set forth
13
herein.
14
43. The unauthorized use by Defendant of the Silhouette Mark is likely to cause
15
confusion, mistake, or deception about the origin of Defendant’s goods, and therefore infringes
16
Plaintiff’s trademark rights in its federally-registered Silhouette Mark under 15 U.S.C. § 1114 and
17
constitutes inducing the infringement by others.
18
44. Upon information and belief, Defendant’s use of the shape of the Pso-Rite® and
19
photographic choices to show the Infringing Product at an angle that makes it appear substantially
20
similar to the Silhouette Mark is part of a deliberate plan to trade on the valuable goodwill Plaintiff
21
has established in its mark.
22
45. Upon information and belief, with knowledge of Plaintiff’s ownership of its
23
federally-registered mark and the deliberate intention to unfairly benefit from the goodwill
24
generated thereby, the actions of Defendant has been carried out in willful disregard of Plaintiff’s
25
rights, in violation of 15 U.S.C. § 1114.
26
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 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 11 of 14

FOURTH CLAIM FOR RELIEF

1 (UNFAIR COMPETITION AND FALSE DESIGNATION OF ORIGIN
UNDER 15 U.S.C. § 1125(A))
2
46. Plaintiff hereby incorporates by reference paragraphs 1-45 as if fully set forth
3
herein.
4
47. Plaintiff’s claim arises under Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a),
5
for unfair competition, false designation of origin and false descriptions and representations in
6
interstate commerce
7
48. Plaintiff has substantial protectable rights in the ‘479 Patent, and its Silhouette
8
Mark, and it has established substantial goodwill in its business, its products and its branding.
9
49. Through Plaintiff’s extensive advertising and promotional activities, Plaintiff has
10
established extensive goodwill in design of the ‘479 Patent and the Silhouette Mark and they are
11
uniquely associated with Plaintiff in the minds of the general public.
12
50. Defendants have used the ‘479 Patent, and the Silhouette Mark on and/or in
13
connection with online stores and the sale and offering to sell the Infringing Product.
14
51. As the infringing conduct was conducted over the Internet, through some of the
15
same sales channels used by Plaintiff to sell its products, Defendants sale of, and offering to sell,
16
the Infringing Product is targeted to the same consumers as Plaintiff through the same sales
17
channels as Plaintiff.
18
52. Upon information and belief, Defendant’s sales, and offers to sell, merchandise
19
online using the design covered by the ‘479 Patent, and the Silhouette Mark and other indicia
20
associated with Plaintiff’s website enables Defendants to benefit unfairly from Plaintiff’s
21
reputation and success, thereby giving Defendant’s products commercial value they would not
22
otherwise enjoy.
23
53. Upon information and belief, prior to Defendant’s infringing use of the design
24
covered by the ‘479 Patent and the Silhouette Mark, Defendants were aware of Plaintiff’s
25
business, the ‘479 Patent and the Silhouette Mark as a result of the popularity of Plaintiff’s
26
advertising and Plaintiff’s sales of its products through www.amazon.com in the United States.
27
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 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 12 of 14

1 Accordingly, Defendants use of the design covered by the ‘479 Patent and the Silhouette Mark
2 was intentional, willful and without regard to Plaintiff’s rights.
3 54. Upon information and belief, as a direct and proximate result of Defendant’s
4 actions, the public is likely to be confused and has been confused as to believe that Defendants’
5 Infringing Product is associated with Plaintiff’s and/or its products bearing the ‘479 Patent and
6 the Silhouette Mark, when in truth and in fact they are not.
7 55. As a direct and proximate result of Defendant’s actions, Plaintiff is entitled to
8 injunctive relief enjoining and restraining Defendant’s from use of the design covered by the ‘479
9 Patent and the Silhouette Mark throughout the United States.
10 56. Because Plaintiff cannot control the nature and quality of Defendant’s goods,
11 Defendant’s infringing activities have had and will have an adverse effect on Plaintiff’s business
12 and reputation in this District, and throughout the United States, and Plaintiff has no adequate
13 remedy at law.
14 57. Upon information and belief, the Defendant has obtained gains, profits and
15 advantages as a result of their unlawful acts.
16 58. As a direct and proximate result of Defendant’s acts, Plaintiff has been injured and
17 will continue to suffer monetary damages in this District, and throughout the United States in an
18 amount presently unknown and to be determined at trial.
19 59. As Defendant’s actions have been willfully committed with intent to damage
20 Plaintiff and to confuse and deceive the public, Plaintiff is entitled to Defendant’s profits, treble
21 Plaintiff’s actual damages, an award of costs, and this being an exceptional case, reasonable
22 attorneys’ fees pursuant to 15 U.S.C. § 1117(a).
23 PRAYER FOR RELIEF
24 WHEREFORE, Plaintiff respectfully requests the following relief:
25 A. Entry of a judgment in favor of Plaintiff on all Counts of the Complaint;
26 B. Entry of a judgment that Defendant has directly and/or indirectly infringed the ‘479
27 patent and that such infringement has been willful;
28

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 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 13 of 14

1 C. Entry of a permanent injunction against Defendant, pursuant to 35 U.S.C. § 283

2 and/or the equitable powers of this Court, to prevent further direct and/or induced infringement of
3 the ‘479 patent;
4 D. An award damages, in an amount to be determined, adequate to compensate Plaintiff
5 for the infringement that has occurred, pursuant to 35 U.S.C. § 284;
6 E. An Order requiring Defendant to account for and pay to Plaintiff any and all profits
7 made by Defendant from sales of its infringing products pursuant to 35 U.S.C. § 289;
8 F. An Order requiring Defendant to pay Plaintiff its costs and attorneys’ fees in this
9 action pursuant to 35 U.S.C. § 285 and/or other applicable laws;
10 G. A finding that Plaintiff is the owner of the entire right, title and interest in and to the
11 Silhouette Mark, that these rights are valid and enforceable and that Defendant has violated these
12 rights;
13 H. A finding that Defendant has violated 15 U.S.C. § 1125;
14 I. A finding that Defendant has violated 15 U.S.C. § 1114;
15 J. A finding that Defendant has competed unfairly with Plaintiff;
16 K. Entry of a preliminarily and permanent injunction enjoining Defendant from
17 violating any proprietary rights of Plaintiff;
18 L. A finding that Defendant willfully infringed Plaintiff’s rights;
19 M. An Order that all damages sustained by Plaintiff be increased as the result of the
20 willful nature of Defendant’s conduct; and
21 N. Such other and further relief as the Court may deem just and proper.
22 JURY DEMAND
23 Plaintiff hereby demands a trial by jury of all issues so triable.
24
25
26
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 Case 2:20-cv-02146-ESW Document 1 Filed 11/09/20 Page 14 of 14

DATED this 9th day of November, 2020.

1
KELLEY DRYE & WARREN LLP
2
3
By: /s/ Michael J. Zinna
4 Michael J. Zinna (admission pending)
Tiffany Arosemena (admission pending)
5
LANG & KLAIN, P.C.
6
7
By: /s/ William G. Klain
8 William G. Klain
George H. King
9 Attorneys for Plaintiff
10
11
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15
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11/9/2020 Case 2:20-cv-02146-ESW Document 1-1 Filed 11/09/20 Page 1 of 2
https://www.azd.uscourts.gov/cgi-bin/generate_civil_js44.pl

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Civil Cover Sheet

This automated JS-44 conforms generally to the manual JS-44 approved by the Judicial Conference of the United States in September
1974. The data is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. The information contained
herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law. This form is authorized for
use only in the District of Arizona.

The completed cover sheet must be printed directly to PDF and filed as an attachment to the
Complaint or Notice of Removal.

Plaintiff(s): Pso-Rite.com LLC Defendant(s): Exerscribe, Inc.

County of Residence: Outside the State of Arizona County of Residence: Maricopa
County Where Claim For Relief Arose: Maricopa

Plaintiff's Atty(s): Defendant's Atty(s):

William Klain
6730 N. Scottsdale Rd., Suite 101
Scottsdale, Arizona 85253-4408
480-534-4900

II. Basis of Jurisdiction: 3. Federal Question (U.S. not a party)

III. Citizenship of Principal

Parties (Diversity Cases Only)
Plaintiff:- N/A
Defendant:- N/A

IV. Origin : 1. Original Proceeding

V. Nature of Suit: 830 Patent

VI.Cause of Action: 15 USC 1114, 1125; 35 USC 271, 289 Brief description: patent
infringement; trademark infringement; unfair competition
VII. Requested in Complaint
Class Action: No
Dollar Demand:
Jury Demand: Yes

VIII. This case is not related to another case.

Signature: William G. Klain

Date: 11/9/20
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11/9/2020 Case 2:20-cv-02146-ESW Document 1-1 Filed 11/09/20 Page 2 of 2
https://www.azd.uscourts.gov/cgi-bin/generate_civil_js44.pl
If any of this information is incorrect, please go back to the Civil Cover Sheet Input form using the Back button in your browser
and change it. Once correct, save this form as a PDF and include it as an attachment to your case opening documents.

Revised: 01/2014

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 1 of 81

Exhibit A
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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 11 of 81

Exhibit B
 Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 12 of 81
Hip-Hero - Fully Adjustable Psoas Muscle Release Tool and Massager

https://hip-hero.com/ 9/9/2020 6:55 p.m.

Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 13 of 81

Exhibit C
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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 23 of 81

Exhibit D
Amazon.com: The BODY WEDGE Personal Abdominal Massager Tool - Relieves Hip, ... Page 1 of 9
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 24 of 81

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• ALLEVIATES LOWER BACK Powerful Magic Cordless Wand

PAIN AND SPEEDS UP Massager Handheld…
RECOVERY: Keep your body 232
in top shape by using our $
17.99
muscle massager device to
help reduce muscle stiffness, Sponsored

tight spots, and inflammation

after long periods of sitting or
uncomfortable sleeping
• STIMULATES YOUR CORE
PSOAS MUSCLE: Designed

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 25 of 81

specifically to massage the

PSOAS, our patented body
wedge has multiple contact
points to effectively stimulate
core muscles while relieving
tension and releasing
pressure
• WHY YOUR PSOAS
MUSCLE IS SO
IMPORTANT: The psoas
provides essential support for
organs while stabilizing your
trunk and spine during
movement; It’s the main flexor
of the hip joint and key to
maintaining posture, mobility,
and structural well-being
• YOUR AT-HOME PHYSICAL
THERAPIST: Our unique
personal massager is
specifically designed to mimic
the fingertips, knuckles, and
palm of the hand, making it
the next best thing to having
your own therapist or
chiropractor!
• LIGHTWEIGHT AND EASY
TO USE: Made of durable
foam material and is small
enough for travel; Please note
that you may experience
slight discomfort when
releasing trigger points in the
muscle but this will greatly
reduce after using daily for a
week

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- Myofascial Release…
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Frequently bought together

Total price: $109.98

+ +

 This item: The BODY WEDGE Personal Abdominal Massager Tool - Relieves Hip, Knee, and Lower Back Pain - Psoas… $40.00 ($40.00 / 1 Count)
 PSO-RITE Psoas Muscle Release Tool and Personal Body Massager - Night Black $49.99 ($49.99 / 1 Count)
 Hip Flexor Release Ball for Hip Flexor and Psoas. Pain Relief for Lower Back, Hips, Tailbone, Knees… $19.99 ($19.99 / 1 Count)

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 26 of 81

Vinyl - Foam Positioning

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Product description

Size:X-Large (Pack of 1)

Release your power with THE BODY WEDGE!

Designed specifically to massage the PSOAS, our patented foam wedge has multiple contact points to stimulate core muscles while relieving tension. The
psoas muscle is the most important skeletal muscle in your body for structural and psychological well-being. It’s the primary connector between your torso and
legs and gets compromised due to prolonged sitting and sleeping habits. During periods of immobilization, the psoas muscle is known to decrease in size which
may represent global muscle loss.

Why supporting the psoas muscle is so important

As the deepest muscle in our core, the psoas works with the hip flexors to pull the thigh and torso toward each other. Without it, we wouldn’t be able to get out
of bed in the morning. Your psoas muscle allows you to bend your hips and legs towards your chest and move your leg forward when you walk or run. This
muscle supports internal organs and stabilizes your trunk and spine.

When we live sedentary lifestyles, our psoas muscle starts to suffer from lack of movement. This can affect the spine, hip function and create imbalances in
glutes, quads and hamstrings. The breakdown of these muscles affects the lower back, hips, knees and then the ankles and feet.

The Body Wedge exposes the underlying cause of referred BACK-HIP-KNEE pain. Massaging the psoas and applying the right amount of pressure for a period
of time (2-5 minutes), relieves discomfort and releases tightness. It’s the first line of defense to bring balance back to your body.

Choose size based on height:

BLUE (Small/Medium) - for people with short to average torso, height 5' 6" and below.

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 27 of 81

RED (Medium/Large) - for people with average to long torso, height 5'6 and above.
BLACK (X-Large) - for people with long torso, height 6' and above.
*These are our best suggestions ONLY.

Product details
Size:X-Large (Pack of 1)

Product Dimensions : 6 x 4 x 6 inches; 6.38 Ounces

Date First Available : January 19, 2020
Manufacturer : Simple And Good Enterprise
ASIN : B0841TBMBJ
Best Sellers Rank: #115,503 in Health & Household (See Top 100 in Health & Household)
#449 in Manual Back Massagers
#30,646 in Health Care Products
Customer Reviews:
14 ratings

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Important information

Legal Disclaimer
In the unlikely event you experience more than a “good pain” (like you would feel with deep stretching or a deep full-body), or if the symptoms get worse,
you should stop using The Body Wedge™ or any other massage or self-care tool and consult a physician.

If you suspect any injury other than Repetitive Stress symptoms (such as sprains, bruising, broken or fractured bones, a tear or other acute injury to the
muscles, tendons or ligaments), you should not use the Body Wedge™ or the Body Wedge Kit or any other self-care or self-massage tool, as these tools
are not designed or intended to treat those types of injuries or conditions.

If any of those conditions are present, please consult a physician before using the Body Wedge™/Body Wedge Kit or other self-care, self-massage or
trigger point tools.

Please also supervise children in the use of The Body Wedge and Body Wedge Kit or any other self-care or self-massage tools and use only as directed.

Surgery in abdominal area is a contraindication for using the Body Wedge™. DO NOT USE WEDGE.

Pregnant Women should NOT use the Body Wedge™. Massage therapy during pregnancy has been shown to provide many benefits, including a sense of
wellness, improved relaxation, and better sleep. But certain techniques and trigger points in the body can cause contractions and premature labor, so
seeking expertise is vital. Happy Wedging!

Statements regarding dietary supplements have not been evaluated by the FDA and are not intended to diagnose, treat, cure, or prevent any disease or
health condition.

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 28 of 81

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Rating

Price $ 4000 $4999 7

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Sold By Simple And Good Enterprise PSO-RITE MIGLEO INC Body Back Company Inc

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Customer Questions & Answers

See questions and answers

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Customer reviews Top reviews

3.5 out of 5
Top reviews from the United States
14 global ratings

5 star 52% Joel Miscall

4 star 12%
It doesn't really work
3 star 0%
Reviewed in the United States on June 21, 2020
2 star 0%
Size: X-Large (Pack of 1) Verified Purchase
1 star 36%
I think this tool may work for other people, but I can't seem to isolate my psoas with it. I think a
How are ratings calculated? large softball does way better and a lot cheaper. I can release my psaos with a softball, but not
this tool. Try a softball first. Tip: I usually breathe in to bring my psaos up to the surface, and then
go dig in with a softball.

6 people found this helpful

Comment Report abuse

Dakota
BRILINTA is for adults who have been
hospitalized for a heart attack, known as
acute coronary syndrome.
Pain Relief!
Reviewed in the United States on July 23, 2020
Size: X-Large (Pack of 1) Verified Purchase
Great product for tight psoas

Comment Report abuse

Prescribing Information | Medication Guide

IMPORTANT SAFETY INFORMATION MJC
ABOUT BRILINTA® (ticagrelor), INCLUDING BOXED
WARNINGS, FOR 60-MG AND 90-MG TABLETS Targeted for the psoas. Not hard plastic
BRILINTA is used to lower your chance of having a Reviewed in the United States on January 29, 2020
Sponsored
Size: X-Large (Pack of 1)
This is an unverified purchase because I bought the wedge on another site before it was offered
on amazon. I bought this wedge for my psoas after Hip flexor pain made it painful to walk let
alone do any kicking or karate that I like to do. The wedge is made of a hard foam similar to yoga
blocks or swimming kickboards, so it is firm yet tolerable. Prior to the wedge I was using a hard
foam roller and before that, a kettle bell from youtube video instruction. Those were just too hard
for me as a female and the foam roller wasn’t targeted enough and felt like it smashed my organs
in. The wedge offers specific instructions including a video on youtube and is targeted. I even
flipped it over and laid on the rounded part when I got tired of being on my forearm and it felt
relieving. The seller was helpful in advice for size, I chose red because I’m in the middle size for
a female.
8 people found this helpful

Comment Report abuse

Pain free at last

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Fix Your Back and Hip Pain

Reviewed in the United States on January 30, 2020
Size: X-Large (Pack of 1)
Having suffered from lower back and hip pain for several years (from old injuries and a job where
I sit all day), I was thrilled to try The Body Wedge. My trainer suggested I try this product, and I
noticed improvement after the first use. There is just no better way to work on the psoas muscle
as it’s buried deep in your abdomen, and a tight psoas will affect hips and lower back. With The
Body Wedge, you control the intensity and the very firm foam material is hard enough to be
effective but not so hard that you feel like you might get injured. I now take my Body Wedge with
me when I travel to work out the kinks from sitting for long hours on the airplane. It’s a Simple,
but Great, product!!
4 people found this helpful

Comment Report abuse

Steven G. Depolo

Great tool for PSOAS that is affordable and works

Reviewed in the United States on January 30, 2020
Size: X-Large (Pack of 1)
The Body Wedge is a great tool to support my running, biking, and weightlifting. It is small, easy
to use, and affordable. The instructions are easy to use and there are plenty of videos to see it in
action. After using it regularly, I can see the benefits in my range of motion and flexibility. Put the
top of the wedge in your belly button and the lip shows you where to put the lip to position it over
your psoas. Easy!
One person found this helpful

Comment Report abuse

ColleenL

Great to combat psoas tightness from too much sitting

Reviewed in the United States on January 30, 2020
Size: X-Large (Pack of 1)
Too much sitting! I’d feel stiff and it hindered my training. I tried the wedge to get at the psoas to
help release it. The design with the lip helps target the areas that are tight. How much you lean
on it affects how deep it gets and the rocking motion helps you stay in the area, and get
circulation going. I also like to use it on my side to help “floss” the muscles that get stuck sitting.
3 people found this helpful

Comment Report abuse

See all reviews

4 stars and above

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Psoas Muscle $39.99

Release Tool and
Personal Body FREE delivery: Friday, Oct 30
Details
Massage for
FREE Amazon Day delivery:
Release Back Tuesday, Nov 3 with fewer
Bain, Trigger Point boxes and deliveries

Physical Therapy In Stock.

with 6 Massage Qty: 1

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Brand: LPYSFW
3 ratings
| 7 answered questions

Price: $39.99 ($39.99 / Secure transaction

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• 【Massage when Sleeping】

Have one to sell?
-Specially designed for hip,
back, waist, neck, calf, Sell on Amazon
shoulder, thigh massage to
remove mucle stiffness and 5% off coupon
soreness. Strongly
recommend you use before
sleep and after warm
shower.
• 【Pain relief and Pelvic
Correction】-The personal
body massager has been
proved great effect to pelvic Powerful Magic Cordless Wand
correction and pain relief for Massager Handheld…
hip, back, waist, shoulder, 232
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• 【Safe and Premium Raw
Material】-For the sake of
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experience, we select

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 34 of 81

natrual premium rubber

wood that is moisture-proof,
no discoloration, durable and
non-toxic for human to
guarantee the quality of the
tool itself.
• 【Handmade Craft】-Not
only a massager, but also a
delicate hand-made craft.
From material cutting to
finishing, skilled
woodworkers lead all the
process of making to make
sure the smoothness,
precise size of any ball and
great surface finish.
• 【Perfect Gift for Different
Ages】-Specially suitable
gift for people who are
backache, hip pain, sore
waist and also young people
with these problems. Perfect
gift on Mother's Day,
Father's Day, Teachers' Day,
Birthday, Christmas.

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Fascia Trigger Point

Massager Massage Tools
- Myofascial Release…
593
$
40.99

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Made Easy With Pso-Rite
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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 35 of 81

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Product Description

How to use?
1.It is recommended to use 2-3 times a day. It is strongly recommended not only in the morning and evening, but also after washing with hot water.

2.If you feel excessive stimulation, please put a towel between your body to adjust.

3.Recommended for post-natal people, where the pelvis is often deformed.

Massage each affected area.

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 36 of 81

Advantages Reminder
1.The uniquely designed three-dimensional shape moderately
• You must consult your
stretches the entire body!
physician prior to
2.Pushing in different sizes of spherical protrusions can stimulate the hips, hips and back well! You can relax starting this or any other
stiffness and correct your pelvis. program.
• If you experience
3.The "press point" that highlights the hardness, shape and protrusion arrangement will heal your fatigue. discomfort while using
this product, stop activity
4.The ball pot can be firmly fixed, so you can adjust it according to your body and preferences. immediately.
• Always check
equipment before using.
If any defects are found,
do not use this product.

Why to use?
When an injury within the soft tissue occurs, the tissue repairs itself in a haphazard pattern, forming scar tissue. While the scar tissue itself is not painful, it
does tend to limit range of motion, and the ongoing stiffness may contribute to chronic pain.

Waist and hip massage Neck massage Thigh massage

Lie on your back and place the ball on the Press with large and small protrusion push balls Effectively relieve leg stiffness and fatigue,
affected area. Adjust the position of the sphere from the back of the head to the shoulders at improve sciatica and hip joint pain.
according to the position of the affected area. once.

Slowly lean down and lie on your back.

Heel massage Calf massage Foot massage

Since the ball is made by reproducing the Massage the area where you feel tight and Sit in a chair and place the weight in a
feeling of finger pressure, it is also the best swollen. Please adjust the position of the sphere comfortable place. Suggest the outermost
choice for pushing onto the sole of the foot. according to the party. position of the sphere.

Product details
Package Dimensions : 11.81 x 4.72 x 4.72 inches; 2.65 Pounds
Date First Available : August 15, 2020
Manufacturer : LPYSFW
ASIN : B08FY88FZX
Best Sellers Rank: #72,569 in Health & Household (See Top 100 in Health & Household)
#236 in Manual Back Massagers
#18,884 in Health Care Products
Customer Reviews:
3 ratings

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 37 of 81

Videos
Videos for related products

4:26 3:34 24:33

The 10 Best Massage Guns The 5 Best Chiropractic Adjusting How to manage ITBand and Knee Back Stretcher for pain relief
Tools pain using the massage gun

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Important information

Legal Disclaimer
Statements regarding dietary supplements have not been evaluated by the FDA and are not intended to diagnose, treat, cure, or prevent any disease or
health condition.

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Body Massage for Release and Massager Drainage Scraping Massage Acupressure, Trigger Point
Back Bain, Trigger Point Tool Used for Pressure Massage
Physical Therapy with 6 Back/Legs/Arms/Neck/Shoul
Massage Heads der/Tiger Point Professional
Scraping Massage
Myofascial Release Physical
Therapy

Customer (3) (56) (11) (392)

Rating

Price $ 3999 $ 3999 $ 1999 7

$ 99

Shipping

Sold By ECOGUN-Direct Exerscribe Mikako MIGLEO INC

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Customer reviews Top reviews

4.3 out of 5
Top review from the United States
3 global ratings

5 star 63% JJL VINE VOICE

4 star 0%
Nothing Special Here

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3 star 37% Reviewed in the United States on October 19, 2020

2 star 0% Vine Customer Review of Free Product ( What's this? )
1 star 0% This is a really nicely crafted product. The wood is solid, smooth and polished. However,
there's more cons than pros.
How are ratings calculated?

First, you get six massage balls, but only five of them fit nicely in the holes at the same time.
So if you want to store them (or even display as art), you have an extra ball. (You can get all
six to fit if you angle them, but the sixth will keep falling out, and looks stupid anyway.)

When using, the base doesn't really do much. It's much easier to just tuck a ball or two under
my body and roll around. The balls feel good under sore spots, but, newsflash: you can do the
same with a tennis ball. There's no reason to buy this, as it doesn't do anything special.

Overall, while nicely made, I'm disappointed.

One person found this helpful

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Neck Massager, Intelligent Neck Massage… See all reviews

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RAD Roller I Deep Tissue Peanut $29.99

Massage Tool for Neck, Upper & FREE Returns

Back, Thoracic Spine, Psoas, FREE delivery: Friday, Oct 30

Details
Quads and Hamstring Self
FREE Amazon Day delivery:
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Add to List
• RELIEVE ACHES AND PAINS. Reduce inflammation
and strain on soft tissue trigger points for an increased Add to Baby Registry
sense of wellness and body awareness with daily
fascia massage.
• INCREASED MOBILITY. Improve joint range of motion
and myofascial mobility to help increase strength, New & Used (2) from
speed and wellness. For all over muscle use including $27.35 FREE Shipping
cervical spine, thoracic spine, glutes, back, neck,
psoas, quad, glute, lumbar spine, hip and feet.
• RECOVER LIKE A PRO. Promote faster post- Share
exercise/workout recovery by rolling out for 10 minutes
a day. Recovery must occur before progress can be Have one to sell?
made, SMR is important for staying injury free and Sell on Amazon
minimizing movement restrictions.
• BODY MAINTENANCE MASTER. Soft density peanut
roller with extra wide spinal recess for deep tissue
massaging of muscles, not bones. Fits inside the RAD
Block for storage (sold seperately).
• TRAVEL SIZE. Myofascial release tool for easy on-
the-go use at home, the gym, your yoga studio or your
suitcase. 5.6 inches by 2.8 inches / 17 ounces.

New & Used (2) from $27.35 FREE Shipping

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 RAD All in Kit I Myofascial Release Tool Kit with Block, Massage Balls, Peanut Roller, Massage Stick… $140.00
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Product Description

RAD RAD Roller

Tension Relieving Massage Tools Technical Specs
• 4.9" x 2.5"
Ever wish you could see a massage therapist everyday? We do! Which is why we designed the entire line of RAD
• Green = gentle/soft touch
mobility tools to closely replicate the touch of a trained massage therapist. They provide acute point release and
• Blue = original density
flush out waste materials from your soft tissue to achieve optimal mobility and recovery.
• Black = extra stiff/deep tissue
RAD Roller Get the (RAD) Ball Rollin’ With a
The RAD Roller is where it all began. Its shaped just right to use all over the body from your neck to your feet. Partner
Don’t let the term self myofascial
release fool you. You don’t have to
keep our tools to your self. Grab a
partner and roll out each other’s
tough spots with any one of our RAD
tools.

The Everywhere Massage Roller

The RAD Roller is the most functional massage and release tool ever designed. It works everywhere
on you (precise enough to target almost every muscle in your body) and everywhere you go (it’s
crazy compact and perfectly portable). Plus, this thing is super easy to use.

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THE DENSITIES, EXPLAINED

SOFT MEDIUM STIFF

The Soft RAD roller offers a more gentle touch, Texture is soft enough to use on more sensitive Ideal for athletes and more intensity, the Stiff
making it perfect for newbies. Ideal for massaging areas like your neck, yet hard enough to unlock RAD Roller has a harder texture and bends less
your neck, scalp and more delicate areas of the tougher muscles like your back, legs and in the middle so you can turn it sideways and
body. everywhere else you’re ready to roll. work areas like your pecs and inner leg.

RAD Roller Soft RAD Roller Original RAD Roller Stiff RAD Roller XL RAD Helix

Size 4.9" x 2.5" 4.9" x 2.5" 4.9" x 2.5" 5.6' x 2.8" 12.5" x 3"

Density Gentle Classic Deep tissue Gentle Classic

Weight 13 oz. 13 oz. 13 oz. 17 oz. 1 lb.

Area of spine designed Mid-spine + neck Mid-spine + neck Mid-spine + neck Lumbar Lumbar
for

Product details
Color:Xl

Is Discontinued By Manufacturer : No
Package Dimensions : 5 x 4 x 4 inches; 1 Pounds
Date First Available : May 21, 2015
Manufacturer : RAD
ASIN : B00Y1HH26S
Best Sellers Rank: #29,408 in Health & Household (See Top 100 in Health & Household)
#32 in Manual Massage Balls
#7,503 in Health Care Products
Customer Reviews:
40 ratings

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2:56 10:54 13:59

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Important information

Legal Disclaimer
Not meant to treat, cure or prevent any disease or condition. Talk to your doctor before using any RAD products. Please use responsibly.

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Customer Questions & Answers

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Customer reviews Top reviews

4.2 out of 5
Top reviews from the United States
40 global ratings

5 star 57% Gino

4 star 22%
Very Good Product
3 star 9%
Reviewed in the United States on July 15, 2019
2 star 7%
Color: Xl Verified Purchase
1 star 5%
I have use several gadgets and items for stress/pain in between my shoulder blades and base of
How are ratings calculated? neck area. This is by far the best and easy to use product. By using it 5/10 minutes three times a
day, my pain has dissapeared. I've tried flat on the floor and against a wall, with good results, it
will take you a few tries to figure out the best and most beneficial position for you. A bit pricey but
worth the money, it'll basically last you for the rest of your life. I got the XL size. I'm 180 lbs; 5:10
2 people found this helpful

Comment Report abuse

Amazon Customer

great quality
Reviewed in the United States on August 21, 2019
Color: Xl Verified Purchase

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 47 of 81

used it at first in my physical therapy sessions, it was called ACTIV8R. made some research and
found the company was acquired by RAD. debated a little on the price then pulled the trigger.
after that i wish i have purchased it sooner
2 people found this helpful

Comment Report abuse

Michael R

Too soft
Reviewed in the United States on November 23, 2018
Color: Xl Verified Purchase
Too soft for me. I like the black one because it is harder and gets into my muscles much better.

3 people found this helpful

Comment Report abuse

Judith Sponsel

New to this - but does the job

Reviewed in the United States on December 17, 2019
Color: Xl Verified Purchase
I am new to using this type of roller, but with my back issues, it was recommenced by my
chiropractor. What a difference! Easy to use (several videos out there). I even have my husband
trying it!
One person found this helpful

Comment Report abuse

Chris Mogil

Disappointing
Reviewed in the United States on January 25, 2020
Color: Xl Verified Purchase
Honestly, it’s just like using one of my dogs toys to crack my back. I thought it would’ve been a
larger product! Sometimes, if I don’t have my wife put it underneath me, it’s hard to center on the
sweet spots.
2 people found this helpful

Comment Report abuse

Wishnick

Should have bought medium hard is way too hard

Reviewed in the United States on November 15, 2019
Color: Xl Verified Purchase
Should have bought medium hard is way too hard I like it though would work just as well and in
soft or Medium
One person found this helpful

Comment Report abuse

world peace

Very comfortable. I want you to sell it in Japan. XL size.

Reviewed in the United States on November 17, 2019
Color: Xl Verified Purchase
I can't buy it in Japan. XL size.
I'm in trouble. Some Japanese people have big bodies.
The shipping cost is inexpensive. good.
It is not hollow. Moderately hard.
RAD Roller XL is the best.
One person found this helpful

Comment Report abuse

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Krystina Brown

BUY IT!!!
Reviewed in the United States on February 28, 2019
Color: Xl Verified Purchase
Cracks your back all the way down, digs deep and relieves tension. Love it!!
2 people found this helpful

Comment Report abuse

See all reviews

Top reviews from other countries

L. Chapman

Chiropractor replacer...
Reviewed in Canada on February 28, 2018
Color: Xl Verified Purchase
There is absolutely no substitute for this roller, and I've tried many. If you have trouble with your
back between your shoulder blades shifting out of place, this roller is perfect in size and stiffness
for shifting your vertebrae back. I haven't been to the chiropractor in over a year and a half
because of this roller, and because I can treat myself so often (i.e. whenever I need to) my back
problem areas have become much more stable and strengthened (my back hardly every shifts
out any more). In my area, the cost of a single chiropractor visit would pay for this roller 1.5 times
over. To use it the way I do, you lay down on your back and position the roller on either side of
your vertebrae to the spot where it's shifted out, cross your arms across your chest tightly and
suck your head/chin to your chest, raise your torso up a bit (perhaps an inch or two) like you're
doing a slight sit-up, and fall back onto the roller (multiple times, if necessary) with increasing
force until it shifts back in place. It's also excellent for tight shoulder muscles, for pressure point
therapy/massaging. I'd avoid use of this roller on the lower back, as it's not meant for this area
and injuries may result. You can use the roller on tight neck muscles for pressure point therapy
and massaging - just don't go overboard with the pressure/force on your neck. If you're looking at
all the options I definitely recommend going with this brand (again, I've tried many) - everything
2 people found this helpful

Report abuse

Amazon Customer

Better than a Foam Roller Stick

Reviewed in Canada on August 27, 2019
Color: Xl Verified Purchase
I like it and my husband loves it. He finds that it works really well on his back and neck. I find it
helps for my shoulders and gluts. I would like to invest in a massage tool that you do not have to
roll on it across the floor to use it, but he doesn't mind having to do this to loosen tight muscles. It
collects hair and dust off the floor too easily, but is very easy to wash off quickly.

Report abuse

Barbara

Love love love

Reviewed in Canada on October 16, 2020
Color: Xl Verified Purchase
I love this product!! For rolling for pain relief and mobility, it’s great for thoracic spine but also for
leg muscles as well.
It’s a bit bigger than other peanut products and that makes it good for upper traps and glutes.
Highly recommended!!

Report abuse

David Fishman

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 49 of 81

Very well designed and made - I just wish there were density choices
Reviewed in Canada on August 5, 2017
Color: Xl Verified Purchase
Very well designed and made - I just wish there were density choices same as for the regular
RAD roller, but not a huge concern. Definitely feels better on the lumbar spine and SI-joint area
than the regular roller - my understanding is that it was specifically designed for that because the
vertebrates in those areas are larger . . . works very well for me !

Report abuse

Denis G

Good product
Reviewed in Canada on August 31, 2018
Color: Xl Verified Purchase
Too hard for my liking. I'll most likely go for the softer pair of I decide to continue using this brand

Report abuse

See all reviews

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DCT KnotStop - $39.95

Neck Massage, & FREE Returns

Trigger Point FREE delivery: Saturday, Oct

31
Therapy, Muscle Order within 9 hrs and 43 mins
Pain Reliever, Details

Deep Tissue FREE Amazon Day delivery:

Tuesday, Nov 3 with fewer
Massage for Head, boxes and deliveries

Neck, Shoulder, Only 18 left in stock -

Arms, Back, Leg, order soon.
foot - Upgrade Qty: 1

Your Therapy Balls

for better
Myofascial release
Brand: DCT
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• PORTABLE & EASY to use.
The collapsable cradle makes
it packable for any trip… be it Share
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Have one to sell?
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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 52 of 81

game by investing in the

patented DCT KnotStop.
• GO DEEPER – Designed for
deep tissue trigger point
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• FREE USER GUIDE
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• 120 DAY NO QUESTIONS
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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 53 of 81

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Product description

The DCT KnotStop was specifically designed and patented based on the anatomy and biomechanics of the Neck, Spine, and Pelvis. The unique shape and
construction of the DCT KnotStop gives precise pressure without completely restricting motion, creating an unparalleled therapeutic release of tension.

Product details
Is Discontinued By Manufacturer : No
Package Dimensions : 9.65 x 7.91 x 3.74 inches; 15.77 Ounces
Date First Available : May 29, 2017
Manufacturer : DCT Products
ASIN : B07262S37B
Best Sellers Rank: #486,432 in Health & Household (See Top 100 in Health & Household)
#1,035 in Manual Massage Balls
#132,503 in Health Care Products
Customer Reviews:
2 ratings

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 54 of 81

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 55 of 81

Customer reviews Top reviews

3.9 out of 5
Top reviews from the United States
2 global ratings

5 star 46% Kimmie

4 star 0%
It's a great product and it really does work but........
3 star 54%
Reviewed in the United States on December 27, 2018
2 star 0%
Verified Purchase
1 star 0%
These balls come with some kind of chemical that gets on your hands and it's hard to get off. It
How are ratings calculated? taste awful, and it took several washes to finally get it off. Do not touch them with your hand.
Wash them off until, you get rid of that horrible chemical.
2 people found this helpful

Comment Report abuse

lionesspride
$5 off coupon
Most important thing I own, next to my new stabilizing disk, of course!
Reviewed in the United States on June 24, 2018
Verified Purchase
Use it at least once a day. It helps to center everything so I don't walk lopsided.

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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 58 of 81

Exhibit E
 Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 59 of 81

KELLEY DRY E & W ARREN LLP

A LI MIT E D LIA BI LIT Y P ART NER SHI P

101 PARK AVENUE

CH I CAGO, IL F ACSIM I LE

HO USTO N,T X
NEW YORK, NY 10178 ( 212) 808- 7897

LOS A NGE L ES, C A www.kelleydrye.com

P A RSI PP A NY, NJ (212) 808-7800

S A N DIEG O, CA

S TAM FOR D, C T MICHAEL J. ZINNA

W AS HI NGTO N, DC DIRECT L INE:(212) 808-5964

EMA IL: mz inna@kelleyd rye.com

AFFILIATE OFFICE

MUMBAI, INDIA

September 10, 2020

Via Electronic Mail to:

[email protected]; [email protected]
[email protected]

Via Federal Express to:

Mr. Kusha Karvandi
Hip Hero / Exerscribe, Inc. at:

6501 E. Greenway Parkway

Scottsdale, Arizona 85254

1124 Brenham Lane

Leander, Texas 78641

3550 Lakeline Blvd.

Leander, Texas 78641

Re: Infringement of PSO-RITE.COM LLC’s Intellectual Property Rights

Dear Mr. Karavandi:

We represent PSO-RITE.COM LLC (“Pso-Rite”) in intellectual property legal matters.

Pso-Rite is a health and fitness company specializing in muscle release and recovery
tools. The company has obtained multiple patents and trademarks around the world in
connection with its innovative products. Among these assets are:

 United States Design Patent No. 823,479 (“the ’479 Patent”) which covers the
design of a massager (attached as Exhibit A). The unique design of the massager

4814-3216-1994v.1
 Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 60 of 81

KELLEY DRYE & WARREN LLP

September 10, 2020

Page Two

covered by the ‘479 Patent is meant to optimize psoas release, but can also be
used on other muscles and body parts.

 U.S. Trademark Reg. No. 5,363,487 (the “487 Registration”), for the mark PSO-
RITE® for use in connection with massage apparatuses for personal use, for
massaging neck, shoulders, chest, glutes, legs, back and other painful or tight
knots or spots; foam rollers; massage rollers; massage sticks and massage balls
(attached as Exhibit B).

It has come to Pso-Rite’s attention that you are offering for sale a product called the Hip
Hero, which is described at www.hip-hero.com as a “Fully Adjustable Psoas Muscle Release
Tool and Massager.” We are aware that the Hip Hero is being offered for sale at least through
the Hip Hero website mentioned above, on Amazon and on eBay. Screenshots of these offers for
sale of the Hip Hero are attached as Exhibit C.

This letter is to advise you that your conduct in connection with making, using, selling,
offering for sale and marketing the Hip Hero constitutes infringement of Pso-Rite’s patent and
trademark rights and is in violation of several federal and state laws. If you wish to avoid legal
action, these activities must stop immediately.

A design patent is infringed when the accused design, taken as a whole, is found to be
substantially similar to the patented design by the ordinary observer. See Egyptian Goddess, Inc.
v. Swisa, Inc., 543 3d. 665 (Fed. Cir. 2008). Notably, in order for there to be infringement, the
accused product need not be an exact copy of the patented design. Here, there can be no credible
dispute that the Infringing Product is substantially similar to the design covered by the ‘479
Patent. The basic shape of the Infringing Product and the design covered by the ‘479 Patent are
the same. Indeed, from the side, the products look identical. The similarities make sense
(however illegal they may be) because the Hip Hero is intended for the exact same purpose as
the Pso-Rite, and was clearly based on our client’s product.

Trademark infringement is the unauthorized use of a source identifier that is identical or

confusingly similar to another party’s trademark, in a manner that is likely to cause confusion,
deception, or mistake about the source of the goods or services offered by the parties. See 15
U.S.C. §1125. In other words, trademark rights give the trademark owner the ability to stop third
parties from using confusingly similar words or indicia in connection with goods or services that
are similar to those covered by the trademark. Our investigation reveals that you have been
purchasing and using PSO-RITE®, as well as other Pso-Rite trademarks and keywords, for use
as your own keywords on Amazon. The unauthorized use of PSO-RITE® as a keyword is
clearly designed to trade upon the goodwill associated with our client’s name and federally-
registered trademark. See e.g. Australian Gold Inc. v. Hatfield, 436 F.3d 1228, 1240–41 (10th
Cir. 2006) (finding Defendant’s purchase of Plaintiff’s trademark as a keyword to be

4814-3216-1994v.1
 Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 61 of 81

KELLEY DRYE & WARREN LLP

September 10, 2020

Page Three

infringement, due to initial interest confusion); Network Automation, Inc. v. Advanced System
Concepts, Inc., 638 F.3d 1137, 1145–54 (9th Cir. 2011) (holding that under the Lanham Act, a
trademark purchased as a keyword for use in a search engine can lead to likelihood of confusion
and therefore constitute trademark infringement). As one example of your keyword-related
unlawful activity, attached hereto as Exhibit D is a URL link evidencing your purchase of the
term PSO-RITE® as a keyword for use in connection with the Hip Hero. As you clearly know,
this causes the Hip Hero to be listed near the top of Amazon search results when Amazon users
are actually looking for Pso-Rite products. If you can only sell the Hip Hero effectively on
Amazon by wrongly associating the product with Pso-Rite, that fact in and of itself is evidence
of trademark infringement, false designation of origin and unfair competition.

In addition, your infringing actions have clearly been willful. It would be impossible for
you to assert that you did not know about Pso-Rite until now, given that you have used the
company name as an Amazon keyword. A finding of willful patent infringement and willful
trademark infringement comes with additional liability and the possibility that Pso-Rite will be
awarded enhanced damages beyond the damages usually awarded for “innocent” infringement.

In light of all this, Pso-Rite would be well within its rights to commence litigation in
federal court against you for willful patent infringement, willful trademark infringement, false
designation of origin, unfair competition and other violations of federal and state law, seeking
monetary damages, injunctive relief and any other remedy a court may deem just and proper.
Nonetheless, Pso-Rite would prefer to resolve this matter amicably. If you share this desire, you
must take the following actions immediately:

(i) Discontinue all offers for sale and actual sales of the Hip Hero;
(ii) Immediately and permanently cease all use of PSO RITE® or any Pso-Rite
trademark or keyword in connection with any of your marketing efforts;
(iii) Cancel all pending orders for the Hip Hero, including orders you have placed with
your supplier and orders your customers have placed with you;
(iv) Remove all reference to Pso-Rite from websites and social media accounts owned
or operated by you;
(v) Destroy all inventory of the Hip Hero;
(vi) Provide Pso-Rite with an accounting of unit sales, revenue and profit for the Hip
Hero;
(vii) Agree to refrain from infringing our client’s trademarks and patents in the future;
and

(viii) Provide us with the name and contact information of the entity who is
manufacturing the Hip Hero for you.

4814-3216-1994v.1
 Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 62 of 81

KELLEY DRYE & WARREN LLP

September 10, 2020

Page Four

If you wish to resolve this matter amicably, please confirm in writing by no later than
September 18, 2020 that these actions have been taken.

This letter is without prejudice to any and all rights and remedies that Pso-Rite may have,
all of which are expressly reserved.

Very truly yours,

Michael J. Zinna

4814-3216-1994v.1
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 63 of 81

Exhibit A
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 64 of 81
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 65 of 81
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 66 of 81
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 67 of 81
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 68 of 81
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 69 of 81
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 70 of 81
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 71 of 81
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 72 of 81
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 73 of 81

Exhibit B
 Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 74 of 81

Reg. No. 5,363,487 PSO-RITE.COM LLC (DELAWARE LIMITED LIABILITY COMPANY)

1122 6th Street, Apt. 307
Registered Dec. 26, 2017 Santa Monica, CALIFORNIA 90403

CLASS 10: Massage apparatus for personal use for massaging neck, shoulders, chest, glutes,
Int. Cl.: 10 legs, back and other painful or tight knots or spots; Massage apparatus, namely, foam rollers,
massage rollers, massage sticks and massage balls
Trademark
FIRST USE 2-22-2017; IN COMMERCE 2-22-2017
Principal Register
THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY
PARTICULAR FONT STYLE, SIZE OR COLOR

SER. NO. 87-418,277, FILED 04-20-2017

Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 75 of 81

Exhibit C
 Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 76 of 81
Hip-Hero - Fully Adjustable Psoas Muscle Release Tool and Massager

https://hip-hero.com/ 9/9/2020 6:55 p.m.

 Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 77 of 81
Amazon.com: Hip Hero Fully Adjustable Psoas Muscle Release Tool and Massager: Health & Personal Care

https://www.amazon.com/Fully-Adjustable-Muscle-Release-Massager/dp/B083VXNJ95/ref=sr_1_22_sspa? 9/9/2020 7:05 p.m.

Hip Hero Fully Adjustable Psoas Muscle Release Tool and Massager | eBay Page 1 of 4
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 78 of 81

Hi Michael! Daily Deals Brand Outlet Help & Contact Sell Watchlist My eBay

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Release Tool and Massager
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Condition: New
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Item location: Scottsdale, Arizona, United States
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Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 79 of 81

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eBay item number: 184431365043

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Last updated on Sep 09, 2020 11:56:18 PDT View all revisions

Item specifics
Condition: New: A brand-new, unused, unopened, undamaged item in its Material: Plastic
original packaging (where packaging is ... Read more
Body Area: Hip Type: Trigger Point Massager
Brand: HIP HERO Features: Adjustable
Massage Function: Pain Relief UPC: 850006340033

https://www.ebay.com/itm/Hip-Hero-Fully-Adjustable-Psoas-Muscle-Release-Tool-and-M... 9/10/2020
Hip Hero Fully Adjustable Psoas Muscle Release Tool and Massager | eBay Page 3 of 4
Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 80 of 81

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✔ ADJUSTABLE If you are looking for the best in psoas massager tools, your are in the right place. Hip Hero is easily adjustable with a
patent pending sliding and locking mechanism so you can fully customize this amazing tool to YOUR body. Locating and massaging the
psoas is not a one-size-fits-all process, so it is vital that your massager be adjustable to fit your body properly.

✔ VARIETY OF USES Hip Hero is not only amazing for precisely massaging and releasing tight psoas muscles, it can also be used for
myofascial release on a variety of muscle groups just by laying on the muscle group for 30-60 seconds. Massage and stretch the piriformis,
unlock tight hip flexors, and gain strength and flexibility so your whole body can move and perform better.

✔ RELIEF Get the relief you need without constant costly trips to a massage therapist. The Hip Hero simulates the hand or elbow of an
expert massage therapist.

✔ YOUR NEW FAVORITE TOOL You can toss out your bulky, dirty, and misshapen foam rollers and massagers that you previously used
for unlocking hips, releasing a trigger point, or hip flexor stretching. The Hip Hero is portable, lightweight, ergonomic, easy to clean, and has
a premium slip resistant coating.

✔ QUALITY Hip Hero is made of high density material and quality construction designed to last. It is designed with smooth and rounded
massage contact points designed to simulate elbow of a massage therapist. Additionally, there are rubber strips on the bottom for better grip
to prevent slipping. 1 year manufacturer warranty.

Locating and massaging the psoas is not a one-size-fits-all process, so it is vital that your massager be adjustable to fit your body
properly. So toss that stagnant psoas stretcher, foam roller, or massage ball and replace it with the uniquely adjustable Hip Hero.
The Hip Hero is uniquely designed to release those hard to reach areas that typical exercises and stretches cannot. The
dimensions of the product are 5 inches (width) by 16.25 inches (length) by 5.5 inches (height).

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More to explore : Circulation Massager Massagers, Hitachi Massage Wand Massagers, TENS Circulation Massager Massagers, HoMedics Massage Cushion Massagers,
Full Body Massage Cup Massagers, IQ Massager Massagers, Cordless Massage Wand Massagers, Vibratex Massage Wand Massagers, Fully Adjustable Dental Articulators,
HoMedics Massage Mat Massagers

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https://www.ebay.com/itm/Hip-Hero-Fully-Adjustable-Psoas-Muscle-Release-Tool-and-M... 9/10/2020
 Case 2:20-cv-02146-ESW Document 1-2 Filed 11/09/20 Page 81 of 81

Exhibit D

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