Public Engines v. Reportsee

Filing 61

Stipulated MOTION for Permanent Injunction filed by Plaintiff Public Engines. (Attachments: # 1 Text of Proposed Order)(Shaughnessy, Todd) Modified on 12/6/2010: corrected motion relief (alt)

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Public Engines v. Reportsee Doc. 61 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 AND JOINT MOTION FOR ENTRY OF PERMANENT INJUNCTION Case No. 2:10-cv-317 Honorable Tena Campbell Plaintiff Public Engines, Inc. ("Public Engines") and Defendant ReportSee, Inc. ("ReportSee"), have entered into a settlement of the above-captioned lawsuit, one requirement of which is the entry of a Stipulated Permanent Injunction consistent with the Stipulated 12200205 Preliminary Injunction entered by the Court on June 24, 2010, and the Seventh Claim for Relief in Public Engines' complaint. Pursuant to an Addendum to Settlement Agreement and Mutual Release, Colin, Inc., an owner and affiliate of ReportSee, has each consented to the entry of the attached Stipulated Permanent Injunction. The parties waive the entry of findings of fact and conclusions of law, to the extent such may be required by Rules 52 or 65 of the Federal Rules of Civil Procedure. Based on the foregoing, the parties jointly move the Court to enter the Stipulated Permanent Injunction appended hereto. Dated this 1st day of December, 2010. Snell & Wilmer L.L.P. /s/ Todd M. Shaughnessy Alan L. Sullivan Todd M. Shaughnessy J. Elizabeth Haws Attorneys for Plaintiff Public Engines, Inc. Bowie & Jensen, LLC /s/ Joshua A. Glikin (signed with permission) Joshua A. Glikin Attorneys for Defendant ReportSee, Inc. Bowie & Jensen, LLC /s/ Joshua A. Glikin (signed with permission) Joshua A. Gliken Attorneys for Colin, Inc. 12200205 2

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