WILLIAM J. BRUTOCAO, (SBN 75959) WILLIAM D. BOWEN, (SBN 254398) SHELDON MAK & ANDERSON PC, Pasadena, CA. Attorneys for Defendants and Counterclaimants WISE UNICORN INDUSTRIAL, LTD.; WISE UNICORN CRAFTS & GIFTS (HUI YANG) INDUSTRIAL, LTD.; and UNICORN STUDIO INC.
[PROPOSED] PERMANENT INJUNCTION
MARGARET M. MORROW, District Judge.
In accordance with the Stipulation for Permanent Injunction entered into by and between Plaintiff and Counter-Defendant ThinkBronze LLC ("ThinkBronze"), Counter-Defendants Steve Marvisi, Parviz Noghrey, and European Bronze (the "ThinkBronze Parties"), third party Felicity International Trading, Inc. ("Felicity"), and Defendants and Counterclaimants Wise Unicorn Industrial, Ltd., Wise Unicorn Crafts & Gifts Industrial, Ltd., and Unicorn Studio, Inc. (the "Unicorn Parties") (collectively, the "Parties") entered into pursuant to a the Parties settlement of this matter, the Court orders as follows:
1. Counter-defendants Steve Marvisi, Parviz Noghrey, ThinkBronze LLC, European Bronze, and third party Felicity International Trading, Inc., their officers, agents, employees, and those acting in concert or conspiracy with them, including their customers and suppliers, are hereby permanently restrained and enjoined from:
(a) manufacturing, copying, importing, offering for sale, or selling any of the sculptures identified in Exhibit A to the First Amended Counterclaim in this case (the "Subject Sculptures"), or any item substantially indistinguishable from the Subject Sculptures; the term "Subject Sculptures" expressly excludes items identified as numbers 56 (Cupid and Psyche) and 65 (Napoleon) in Exhibit A;
(b) copying, duplicating, selling, renting, marketing, leasing or distributing any unauthorized copies of the Subject Sculptures currently in their possession, custody or control; however, the affected parties may, within six months of the date this injunction is entered, return said items currently in their possession, custody or control to the manufacturers or suppliers from whom they purchased said items, or destroy the items;
(c) manufacturing, importing, offering for sale, or selling any merchandise bearing the trademark "Veronese" or any colorable imitation thereof.
2. This Court retains jurisdiction over the ThinkBronze Parties and Felicity for the sole purpose of enforcing the permanent injunction as set forth herein;
3. This Action, including the Unicorn Parties' First Amended Counterclaim and Third Party Complaint are ...