The opinion of the court was delivered by: U.S. District Judge Kronstadt
MEGAN E. GRAY (SBN 181204) GRAY MATTERS 2017 Kalorama Road NW, Suite 3 Washington, DC 20009 Telephone: (202) 265-2738 Facsimile: (202) 280-1225 Email: email@example.com Attorneys for Plaintiff M.M.P., INC.
CONSENT JUDGMENT as to Defendants Leyendecker, Moss, and Guarjardo (JS-6 Only)
Plaintiff M.M.P., Inc. ("Plaintiff") and Defendants Leyendecker Los Angeles, LLC, Jessica Moss, and Lisa Guarjardo ("Defendants") hereby stipulate to the entry of Judgment as set forth below, there having been no adjudication of the issues, it is hereby:
ORDERED, ADJUDGED, AND DECREED THAT:
1. This Court has jurisdiction over the parties to this action and over the subject matter hereof pursuant to 17 U.S.C. § 501, and 28 U.S.C. §§ 1331, 1332, 1338 and 1367. This Consent Judgment binds defendant(s), their servants, employees, subsidiaries, and successors-in-interest. Likewise, Plaintiff's interest in this Consent Judgment may be assigned, permitting any successor-in-interest to enforce these provisions.
2. Plaintiff is the owner of the following copyrighted designs: MMP's design number SAP0800064, which has copyright registration number VA-1-694-742, and design number AM085, which has copyright registration number VA-1-683-873S, as attached as exhibits to the Complaint (collectively referred to as the "Copyrighted Designs").
3. As of the date of this Order, Defendants, and each of its officers, directors, shareholders, successors and assigns, agents, employees, and all persons in active concert or participation with any of them, be permanently enjoined and restrained from, directly or indirectly, infringing the above-described Copyrighted Designs of MMP in any manner, including generally, but not limited to reproducing, adapting, and/or displaying the Copyrighted Designs by manufacturing, distributing, advertising, selling, and/or offering for sale any merchandise that infringes said Copyrighted Designs, and specifically:
(i) Manufacturing, distributing, selling, and/or offering for sale said products or any other unauthorized products that picture, reproduce, adapt or display any design that bears a substantial similarity to MMP's Copyrighted Designs; or
(ii) Manufacturing, distributing, selling, or offering for sale or in connection thereto any unauthorized promotional materials, labels, packaging, or containers that picture, reproduce, adapt, or display any design that bears a substantial similarity to MMP's Copyrighted Designs;
4. Defendants are required to effect the recall, removal, and return from commercial distribution and/or public display of:
(a) Any merchandise that pictures, reproduces, copies, adapts, or displays designs that bear a substantial similarity to MMP's Copyrighted Designs;
(b) Any promotional and advertising material labels, packages, wrappers, containers, and any other unauthorized items that reproduces, copies, adapts, or displays designs that bear a substantial similarity to MMP's Copyrighted Designs;
(c) Any molds, screens, patterns, plates, or negatives used specifically for making or manufacturing products with designs that picture, reproduce, copy, or bear a ...