There may soon be new developments in the areas of counterfeit and trademark law following the April 8, 2021 filing of a petition for a writ of certiorari with the U.S. Supreme Court by Arcona, Inc. after its back-to-back losses before the U.S. District Court for the Central District of California and the U.S. Court of Appeals for the Ninth Circuit in Arcona, Inc. v. Farmacy Beauty, LLC.