CHRISTIAN LOUBOUTIN, CHRISTIAN LOUBOUTIN SA, and CHRISTIAN LOUBOUTIN LLC, Plaintiffs,
NIKI MOOSH and DOES 1 through 10, Defendants.
KILPATRICK TOWNSEND & STOCKTON LLP, GREGORY S. GILCHRIST, (Cal. State Bar No. 111536) RYAN BRICKER, (Cal. State Bar No 269100), Francisco, CA, Attorneys for Plaintiffs, CHRISTIAN LOUBQUTIN, CHRISTIAN LOUBOUTIN SA, and CHRISTIAN LOUBGUTIN LLC.
FINAL JUDGMENT AND PERMANENT INJUNCTION
CHRISTINA A. SNYDER, District Judge.
Pursuant to the parties' stipulation, the Court enters judgment as follows:
I. FINDINGS OF FACT:
1. LOUBOUTIN owns a number of trademarks, that it has registered around the World, including in the United States as shown in the following chart:
2. LOUBOUTIN has used these and other trademarks ("Trademarks") for many years to identify itself as the source of its high quality footwear and leather goods.
3. The Trademarks are valid and famous trademarks owned by LOUBOUTIN and that LOUBOUTIN has the exclusive right to use the Trademarks throughout the world.
4. MOOSH has offered to sell and sold products bearing one or more of these trademarks which were never manufactured by or for LOUBOUTIN or With its approval.
5. MOOSH has used social media sites to solicit her consumers, including but not limited to Facebook ("Niki Moosh"), Instagram ("nikimoush", and "nikimoosh2." Examples of MOOSH's offers and sales are annexed as Exhibit l.
6. MOOSH's offers and sales violate LOUBOUTIN's rights in its Trademarks.
7. LOUBOUTIN has incurred or suffered damages totaling no less than $12, 500 that is uncompensated by this Judgment and Final Injunction.
8. The following consitute all of the sources of supply that MOOSH has identified as her source of supply for any products bearing the Trademarks
a. Ronghua Wang residing in the People's Republic of China (address unknown); contact through www.ioffer.com; ...