Synopsys, Inc. v. Library Technologies, Inc.
Filing
151
ORDER RE SETTLEMENT AND DISMISSAL OF CASE WITH PREJUDICE. Signed by Judge Charles R. Breyer on 8/2/2022. (ls, COURT STAFF) (Filed on 8/2/2022)
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DENISE M. MINGRONE (SBN 135224)
dmingrone@orrick.com
ROBERT L. URIARTE (SBN 258274)
ruriarte@orrick.com
ORRICK, HERRINGTON & SUTCLIFFE LLP
1000 Marsh Road
Menlo Park, CA 94025-1015
Telephone:
+1 650 614 7400
Facsimile:
+1 650 614 7401
Attorneys for Plaintiff,
SYNOPSYS, INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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SYNOPSYS, INC.,
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Plaintiff,
v.
Case No. 3:20-cv-07014-CRB
[PROPOSED] ORDER RE
SETTLEMENT AND DISMISSAL OF
CASE WITH PREJUDICE
LIBRARY TECHNOLOGIES, INC., a
California corporation, and DOES 1-10,
inclusive,
Defendants.
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ORRICK, HERRINGTON &
SUTCLIFFE LLP
[PROPOSED] ORDER RE
SETTLEMENT AND DISMISSAL
3:20-CV-07014-CRB
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WHEREAS Plaintiff Synopsys, Inc. (“Plaintiff”) and Defendant Library Technologies,
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Inc., (“Defendant”) are parties to a civil action entitled Synopsys, Inc. v. Library Technologies,
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Inc., et al., in the United States District Court for the Northern District of California, Case No.
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3:20-cv-07014-CRB (the “Litigation”);
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WHEREAS Plaintiff has alleged that the Defendant violated the Digital Millennium
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Copyright Act (“DMCA”) and Breach of the Parties Contracts and Defendant denies these
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allegations; and
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NOW THEREFORE, in consideration of the foregoing and in consideration of the
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payments, promises and mutual undertakings set forth herein and in the Parties’ Confidential
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Settlement Agreement (“Agreement”) executed by Plaintiff and Defendant and incorporated
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herein by this reference, the sufficiency of which is hereby acknowledged, the Court orders as
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follows.
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1. Defendant, its representatives, officers, agents, directors, affiliates, servants,
employees, contractors, and consultants and all persons acting in concert or
participation with it agree they have ceased accessing any Synopsys applications or
any electronic files associated with the use of or access to any Synopsys applications,
including but not limited to counterfeit license key files. Defendant, its
representatives, officers, agents, directors, affiliates, servants, employees, consultants
and all persons acting in concert or participation with it including employees and
independent contractors, are permanently enjoined from directly or indirectly
accessing, using, transferring, or copying, in any way, any Synopsys software without
authorization from Synopsys.
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2. Defendant shall certify with the court that all Synopsys software located on devices
have within Defendants’ control been removed, including devices within the control
of Defendant’s representatives, officers, agents, directors, affiliates, servants,
employees, consultants and all persons acting in concert or participation with it
including employees and independent contractors.
3. This Court shall retain jurisdiction of this matter to enforce the terms of the
Agreement without the necessity of any party’s filing a separate lawsuit to do so. In
any contest over an alleged violation of this Agreement, the prevailing party shall
recover its reasonable attorneys’ fees and costs.
4. All claims filed herein are hereby dismissed with prejudice. Each party shall bear its
own fees and costs, except as specified in the Parties’ Confidential Settlement
Agreement.
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ORRICK, HERRINGTON &
SUTCLIFFE LLP
-1-
[PROPOSED] ORDER RE SETTLEMENT
AND DISMISSAL
3:20-CV-07014-CRB
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IT IS SO ORDERED.
August 2, 2022
Dated: _____________________
HONORABLE CHARLES R. BREYER
United States District Judge
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ORRICK, HERRINGTON &
SUTCLIFFE LLP
4162-5212-1148.1
-2-
[PROPOSED] ORDER RE SETTLEMENT
AND DISMISSAL
3:20-CV-07014-CRB
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