Case Information
*1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION
AMAZON.COM, INC., a Delaware
corporation; AMAZON.COM
SERVICES LLC, a Delaware limited
liability company; and AMAZON CIVIL ACTION FILE TECHNOLOGIES, INC., a Nevada
Corporation, NO.: 1:23-cv-5175-ELR
Plaintiffs, JOINT MOTION AND STIPULATION FOR v. PERMANENT INJUNCTION DIGITAL HOME SOLUTIONS LLC,
a Georgia corporation; JOTI APPLEE
DHILLON, an individual; and DOES
1-50, unknown individuals and entities,
Defendants. *2 ORDER ENTERING PERMANENT INJUNCTION
Pursuant to the above joint motion and stipulation for permanent injunction of the parties, IT IS HEREBY ORDERED that Defendants Joti Applee Dhillon and Digital Home Solutions LLC, and their directors, principals, officers, successors and assigns, and all others in active concert or participation with them, are enjoined and restrained from:
1. Using any trademarks registered by or otherwise associated with Amazon (the “Amazon Trademarks”) or any simulation, reproduction, counterfeit, copy, or colorable imitation of them, in any manner in connection with any advertising, marketing, offer for sale, promotion, display, publication, website, email, or software, without Amazon’s prior written consent (which it has sole discretion to provide or withhold for any reason);
2. Using any false designation of origin or false or misleading description or representation that can or is likely to lead the trade or public or individuals erroneously to believe that any website, email, advertisement, pop-up, or other marketing material has been produced, distributed, displayed, licensed, sponsored, approved or authorized by or for Amazon, when such is not true in fact;
3. Engaging in any other activity constituting an infringement or dilution of any of the Amazon Trademarks, or of Amazon’s rights in, or right to use or to exploit, such trademarks or services marks;
4. Engaging in any other conduct involving the unauthorized use of A mazon Trademarks or other indicia of Amazon’s brand to defraud or otherwise obtain payment from Amazon customers or other members of the public; and
5. Aiding, assisting, or abetting any other person or business entity in engaging in or performing any of the activities listed above.
DATED THIS 21st day of March , 2024.
_________________________________ The Honorable Eleanor L. Ross United State District Court, Northern District of Georgia *4 Respectfully submitted this 19th day of March, 2024.
DAVIS WRIGHT TREMAINE LLP LEXERO LLC /s/ Jaime Drozd /s/ Eric Menhart Bonnie E. MacNaughton* Eric Menhart* Jaime Drozd* 512 C. St. NE 920 Fifth Avenue, Suite 3300 Washington, DC 20002 Seattle, WA 98104 Phone: (855) 453-9376 Phone: (206) 622-3150 Fax: (855) 453-9376 Fax: (206) 757-7700 eric.menhart@lexero.com bonniemacnaughton@dwt.com
jaimedrozd@dwt.com *pro hac vice forthcoming *pro hac vice Attorney for Defendants ROBBINS ALLOY BELINFANTE
LITTLEFIELD LLC
/s/ Craig G. Kunkes
Craig G. Kunkes
Georgia Bar No. 963594
Michael D. Forrest
Georgia Bar No. 974300
500 14th Street, NW
Atlanta, Georgia 30318
Phone: (678) 701-9381
ckunkes@robbinsfirm.com
mforrest@robbinsfirm.com
Attorneys for Plaintiffs