Amazon.com Inc et al v. Does 1-20 et al

Filing 31

PERMANENT INJUNCTION as to Defendant Justin Cook. Signed by Judge Tana Lin. (MJV)

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The Honorable Tana Lin

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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10 AMAZON.COM, INC., a Delaware corporation,
AMAZON.COM SERVICES LLC, a Delaware
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limited liability company, and AMAZON
12 TECHNOLOGIES, INC., a Nevada corporation,
Plaintiffs,

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v.

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Does 1-20, unknown parties doing business as
16 “CHIN CHOPA,” and the following individuals:
Justin Cook, Timothy Rodgers, Sai
17 Parvathareddy, Danielle Lantz, Brandon Wong,
Bharath Kumar Gandhe, Berkcan Turkmenoglu,
18 and Mike Ahlert,
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No. 2:24-cv-01083-TL
STIPULATED PERMANENT
INJUNCTION AS TO
DEFENDANT JUSTIN COOK
AND PROPOSED ORDER
NOTED FOR CONSIDERATION:
November 25, 2024
Without Oral Argument

Defendants.

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STIPULATION
Plaintiffs Amazon.com, Inc., Amazon.com Services LLC, and Amazon Technologies,

23 Inc. (together, “Amazon”), and Defendant Justin Cook and (collectively “Settling Parties”), by
24 and through Amazon and Cook’s respective counsel of record, notify the Court that the Settling
25 Parties have reached a settlement of all claims between them in this matter. Pursuant to the
26 terms of that settlement, the Settling Parties stipulate and agree to entry of the permanent
27 injunction below.
STIPULATED PERMANENT INJUNCTION (2:24-cv-01083-TL) - 1

Davis Wright Tremaine LLP

L AW O FFICE S
920 Fifth Avenue, Suite 3300
Seattle, WA 98104-1610
206.622.3150 main · 206.757.7700 fax

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DATED this 25th day of November, 2024.
Davis Wright Tremaine LLP
Attorneys for Plaintiffs

Justin Cook
Pro Se, Justin Cook

By s/ Bonnie MacNaughton___________
Bonnie MacNaughton, WSBA #36110
Tim Cunningham, WSBA #50224
920 Fifth Avenue, Suite 3300
Seattle, WA 98104-1610
Phone: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]

By s/ Justin Cook
Justin Cook
165 E Dougherty St,
Athens, GA 30601
Phone: [phone]
Email: [e-mail]

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PERMANENT INJUNCTION

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Pursuant to the above stipulation of the parties, IT IS HEREBY ORDERED that

15 Defendant Justin Cook, and his respective employees, agents, successors and assigns, and all
16 others in active concert or participation with him, are permanently enjoined and restrained from:
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Accessing and using, whether directly or indirectly via a third party, intermediary,

18 or proxy, Amazon.com, or any other Amazon online store around the world;
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2.

Exploiting or abusing Amazon’s ordering or return services;

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3.

Making false statements or misrepresentations to Amazon;

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4.

Engaging in any activity that defrauds Amazon into paying money or providing

22 replacement products for illegitimate returns;
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5.

Engaging in any scheme or malicious activity that interacts with Amazon; and

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6.

Knowingly and materially assisting or engaging any other person or business

25 entity in engaging in or performing any of the activities listed above.
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STIPULATED PERMANENT INJUNCTION (2:24-cv-01083-TL) - 2

Davis Wright Tremaine LLP

L AW O FFICE S
920 Fifth Avenue, Suite 3300
Seattle, WA 98104-1610
206.622.3150 main · 206.757.7700 fax

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The Court shall retain continuing jurisdiction over this matter for the limited purposes of

2 enforcing the terms of the Settling Parties’ settlement agreement and this Stipulated Permanent
3 Injunction.
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IT IS SO ORDERED.

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DATED: November 26, 2024.

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A

Tana Lin
United States District Judge

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STIPULATED PERMANENT INJUNCTION (2:24-cv-01083-TL) - 3

Davis Wright Tremaine LLP

L AW O FFICE S
920 Fifth Avenue, Suite 3300
Seattle, WA 98104-1610
206.622.3150 main · 206.757.7700 fax