DISH Network L.L.C. et al v. Lau
Filing
9
MOTION by Defendant Edmund Lau for judgment Agreed Final Judgment and Permanent Injunction (Niemi, Amelia)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
DISH NETWORK L.L.C.,
ECHOSTAR TECHNOLOGIES L.L.C.,
and NAGRASTAR LLC,
Plaintiffs,
v.
EDMUND LAU,
Defendant.
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Case No. 1:14-cv-04292
JOINT MOTION FOR ENTRY OF AGREED FINAL JUDGMENT
AND PERMANENT INJUNCTION
Plaintiffs DISH Network L.L.C., EchoStar Technologies L.L.C., and NagraStar LLC
(collectively, “DISH Network”), and Defendant Edmund Lau, respectfully file this joint motion
for entry of an agreed final judgment and permanent injunction, and in support state:
I.
NATURE OF THE CASE
DISH Network brought this action claiming that Defendant unlawfully circumvented the
DISH Network security system and intercepted DISH Network satellite television programming.
Defendant is alleged to have accomplished this in part by subscribing to a pirate television service
known as IKS Rocket. DISH Network claims that Defendant used the IKS Rocket service to obtain
control words or keys necessary to decrypt DISH Network’s satellite signal and view copyrighted
DISH Network programming without authorization from and without payment to DISH Network.
II.
RELIEF REQUESTED
The parties stipulate that a final judgment should be entered in favor of DISH Network on
Count I alleging violations of the Digital Millennium Copyright Act, 17 U.S.C. § 1201(a)(1),
Count II alleging violations of the Federal Communications Act, 47 U.S.C. § 605(a), and Count
III alleging violations of the Electronic Communications Privacy Act, 18 U.S.C. §§ 2511(1)(a) and
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2520. The parties have agreed to a confidential settlement sum and therefore do not request an
award of damages. The parties do, however, stipulate to the entry of a permanent injunction, which
is authorized by Counts I-III. See 17 U.S.C. § 1203(b)(1); 47 U.S.C. § 605(e)(3)(B)(i); 18 U.S.C.
§ 2520(b)(1). A proposed final judgment and permanent injunction has been submitted.
Dated: August 11, 2014
Respectfully submitted,
By: _/s/ David M. Lewin_______________
David M. Lewin
Lewin Law Group
175 W. Jackson Boulevard, Suite 1600
Chicago, IL 60604-2827
Telephone: (312) 540-7556
Facsimile: (312) 540-0578
Attorney for Plaintiffs DISH Network
L.L.C., EchoStar Technologies L.L.C.,
and NagraStar LLC.
By: /s/ Amelia Niemi
Amelia Niemi
Antonelli Law, Ltd.
100 North LaSalle Street, Suite 2400
Chicago, Illinois 60602
Telephone: (312) 201-8310
Facsimile: (888) 211-8624
Attorney for Defendant Edmund Lau
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