Public Engines v. Reportsee

Filing 48

Stipulated MOTION for Preliminary Injunction filed by Plaintiff Public Engines. (Attachments: # 1 Text of Proposed Order)(Shaughnessy, Todd)

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Alan L. Sullivan (3152) Todd M. Shaughnessy (6651) J. Elizabeth Haws (11667) Snell & Wilmer L.L.P. 15 West South Temple, Suite 1200 Beneficial Tower Salt Lake City, Utah 84101-1004 Telephone: (801) 257-1900 Facsimile: (801) 257-1800 Mark Lambert (Cal. Bar No. 197410) Mark Weinstein (Cal Bar No. 193043) Cooley Godward Kronish, LLP Five Palo Alto Square Palo Alto, California 94306-2109 Telephone: (650) 843-5003 Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION PUBLIC ENGINES, INC., a Delaware Corporation, Plaintiff, vs. REPORTSEE, INC., a Delaware Corporation, Defendant. STIPULATION FOR ENTRY OF PRELIMINARY INJUNCTION Case No. 2:10-cv-317 Honorable Tena Campbell Plaintiff Public Engines, Inc. ("Public Engines") and Defendant ReportSee, Inc. ("ReportSee"), through counsel, have agreed to the entry of a Stipulated Preliminary Injunction in the form appended to and filed with this stipulation. ReportSee and Public Engines waive the entry of findings of fact and conclusions of law, to the extent such may be required by Rules 52 11592428 or 65 of the Federal Rules of Civil Procedure. Although ReportSee stipulates to the entry of the Preliminary Injunction, it does so without admitting liability for any of the claims alleged in Public Engines' Complaint. Additionally, Public Engines reserves the right to obtain an award of its attorneys' fees and costs, damages, or any other relief to which it may be entitled as part of a final judgment in this matter. Based on the foregoing, the parties respectfully request that the Court enter the Preliminary Injunction and cancel the hearing on Plaintiff's Motion for Preliminary Injunction, currently scheduled for June 28, 2010, at 10:00 a.m. Dated this 24th day of June, 2010. Snell & Wilmer L.L.P. /s/ Alan L. Sullivan Alan L. Sullivan Todd M. Shaughnessy J. Elizabeth Haws Attorneys for Plaintiff Bowie & Jensen, LLC /s/ Josh A. Glikin (signed with permission) Joshua A. Glikin Attorney for Defendant 11592428 2

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