Warner Bros. Entertainment Inc. et al v WTV Systems, Inc.

Filing 66

STIPULATION for Permanent Injunction as to Entry of Consent Judgment filed by Plaintiffs Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Paramount Pictures Corporation, Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Warner Bros. Entertainment Inc.. (Attachments: # 1 Proposed Order)(Klaus, Kelly)

1
2
3
4
5
6
7
8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10

WESTERN DIVISION

11
12
13
14
15
16
17
18
19
20
21

WARNER BROS.
ENTERTAINMENT INC.,
COLUMBIA PICTURES
INDUSTRIES, INC., DISNEY
ENTERPRISES, INC., PARAMOUNT
PICTURES CORPORATION,
TWENTIETH CENTURY FOX FILM
CORPORATION, and UNIVERSAL
CITY STUDIOS PRODUCTIONS
LLLP,

CASE NO. 2:11-cv-02817-JFW-E
STIPULATION REQUESTING
ENTRY OF CONSENT JUDGMENT
AND PERMANENT INJUNCTION

Plaintiffs,
vs.
WTV SYSTEMS, INC. and WTV
SYSTEMS, LLC d/b/a ZEDIVA, and
VENKATESH SRINIVASAN,
Defendants.

22
23
24
25
26
27
28
15502473.1

STIP. RE ENTRY OF CONSENT JMT. AND
PERMANENT INJUNCTION
2:11-CV-02817-JFW-E

1

WHEREAS, on April 4, 2011, Plaintiffs Warner Bros. Entertainment Inc.,

2

Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Paramount Pictures

3

Corporation, Twentieth Century Fox Film Corporation, and Universal City Studios

4

Productions LLLP (collectively “Plaintiffs”) initiated the above-captioned action

5

against Defendants WTV Systems, Inc. WTV Systems, LLC, and Venkatesh

6

Srinivasan (collectively “Defendants”) (all collectively, the “Parties”);

7

WHEREAS, on August 1, 2011, the Court entered an Order Granting the

8

Motion of Plaintiffs for a Preliminary Injunction against Defendants, Dkt. No. 52

9

(“Preliminary Injunction Order”);

10
11
12

WHEREAS, on August 15, 2011, the Court entered a Preliminary Injunction,
Dkt. No. 58;
WHEREAS, the Parties have reached agreement for resolution of the action,

13

the full terms and conditions of which are set forth in the document entitled

14

“Settlement Agreement,” dated as of October 24, 2011 (the “Settlement

15

Agreement”); and

16

WHEREAS, the Parties’ Settlement Agreement is conditioned upon entry by

17

the Court of a stipulated consent judgment and permanent injunction and the

18

continuing jurisdiction of the Court on the terms and conditions set forth herein;

19
20
21
22
23
24
25
26
27
28
15502473.1

-1-

STIP. RE ENTRY OF CONSENT JMT. AND
PERMANENT INJUNCTION
2:11-CV-02817-JFW-E

1

THEREFORE, the Parties stipulate and agree that this Court has jurisdiction

2

to enter a stipulated consent judgment and permanent injunction on the following

3

terms and conditions and that the Court shall have continuing jurisdiction for

4

purposes of enforcing this consent judgment and permanent injunction and the

5

Parties’ Settlement Agreement and request that the Court enter the attached

6

[Proposed] Consent Judgment and Permanent Injunction Pursuant to Stipulation

7

(“Stipulated Consent Judgment and Permanent Injunction”).

8
9

IT IS SO STIPULATED.
Dated: October 27, 2011

10

Respectfully submitted:

11

MUNGER, TOLLES & OLSON LLP

12

By:

13

/s/ Kelly M. Klaus
KELLY M. KLAUS

14
15

Attorneys for Plaintiffs

16
DURIE TANGRI LLP

17

By:

18
19

/s/ Joseph C. Gratz
JOSEPH C. GRATZ

Attorneys for Defendants

20
21
22
23
24
25
26
27
28
15502473.1

-2-

STIP. RE ENTRY OF CONSENT JMT. AND
PERMANENT INJUNCTION
2:11-CV-02817-JFW-E