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

Filing 33

PERMANENT INJUNCTION as to Defendant Timothy Rodgers. 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 TIMOTHY
RODGERS AND PROPOSED
ORDER
NOTED FOR CONSIDERATION:
November 25, 2024
Without Oral Argument

Defendants.

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

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

STIPULATION

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

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3 Inc. (together, “Amazon”), and Defendant Timothy Rodgers and (collectively “Settling Parties”),
4 by and through Amazon and Rodgers’s respective counsel of record, notify the Court that the
5 Settling Parties have reached a settlement of all claims between them in this matter. Pursuant to
6 the terms of that settlement, the Settling Parties stipulate and agree to entry of the permanent
7 injunction below.
DATED this 25th day of November, 2024.

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Davis Wright Tremaine LLP
Attorneys for Plaintiffs

Timothy Rodgers
Pro Se, Timothy Rodgers

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]
[e-mail]
[e-mail]

By s/ Timothy Rodgers
Timothy Rodgers
500 Dutchview Drive
Atlanta, GA 30349
Phone: [phone]
[e-mail]

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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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PERMANENT INJUNCTION

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

3 Defendant Timothy Rodgers, and his respective employees, agents, successors and assigns, and
4 all others in active concert or participation with him, are permanently enjoined and restrained
5 from:
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1.

Accessing and using, whether directly or indirectly via a third party, intermediary,

7 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

11 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

14 entity in engaging in or performing any of the activities listed above.
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The Court shall retain continuing jurisdiction over this matter for the limited purposes of

16 enforcing the terms of the Settling Parties’ settlement agreement and this Stipulated Permanent
17 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) - 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