Compliance Solutions Occupational Trainers, Inc. v. Safety Helpers, LLC Delinquent April 1, 2012 et al

Filing 45

FINAL JUDGMENT AND ORDER OF STIPULATED PERMANENT INJUNCTION: All claims and counterclaims which were or could have been asserted by the parties herein are DISMISSED. By Judge Robert E. Blackburn on 10/9/2014. (alowe)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Judge Robert E. Blackburn
Civil Action No. 14-cv-00323-REB-KLM
COMPLIANCE SOLUTIONS OCCUPATIONAL TRAINERS, INC., a Colorado
corporation,
Plaintiff,
v.
SAFETY HELPERS, LLC, DELINQUENT APRIL 1, 2012, a Colorado limited liability
company, and
KYLE KNEBEL, an individual,
Defendants.

FINAL JUDGMENT AND ORDER OF STIPULATED PERMANENT INJUNCTION
Blackburn, J.
The matter is before the court on the parties’ Joint Motion For Entry of Final
Judgment and Order of Stipulated Permanent Injunction [#44],1 filed October 8,
2014. By this motion, the parties represent that they have settled this case and agreed
to the entry of a permanent injunction on the terms specified herein. I grant the motion,
enter the parties’ stipulated injunction, and order the entry of judgment accordingly.
THEREFORE, IT IS ORDERED as follows:
1. That the parties’ Joint Motion For Entry of Final Judgment and Order of
Stipulated Permanent Injunction [#44], filed October 8, 2014, is GRANTED;

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[#44]” is an example of the convention I use to identify the docket number assigned to a specific
paper by the court’s case management and electronic case filing system (CM/ECF). I use this convention
throughout this order.

2. That defendants Safety Helpers, LLC, a Colorado limited liability company,
and Kyle Knebel, an individual, and their representatives, agents, servants, employees,
attorneys, or anyone acting in active concert or participation with them, are permanently
ENJOINED, directly or indirectly, as follows:
a. That defendants will not imitate, copy, or make any use of plaintiff’s
trade name (“Compliance Solutions”) or plaintiff’s registered trademark
(“Compliance Solutions ‘Today’s Training… Tomorrow’s Solution’”) or any
confusingly similar trade name or trade mark, including, but not limited to:
operating websites with domain names containing the words “Compliance
Solutions” together; and maintaining online social media, business, or
networking accounts or websites under a name containing the words
“Compliance Solutions” together, including, but not limited to, blogs,
LinkedIn, Facebook, Twitter, Google Plus, Blogger.com, Manta, Chirrpy,
You Tube, and Zvents; and
b. That defendants will recall and destroy all marketing, advertising, and
promotional materials, online or in print, in the marketplace or in
defendants’ possession, custody, or control, that use the words
“Compliance Solutions” together as part of a trade name or trademark or
as part of a domain name or networking account or web site;
3. That defendants are expressly PERMITTED to continue to use “Compliance
Solvers by Safety Helpers LLC,” the domain name www.compliancesolvers.com, and
related social media outlets that utilize only the designation “compliance solvers”;

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provided, however, that in all other instances, defendants shall use the words
“compliance solvers” together only in conjunction with the phrase “by Safety Helpers
LLC”;
4. That all claims and counterclaims which were or could have been asserted by
the parties herein are DISMISSED;
5. That each party SHALL BEAR its own costs and attorney fees in connection
with this action; and
6. That this court SHALL RETAIN jurisdiction of this matter as may be
necessary or appropriate for the construction or the implementation of this Judgment,
for the modification of any of the injunctive provisions hereof, for enforcement of
compliance herewith, and for the punishment of violations hereof; and
7. That judgment SHALL ENTER on the terms of this order.
Dated October 9, 2014, at Denver, Colorado.
BY THE COURT:

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