Google v. Pacific Webworks
Stipulated MOTION for Entry of Judgment and Order For Permanent Injunction Against Defendant Pacific Webworks, Inc., et al. filed by Plaintiff Google. (Attachments: # 1 Exhibit A - Text of Proposed Order)(Haley, George)
HOLME ROBERTS & OWEN LLP Scott R. Bialecki (Pro Hac Vice) firstname.lastname@example.org Roger R. Myers (Pro Hac Vice) email@example.com George M. Haley, #1302 firstname.lastname@example.org Blaine J. Benard, #5661 email@example.com Craig Buschmann, #10696 firstname.lastname@example.org 299 South Main Street, Suite 1800 Salt Lake City, UT 84111-2263 Telephone: (801) 521-5800 Facsimile: (801) 521-9639 Attorneys for Plaintiff GOOGLE INC. IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION GOOGLE INC., a Delaware corporation, Plaintiff,
Case No. 2:09-cv-1068-BSJ JOINT MOTION FOR ENTRY OF STIPULATED FINAL JUDGMENT AND ORDER FOR PERMANENT INJUNCTION AGAINST DEFENDANT PACIFIC WEBWORKS, INC. ET AL. Judge Bruce S. Jenkins
PACIFIC WEBWORKS, INC., a Nevada corporation, BLOOSKY INTERACTIVE, LLC, a Nevada limited liability company, and DOES 2-50, Defendants.
Plaintiff Google Inc. ("Google") and Defendant Pacific WebWorks, Inc. ("PWW"), through their respective undersigned counsel, hereby jointly move for the entry of the Stipulated Final Judgment and Order for Permanent Injunction against Defendant Pacific WebWorks, Inc. et al. ("Judgment") that has been filed herewith.
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As Google and PWW have resolved their dispute, it is in the interest of judicial economy and good cause exists to enter this Judgment against PWW and its related entities, all of which have been represented by counsel and understand the terms of the Judgment (as evidenced by their signatures to the proposed Judgment). The Judgment will dismiss PWW from the pending matter and allow Google to pursue the remaining defendants in the case. To the extent that the Court deems it necessary to clarify any issues prior to the entry of the proposed Judgment, the Parties jointly request a hearing on such issues. WHEREFORE, Google and PWW jointly request that the Court enter the proposed Stipulated Final Judgment and Order for Permanent Injunction against Defendant Pacific WebWorks, Inc. et al. in the form submitted herewith.
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Submitted this 24th day of May, 2010. BY: /s/ George M. Haley______________ HOLME ROBERTS & OWEN LLP Scott R. Bialecki (Pro Hac Vice) Roger R. Myers (Pro Hac Vice) George M. Haley, #1302 Blaine J. Benard, #5661 Craig Buschmann, #10696 ATTORNEYS FOR GOOGLE INC. BY:/s/ Jeffery M. Lillywhite______________ Daniel W. Jackson, #1633 Jeffery M. Lillywhite, #8920 Attorneys For Defendant PACIFIC WEBWORKS, INC., and TRADEWORKS MARKETING, INC., INTELLIPAY, INC., FUNDWORKS INC., PACIFIC WEBWORKS INTERNATIONAL, LTD., FIRST PACIFIC PROCESSING, LTD., THE QUAD GROUP, LLC, WORLD COMMERCE NETWORK, LLC, ABANDO, LLC, BLOGTUBE, LLC, CHATTAG, LLC, CHATTEROPIA, LLC, EDGESHOTS, LLC, FOURBRIDGE, LLC, JAXCAT, LLC, ZOOVEO, LLC, TQG INTERNATIONAL, LTD., SERIES 5 MEDIA, LLC, M5 MARKETING, LLC, BSQUARED MEDIA LLC, AMPERSAND MARKETING, LLC, 50FIRST MARKETING, LLC, CHRISTIAN R. LARSEN, KENNETH W. BELL, ROBERT BRETT BELL, ROBERTA L. (ROBBI) BELL, JENNIFER LARSEN, JILLIAN BELL, WILLIAM MARC BELL and ASHLEY A. BELL
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