1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 v. Century 21 Real Estate Corporation, a Delaware corporation doing business in the State of Arizona, Does(s) 1 through 100, Counterdefendants. WHEREAS, the parties have submitted a stipulation for entry of permanent injunction and to dismiss Century 21 Real Estate Corporation's claims without prejudice, and good cause appearing: Daryush B. Motlagh and Jennifer Motlagh, husband and wife; Integrity Assurance, Inc., an Arizona corporation, Counterclaimants, v. Daryush B. Motlagh and Jane Doe Motlagh, husband and wife; Integrity Assurance, Inc. an Arizona corporation, Defendants. PERMANENT INJUNCTION UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Century 21 Real Estate Corporation, Plaintiff, No. CIV 03 2353-PHX-DGC
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IT IS ORDERED that Defendants and their officers, directors, employees, agents, members, affiliates, subsidiaries, officers, independent contractors, and all those who act in concert or participation with them and/or at their direction, instruction or control (collectively, "Defendants"), are hereby enjoined and restrained from marketing, promoting or providing services at their business, such that the origin of Defendants' services are falsely designated as being those of CENTURY 21, or designated in a manner that is confusingly similar to those trademarks, trade names and/or service marks of CENTURY 21; IT IS FURTHER ORDERED that the above injunction encompasses, but is not limited to, the use of any and all print or telecommunications advertisements, directories, drafts, labels, signs, signage, billboards or roadway signs, plaques, flyers, stationery, envelopes, applications, booklets, brochures, catalogues, circulars, pamphlets, periodicals, bulletins, instructions, minutes, other communications, purchase orders, contracts, agreements, options to purchase, deeds, memoranda of agreements, assignments, licenses, books of account, orders, accounts, working papers, furnishings or equipment at the Defendants' business that bear the CENTURY 21 trade names, trademarks or service marks ("CENTURY 21 Marks") and/or plans that employ or relate in any manner to the CENTURY 21 trade names, trade marks and/or service marks, or other names and marks confusingly similar to the CENTURY 21 trade names, trademarks and/or service marks; Dated this 14th day of November, 2006.
-1Case 2:03-cv-02353-DGC Document 93 Filed 11/15/2006 Page 2 of 2