KENNETH E. KELLER (SBN 71450), ANNE E. KEARNS (SBN 183336), KELLER, SLOAN, ROMAN & HOLLAND LLP, San Francisco, California, Attorneys for Plaintiff CHANEL, INC.
[PROPOSED] ORDER GRANTING PLAINTIFF'S MOTION FOR FINAL DEFAULT JUDGMENT;
PROPOSED] JUDGMENT AND PERMANENT INJUNCTION
RICHARD SEEBORG, District Judge.
THIS MATTER having come before the Court upon motion by Plaintiff, Chanel, Inc. (Chanel") for entry of a final default judgment of its claims against Defendants glamorme.storenvy.com (Defendant 4) and lccboutique.storenvy.com (Defendant 6), partnerships or unincorporated associations (collectively "Defendants") pursuant to Rule 55(b)(2) of the Federal Rules of Civil Procedure; and the Court having considered the moving papers and there being no opposition thereto;
IT IS HEREBY ORDERED that Chanel's Motion for Final Default Judgment is GRANTED, and judgment is hereby entered in favor of Plaintiff, Chanel, Inc., a New York corporation, with its principal place of business in the United States located at Nine West 57th Street, New York, New York, 10019, and against Defendants glamorme.storenvy.com and lccboutique.storenvy.com on all Counts of the Complaint as follows:
(1) Permanent Injunctive Relief:
Defendants and their respective officers, agents, servants, employees and attorneys, and all persons acting in concert and participation with Defendants are hereby permanently restrained and enjoined from:
(a) manufacturing or causing to be manufactured, importing, advertising, or promoting, distributing, selling or offering to sell counterfeit and infringing goods bearing Chanel's trademarks identified in Paragraph 15 of the Complaint (the "Chanel Marks") (ECF 1);
(b) using the Chanel Marks in connection with the sale of any unauthorized goods;
(c) using any logo, and/or layout which may be calculated to falsely advertise the services or products of Defendants offered for sale or sold via the e-stores identified on Schedule "A" hereto (collectively the "Subject E-Store Names") and/or any other website or business, as being sponsored by, authorized by, endorsed by, or in any way associated with Chanel;
(d) falsely representing themselves as being connected with Chanel, through sponsorship or association;
(e) engaging in any act which is likely to falsely cause members of the trade and/or of the purchasing public to believe any goods or services of Defendants offered for sale or sold via the Subject E-Store Names, and/or any other website, e-store, or business are in any way endorsed by, approved by, and/or associated with Chanel;
(f) using any reproduction, counterfeit, copy, or colorable imitation of the Chanel Marks in connection with the publicity, promotion, sale, or advertising of any goods sold by Defendants via the Subject E-Store Names, and/or any other website, e-store, or business, including, without limitation, cases for telephones and protective covers for portable electronic devices, including cell phones, bearing the Chanel Marks;
(g) affixing, applying, annexing or using in connection with the sale of any goods, a false description or representation, including words or other symbols tending to falsely describe or represent goods offered for sale or sold by Defendants via the Subject E-Store Names, and/or any other website, ...