Independence Energy Group LLC et al v. Arash Akhavan
Filing
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PERMANENT INJUNCTION filed by Judge Manuel L. Real (MD JS-6. Case Terminated) (pj)
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GREENBERG TRAURIG, LLP
VINCENT H. CHIEFFO (SBN 49069)
E-Mail: ChieffoV@gtlaw.com
NINA D. BOYAJIAN (SBN 246415)
E-Mail: BoyajianN@gtlaw.com
1840 Century Park East, 19th Floor
Los Angeles, CA 90067-2101
Telephone: 310-586-7700
Facsimile: 310-586-7800
JS-6
Attorneys for Plaintiffs
Independence Energy Group LLC and
Independence Energy Alliance LLC
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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WESTERN DIVISION
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INDEPENDENCE ENERGY GROUP
LLC, a Delaware Limited Liability
Company, and INDEPENDENCE
ENERGY ALLIANCE LLC, a Delaware
Limited Liability Company,
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PERMANENT INJUNCTION
Plaintiffs,
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CASE NO. CV 12-03275 R (AJWx)
[Concurrently Filed With Stipulation for
Entry of Permanent Injunction and
Dismissal of Action]
vs.
ARASH AKHAVAN,
Defendant.
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182,518,591 v2
Judge:
Date Filed:
Hon. Manuel L. Real
April 12, 2012
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Having considered the Stipulation for Entry of a Permanent Injunction and
2 Dismissal of Action submitted by Plaintiffs Independence Energy Group LLC
3 (“Independence Energy Group”) and Independence Energy Alliance LLC
4 (“Independence Energy Alliance”) (Independence Energy Group and Independence
5 Energy Alliance shall collectively be referred to hereafter as “Plaintiffs” or
6 “Independence Energy”) on the one hand, and Defendant Arash Akhavan (“Defendant”)
7 on the other hand:
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IT IS HEREBY ORDERED, ADJUDGED AND DECREED THAT:
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1.
Defendant, his successors, assigns, partners, agents, servants, employees,
10 any and all persons acting in concert or participation with Defendant, are immediately
11 and permanently enjoined from:
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(a)
using the “INDEPENDENCE ENERGY” and/or the “INDEPENDENCE
13 ENERGY ALLIANCE” names in any manner whatsoever, including, but not limited to,
14 the solicitation of potential energy customers;
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(b)
holding themselves out as the marketing arm of Independence Energy Group
16 (“Independence Energy Associates”), that contracts with independent sales associates;
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(c)
contacting any Independence Energy Associates with the intent of selling
18 customer accounts and/or leads; and/or
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(d)
assisting, aiding or abetting another person or business entity in engaging in
20 or performing any of the activities enumerated in subparagraphs (a) through (c) above.
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2.
This Court has personal jurisdiction over the parties with respect to this
22 Action and this Stipulated Permanent Injunction.
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3.
This Court has jurisdiction over the subject matter of this Action.
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4.
Each party shall bear its own attorney’s fees and costs in connection with
25 this Action; provided, however, that in the event any party files a motion, action or other
26 proceeding to enforce or interpret the terms of this Stipulated Permanent Injunction or the
27 Settlement Agreement, the prevailing party shall be entitled to recover all attorney’s fees
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182,518,591 v2
1 and other fees and costs incurred in connection with such a motion, action or
2 enforcement proceeding.
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5.
This Court shall retain jurisdiction over this matter and to the extent
4 necessary to interpret or enforce this Stipulated Permanent Injunction and to determine
5 any issues which may arise concerning this Stipulated Permanent Injunction or the
6 Settlement Agreement.
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6.
Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii), all other claims
8 in this Action are hereby dismissed with prejudice.
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IT IS SO ORDERED.
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12 DATED: May 29, 2012
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______________________________
Honorable Manuel L. Real
United States District Court
Central District of California
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182,518,591 v2
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