Verizon California Inc. et al v. Navigation Catalyst Systems, Inc. et al.

Filing 22

NOTICE OF MOTION AND MOTION for Preliminary Injunction re: registration of domain names filed by Plaintiffs/Counterclaim-Defendants Verizon Licensing Company, Verizon California Inc., Verizon Trademark Services LLC. Motion set for hearing on 6/30/2008 at 10:00 AM before Judge Audrey B. Collins. (Attachments: # 1 Appendix Memorandum of Points & Authorities in Support of Motion for Preliminary Injunction, # 2 Declaration Declaration of Janis M. Manning in Support of Motion for Preliminary Injunction, # 3 Exhibit Exh. A to Manning Declaration, # 4 Exhibit Exh. B to Manning Declaration, # 5 Exhibit Exh. C to Manning Declaration, # 6 Exhibit Exh. D to Manning Declaration, # 7 Exhibit Exh. E to Manning Declaration, # 8 Exhibit Exh. F to Manning Declaration, # 9 Declaration Declaration of Anne F. Bradley in Support of Motion for Preliminary Injunction, # 10 Exhibit Exh. A to Bradley Declaration, # 11 Exhibit Exh. B to Bradley Declaration, # 12 Exhibit Exh. C to Bradley Declaration, # 13 Exhibit Exh. D-Pt.1 to Bradley Declaration, # 14 Exhibit Exh. D-Pt.2 Bradley Declaration, # 15 Exhibit Exh. D-Pt.3 Bradley Declaration, # 16 Exhibit Exh. D-Pt.4 to Bradley Declaration, # 17 Exhibit Exh. D-Pt.5 to Bradley Declaration, # 18 Exhibit Exh. E to Bradley Declaration, # 19 Exhibit Exh. F to Bradley Declaration, # 20 Exhibit Exh. G to Bradley Declaration, # 21 Exhibit Exh. H to Bradley Declaration, # 22 Exhibit Exh. I to Bradley Declaration, # 23 Exhibit Exh. J. to Bradley Declaration, # 24 Exhibit Exh. K to Bradley Declaration, # 25 Proposed Order Proposed Order for Preliminary Injunction)(Steele, David)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CHRISTIE, PARKER & HALE, LLP DAVID J. STEELE, CA Bar No. 209797 Email: david.steele@cph.com CHRISTIE, PARKER & HALE, LLP 3501 Jamboree Road, Suite 6000-North Tower Newport Beach, CA 92660 Telephone: (949) 476-0757 Facsimile: (949) 476-8640 HOWARD A. KROLL, CA Bar No. 100981 Email: howard.kroll@cph.com CHRISTIE, PARKER & HALE, LLP 350 W. Colorado Boulevard, Suite 500 Pasadena, CA 91105 Telephone: (626) 795-9900 Facsimile: (626) 577-8800 JOHN THORNE (admitted pro hac vice) Email: john.thorne@verizon.com VERIZON CORPORATE SERVICES GROUP INC. SARAH B. DEUTSCH (admitted pro hac vice) Email: sarah.b.deutsch@verizon.com VERIZON CORPORATE SERVICES CORP. 1515 North Court House Road, Suite 500 Arlington, VA 22201 Telephone: (703) 351-3044 Facsimile: (703) 351-3670 Attorneys for Plaintiffs VERIZON CALIFORNIA INC. VERIZON TRADEMARK SERVICES LLC VERIZON LICENSING COMPANY UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION VERIZON CALIFORNIA INC.; VERIZON TRADEMARK SERVICES LLC; and VERIZON LICENSING COMPANY, Plaintiffs, vs. NAVIGATION CATALYST SYSTEMS, INC.; and BASIC FUSION, INC., Defendants. AND RELATED COUNTERCLAIMS. -1Case No. CV 08-02463 ABC (Ex) NOTICE OF MOTION AND MOTION FOR PRELIMINARY INJUNCTION DATE: June 30, 2008 TIME: 10:00 a.m. CTRM: 680 HON. AUDREY B. COLLINS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CHRISTIE, PARKER & HALE, LLP TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on June 30, 2008 at 10:00 a.m., or as soon thereafter as this matter may be heard, in Courtroom 680 of the United States District Court for the Central District of California, Western Division, located at 255 East Temple Street, Los Angeles, California 90012 before the Honorable Audrey B. Collins, Plaintiffs Verizon California Inc., Verizon Trademark Services LLC, and Verizon Licensing Company (collectively "Plaintiffs") will bring on for hearing their Motion for a Preliminary Injunction. Plaintiffs will move and hereby do move this Court, pursuant to Rule 65 of the Federal Rules of Civil Procedure, for an order preliminarily enjoining Defendants Navigation Catalyst Systems, Inc. and Basic Fusion, Inc. and their officers, agents, servants, employees, and attorneys, and those persons in active concert or participation with them who receive actual notice of the preliminary injunction order, from: 1. Registering or using any domain name that is identical or confusingly similar to the trade names and trademarks VERIZON, VERIZON WIRELESS, VZ, VZACCESS, VZEMAIL, VZGLOBAL, VZVOICE, VZW, FIOS, VERIZON FIOS; 2. 3. Registering any domain name using an automated process; and Assisting, aiding or abetting any other person or business entity in engaging in or performing any of the activities referred to in subparagraphs 1 and 2, above. This Motion is based upon the accompanying Memorandum of Points and Authorities, the Declarations of Anne F. Bradley and Janis M. Manning, the /// /// /// -2- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CHRISTIE, PARKER & HALE, LLP complete record of this action and such other and further oral and documentary evidence as may be submitted in connection with this Motion. DATED: June 9, 2008 Respectfully submitted, CHRISTIE, PARKER & HALE, LLP By /s/David J. Steele David J. Steele Attorney for Plaintiffs VERIZON CALIFORNIA INC.; VERIZON TRADEMARK SERVICES LLC; and VERIZON LICENSING COMPANY LLB IRV1114122.1-*-06/9/08 3:13 PM -3-

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