Plaintiff Attorney:
Joseph D. Agliozzo, Law Corporation
Injunctive Relief:
3.1. On and after the Effective Date iBenzer shall not sell the Covered Product for distribution
in California in the future and shall not resume sales of the Covered Product in California
unless the product meets the reformulation standard set forth in Paragraph 3.2 or unless
iBenzer provides a clear and reasonable warning for any non-reformulated Covered
Product that it ships, sells, or offers to ship or sell in California.
3.2. Except as provided above, on and after the Effective Date, iBenzer agrees to only
manufacture for sale or purchase for sale in or into California, “Reformulated Covered
Products.” For purposes of this Settlement Agreement, “Reformulated Covered
Products” are Covered Products containing no more than 1,000 parts per million (0.1%)
DINP in any accessible component (“accessible component” is defined as any component
that could be touched by a person during reasonably foreseeable use). In order to
determine compliance with this reformulation standard, iBenzer may rely on third party
testing from an accredited laboratory.