Principal Financial Services, Inc. et al v. GoDaddy.com, LLC et al, No. 1:2014cv01283 - Document 39 (N.D. Ill. 2015)
Court Description: MOTION by Plaintiffs Principal Financial Services, Inc., Principal Global Investors, LLC for judgment (Attachments: # 1 Text of Proposed Order Proposed Final Judgment)(Biagi, Richard)
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Principal Financial Services, Inc. et al v. GoDaddy.com, LLC et al Doc. 39 Att. 1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION PRINCIPAL FINANCIAL SERVICES, INC., an Iowa Corporation, and PRINCIPAL GLOBAL INVESTORS, LLC A Delaware Limited Liability Company, Plaintiffs, v. MAURICIO IZQUIERDO an individual, and John Doe, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No.: 1:14-CV-01283 Honorable Harry D. Leinenweber [PROPOSED] FINAL JUDGMENT This action having been commenced by Plaintiffs PRINCIPAL FINANCIAL SERVICES, INC. and PRINCIPAL GLOBAL INVESTORS, LLC, (collectively “Plaintiffs”) against Defendant MAURICIO IZQUIERDO (“Defendant”), and default having been entered against Defendant MAURICIO IZQUIERDO, the Court being fully advised in the premises, finds as follows: FINDINGS OF FACT AND CONCLUSIONS OF LAW 1. This Court has jurisdiction over the subject matter of the Complaint in this action based on 28 U.S.C. §§ 1332, 1367 and 1338 and 15 U.S.C. § 1121. This Court has personal jurisdiction over the Defendant. Venue is proper within this judicial district. Dockets.Justia.com 2. This Court has personal jurisdiction over Defendant pursuant to the Illinois long-arm statute, 735 Ill. Comp. Stat. 5/2-209 et seq. and such assertion is in accordance with the Due Process Clause of the Fourteenth Amendment of the United States Constitution. 3. This is an action for trademark infringement, unfair competition, deceptive trade practices, cybersquatting, and trademark dilution which arises under the Lanham Act, Title 15, United States Code 1051, et seq., and the statutes and common laws of the State of Illinois. 4. Plaintiff PRINCIPAL GLOBAL INVESTORS, LLC is a limited liability company duly organized and existing under the laws of the State of Delaware and located at 711 High Street, Des Moines, Iowa 50392 (hereinafter “Plaintiff” and/or “PGI”). PRINCIPAL GLOBAL INVESTORS, LLC is an indirect wholly owned subsidiary of PRINCIPAL FINANCIAL SERVICES, INC (herein after “PFSI”). Plaintiff PFSI is the owner of the famous family of PRINCIPAL and PRINCIPAL formative trademarks (“PRINCIPAL Family of Marks”) in the United States and throughout the world. PFSI, through its various member companies and licensees, uses its famous family of PRINCIPAL and PRINCIPAL formative trademarks in interstate commerce and throughout the world in connection with a variety of services including, but not limited to, real estate, investment, investment management, investment advisory, lending, insurance, underwriting, employee benefits, estate planning, tax consultation, financial, banking, mutual funds, retirement, global asset management, and healthcare related services. 5. PFSI and/or its affiliates, licensees or predecessors-in-interest are, and have been for many years, engaged in marketing, advertising and providing a wide variety of real estate, investment, investment management, investment advisory, lending, insurance, 2 underwriting, employee benefits, estate planning, tax consultation, financial, banking, mutual funds, retirement, global asset management, and healthcare related services (hereinafter “Plaintiffs’ Services”). 6. PFSI is the owner of its famous family of PRINCIPAL and PRINCIPAL formative trademarks, including, but not limited to, the following current and subsisting U.S. registrations, pending applications, common law marks, and trade names (hereinafter collectively referred to as the “PRINCIPAL Family of Marks”): Mark THE PRINCIPAL EDGE THE PRINCIPAL FINANCIAL GROUP Reg. No. Reg. Date Services 1,469,375 12/15/87 Life, health, accident and casualty insurance underwriting services, investment management services, administering annuities, mutual funds, pensions and income programs for others and register investment advisory services 08/30/88 Consulting and contract management services to preferred provider organizations; arranging for prepaid medical care for others; health care services rendered through preferred provider organizations 09/13/88 Consulting and contract management services to preferred provider organizations; arranging for prepaid medical care for others; health care services rendered through preferred provider organizations 10/11/88 Life, health insurance and reinsurance underwriting and brokerage services; underwriting, administering and managing annuities and pension funds for others; variable life insurance and variable annuities funded through a variety of funding media 10/11/88 Life, health insurance and reinsurance underwriting and brokerage services; underwriting, administering and managing annuities and pension funds for others; variable life insurance and variable annuities funded through a variety of funding media 10/11/88 Life, health insurance and reinsurance underwriting and brokerage services; underwriting, administering and managing annuities and pension funds for others; variable life insurance and variable annuities funded through a variety of funding media 03/14/89 Life, health insurance underwriting services, investment management services, administering annuities, mutual funds, pensions and income programs for others, registered investment advisory services and brokerdealer securities services Incontestable 1,502,424 Incontestable 1,504,246 Incontestable 1,508,542 Incontestable THE PRINCIPAL FINANCIAL GROUP (Stylized) THE PRINCIPAL (Stylized) 1,508,543 Incontestable 1,508,544 Incontestable 1,530,022 Incontestable 3 Mark Reg. No. Reg. Date Services 1,530,023 03/14/89 Life, health insurance underwriting services, investment management services, administering annuities, mutual funds, pensions and income programs for others, registered investment advisory services and brokerdealer securities services 03/21/89 Life, health insurance underwriting services, investment management services, administering annuities, mutual funds, pensions and income programs for others, registered investment advisory services and brokerdealer securities services 10/17/89 Arranging for pre-paid medical care for others 10/24/89 Financial analysis and consulting, management of securities and securities brokerage services 06/30/92 Real estate leasing and management services 12/15/92 Commercial and residential real estate services; namely, brokerage, investment, management, mortgage loan, and valuation services 12/15/92 Commercial and residential real estate services; namely, brokerage, investment, management, mortgage loan, and valuation services 05/18/04 Retail commercial banking services, namely, checking, savings, money market, credit cards, certificates of deposit, mortgage loans, commercial real estate lending, and corporate banking services Financial services, namely, portfolio management, financial market analysis, asset management, mortgage lending, real estate and securities investment management and investment management advisory services Retail commercial banking services, namely, checking, savings, money market, credit cards, certificates of deposit, mortgage loans, commercial real estate lending, and corporate banking services Incontestable 1,531,199 Incontestable THE PRINCIPAL PLAN 1,561,335 Incontestable PRINCIPAL 1,562,541 Incontestable 1,698,013 Incontestable THE PRINCIPAL FINANCIAL GROUP THE PRINCIPAL 1,740,172 Incontestable 1,740,181 Incontestable PRINCIPAL BANK 2,843,297 Incontestable PRINCIPAL GLOBAL INVESTORS 3,053,544 01/31/06 Incontestable 3,095,382 05/23/06 Incontestable PRINCIPAL FREEDOM 3,107,136 06/20/06 Financial services, namely, variable annuities 11/21/06 Life, health, accident and casualty insurance underwriting and brokerage services, investment management services, underwriting, administering and managing annuities, mutual funds, pensions and income programs for others, registered investment advisory services and management of securities and securities brokerage services Incontestable PRINCIPAL ADVANTAGE 3,174,382 Incontestable 4 Mark Reg. No. Reg. Date Services 3,297,647 09/25/07 Annuities underwriting and investment, management of, distribution and administration services, namely, providing administrative services for fixed and variable annuities; funds investment; trust and custodial services for retirement plans, namely, investment of funds for others in the field of mutual funds and individual retirement accounts; administration of employee pension plans; financial services in the nature of an investment security; investment management services; mutual fund investment, distribution and brokerage; administration of employer provided and individual pension and fixed investment income programs; registered investment advisory services and broker-dealer securities services, namely, brokering and trading in securities and providing investment advisory services; banking services; consumer loan financing; pension plan consulting; estate planning; financial planning; administration services of insurance in the fields of life, disability, dental, prescription drug, vision and accidental death and dismemberment; administration of employee benefit plans, namely, deferred compensation benefit plans, profit sharing plans, cafeteria plans and other employee benefit plans; insurance underwriting and brokerage services for groups and individuals in the fields of life, disability and dental; real estate mortgage lending and mortgage asset procurement for others; maintaining real estate mortgage escrow accounts; real estate investment services; real estate management; leasing of commercial real estate; financial investment in the field of real estate development; providing administration services to employee welfare benefit plans and pre-paid dental plans and claims administration, namely, claims processing; and retail commercial banking services, namely, checking, savings, money market, credit cards, certificates of deposit, mortgage loans, commercial real estate lending, and corporate banking services Annuities underwriting and investment, management of, distribution and administration services, namely, providing administrative services for fixed and variable annuities; funds investment; trust and custodial services for retirement plans, namely, investment of funds for others in the field of mutual funds and individual retirement accounts; administration of employee pension plans; financial services in the nature of an investment security; investment management services; mutual fund investment, distribution and brokerage; administration of employer provided and individual pension and fixed investment income programs; registered investment advisory services and broker-dealer securities services, namely, brokering and trading in securities and providing investment advisory services; banking services; consumer loan financing; pension plan consulting; estate planning; financial planning; administration services of insurance in the fields of life, disability, dental, prescription drug, vision and accidental death and dismemberment; administration of employee benefit plans, namely, deferred compensation benefit Incontestable PRINCIPAL 3,324,583 10/30/07 Incontestable 5 Mark Reg. No. Reg. Date 3,368,180 01/15/08 Financial services, namely, mutual fund investment services 01/15/08 Financial services, namely, mutual fund investment services 1/15/08 Golf umbrellas; plastic water bottles sold empty; jackets; hats; t-shirts; golf shirts; golf balls; entertainment in the nature of golf tournaments 03/25/08 Financial services, namely, portfolio management, financial market analysis, asset management, mortgage lending, real estate and securities investment management and investment management advisory services 07/01/08 Golf umbrellas; plastic water bottles sold empty; jackets; hats; t-shirts; golf shirts; golf balls; entertainment in the nature of golf tournaments 3,461,024 07/08/08 Financial sponsorship of automobile racing teams; financial sponsorship of sporting and entertainment venues; entertainment in the nature of family-oriented festivals 3,461,025 07/08/08 Shirts; annuities underwriting and investment, management of, distribution and administration services, namely, providing administrative services for fixed and variable annuities; funds investment; trust and custodial services for retirement plans, namely, investment of funds for others in the field of mutual funds and individual retirement accounts; administration of employee pension plans; financial Incontestable PRINCIPAL FUNDS 3,368,181 Incontestable THE PRINCIPAL CHARITY CLASSIC 3,369,005 Incontestable 3,400,594 Incontestable 3,456,731 Incontestable 6 Services plans, profit sharing plans, cafeteria plans and other employee benefit plans; insurance underwriting and brokerage services for groups and individuals in the fields of life, disability and dental; real estate mortgage lending and mortgage asset procurement for others; maintaining real estate mortgage escrow accounts; real estate investment services; real estate management; leasing of commercial real estate; financial investment in the field of real estate development; providing administration services to employee welfare benefit plans and pre-paid dental plans and claims administration, namely, claims processing; and retail commercial banking services, namely, checking, savings, money market, credit cards, certificates of deposit, mortgage loans, commercial real estate lending, and corporate banking services Mark 5/17/11 Managed health care services, namely, preventive medical screenings, and wellness programs; providing health care information in the field of health and wellness 4,111,149 3/13/2012 Real estate investment services; real estate management services 4/24/2012 Real estate investment services; real estate management services 4,396,203 09/03/2013 Financial services, namely portfolio management, financial market analysis, asset management, and investment management advisory services 4,396,202 PRINCIPAL FINANCIAL GROUP Services services in the nature of an investment security; investment management services; mutual fund investment, distribution and brokerage; administration of employer provided and individual pension and fixed investment income programs; registered investment advisory services and broker-dealer securities services, namely, brokering and trading in securities and providing investment advisory services; banking services; consumer loan financing; pension plan consulting; estate planning; financial planning; administration services of insurance in the fields of life, health, disability, dental, prescription drug, vision and accidental death and dismemberment; administration of employee benefit plans, namely, deferred compensation benefit plans, profit sharing plans and cafeteria plans; insurance underwriting and brokerage services for groups and individuals in the fields of life, health, disability and dental; mortgage banking services; mortgage brokerage services; real estate mortgage lending and mortgage asset procurement for others; maintaining real estate mortgage escrow accounts; real estate investment services; real estate management; leasing of commercial real estate; financial investment in the field of real estate development; providing administration services to employee welfare benefit plans and pre-paid dental plans and claims administration, namely, claims processing. and retail commercial banking services, namely, checking, savings, money market, credit cards, certificates of deposit, mortgage loans, commercial real estate lending, and corporate banking services 4,130,738 PRINCIPAL GLOBAL FIXED INCOME Reg. Date 3,961,137 PRINCIPAL REAL ESTATE INVESTORS Reg. No. 09/03/2013 Financial services, namely portfolio management, financial market analysis, asset management, and investment management advisory services (pending app) n/a Annuities underwriting and investment, management of, distribution and administration services, namely, providing administrative services for fixed and variable 85/811,463 7 Mark Reg. No. Reg. Date Services annuities; funds investment; trust and custodial services for retirement plans, namely, investment of funds for others in the field of mutual funds and individual retirement accounts; administration of employee pension plans; financial services in the nature of an investment security; investment management services; mutual fund investment, distribution and brokerage; administration of employer provided and individual pension and fixed investment income programs; registered investment advisory services and broker-dealer securities services, namely, brokering and trading in securities and providing investment advisory services; banking services; consumer loan financing; pension plan consulting; estate planning; financial planning; administration services of insurance in the fields of life, disability, dental, prescription drug, vision and accidental death and dismemberment; administration of employee benefit plans, namely, deferred compensation benefit plans, profit sharing plans, cafeteria plans and other employee benefit plans; insurance underwriting and brokerage services for groups and individuals in the fields of life, disability and dental; real estate mortgage lending and mortgage asset procurement for others; maintaining real estate mortgage escrow accounts; real estate investment services; real estate management; leasing of commercial real estate; financial investment in the field of real estate development; providing administration services to employee welfare benefit plans and pre-paid dental plans and claims administration, namely, claims processing; and retail commercial banking services, namely, checking, savings, money market, credit cards, certificates of deposit, mortgage loans, commercial real estate lending, and corporate banking services (pending app) n/a Annuities underwriting and investment, management of, distribution and administration services, namely, providing administrative services for fixed and variable annuities; funds investment; trust and custodial services for retirement plans, namely, investment of funds for others in the field of mutual funds and individual retirement accounts; administration of employee pension plans; financial services in the nature of an investment security; investment management services; mutual fund investment, distribution and brokerage; administration of employer provided and individual pension and fixed investment income programs; registered investment advisory services and broker-dealer securities services, namely, brokering and trading in securities and providing investment advisory services; banking services; consumer loan financing; pension plan consulting; estate planning; financial planning; administration services of insurance in the fields of life, disability, dental, prescription drug, vision and accidental death and dismemberment; administration of employee benefit plans, namely, deferred compensation benefit plans, profit sharing plans, cafeteria plans and other employee benefit plans; insurance underwriting and 85/811,461 8 Mark Reg. No. Reg. Date Services brokerage services for groups and individuals in the fields of life, disability and dental; real estate mortgage lending and mortgage asset procurement for others; maintaining real estate mortgage escrow accounts; real estate investment services; real estate management; leasing of commercial real estate; financial investment in the field of real estate development; providing administration services to employee welfare benefit plans and pre-paid dental plans and claims administration, namely, claims processing; and retail commercial banking services, namely, checking, savings, money market, credit cards, certificates of deposit, mortgage loans, commercial real estate lending, and corporate banking services PRINCIPAL LIFE INSURANCE COMPANY (pending app) n/a Annuities underwriting and investment, management of, distribution and administration services, namely, providing administrative services for fixed and variable annuities; funds investment; trust and custodial services for retirement plans, namely, investment of funds for others in the field of mutual funds and individual retirement accounts; administration of employee pension plans; financial services in the nature of an investment security; investment management services; mutual fund investment, distribution and brokerage; administration of employer provided and individual pension and fixed investment income programs; registered investment advisory services and broker-dealer securities services, namely, brokering and trading in securities and providing investment advisory services; banking services; consumer loan financing; pension plan consulting; estate planning; financial planning; administration services of insurance in the fields of life, disability, dental, prescription drug, vision and accidental death and dismemberment; administration of employee benefit plans, namely, deferred compensation benefit plans, profit sharing plans, cafeteria plans and other employee benefit plans; insurance underwriting and brokerage services for groups and individuals in the fields of life, disability and dental; real estate mortgage lending and mortgage asset procurement for others; maintaining real estate mortgage escrow accounts; real estate investment services; real estate management; leasing of commercial real estate; financial investment in the field of real estate development; providing administration services to employee welfare benefit plans and pre-paid dental plans and claims administration, namely, claims processing; and retail commercial banking services, namely, checking, savings, money market, credit cards, certificates of deposit, mortgage loans, commercial real estate lending, and corporate banking services PRINCIPAL GLOBAL EQUITIES (pending app) n/a Financial services, namely portfolio management, financial market analysis, asset management, and investment management advisory services 85/811,459 85/849,830 9 Mark Reg. No. Reg. Date (pending app) n/a Services Financial services, namely portfolio management, financial market analysis, asset management, and investment management advisory services 85/849,834 Business Names PRINCIPAL ADMINISTRADORA GENERAL DE FONDOS S.A. PRINCIPAL AFORE, S.A. DE C.V., PRINCIPAL GRUPO FINANCIERO PRINCIPAL ASSET MANAGEMENT CHILE S.A. PRINCIPAL ASSET MANAGEMENT COMPANY (ASIA) LIMITED PRINCIPAL AUSTRALIA (HOLDINGS) PTY LIMITED PRINCIPAL BANK PRINCIPAL COMMERCIAL ACCEPTANCE, LLC PRINCIPAL COMMERCIAL FUNDING, LLC PRINCIPAL COMPANIA DE SEGUROS DE VIDA CHILE S.A. PRINCIPAL CONSULTING (INDIA) PRIVATE LIMITED PRINCIPAL DENTAL SERVICES, INC. PRINCIPAL DEVELOPMENT INVESTORS, LLC PRINCIPAL EDGE NETWORK – AUSTIN, LLC PRINCIPAL EDGE NETWORK – DALLAS FT. WORTH, INC. PRINCIPAL EDGE NETWORK – GEORGIA, LLC PRINCIPAL EDGE NETWORK – SAN ANTONIO, LLC PRINCIPAL EDGE NETWORK – TENNESSEE, LLC PRINCIPAL EDGE NETWORK HOLDINGS, INC. PRINCIPAL ENTERPRISE CAPITAL, LLC PRINCIPAL FINANCIAL ADVISORS, INC. PRINCIPAL FINANCIAL GROUP, INC. PRINCIPAL FINANCIAL GROUP (MAURITIUS) LTD. PRINCIPAL FINANCIAL GROUP, S.A. DE C.V., GRUPO FINANCIERO PRINCIPAL FINANCIAL SERVICES, INC. PRINCIPAL FINANCIAL SERVICES (AUSTRALIA), INC. PRINCIPAL FINANCIAL SERVICES I (UK) LLP PRINCIPAL FINANCIAL SERVICES I (US), LLC PRINCIPAL FINANCIAL SERVICES II (UK) LTD. PRINCIPAL FINANCIAL SERVICES II (US), LLC PRINCIPAL FINANCIAL SERVICES III (UK) LTD. PRINCIPAL FINANCIAL SERVICES LATIN AMERICA LTD. PRINCIPAL FONDOS DE INVERSION, S.A. DE C.V., OPERADORA DE FONDOS DE INVERSION, PRINCIPAL GRUPO FINANCIERO PRINCIPAL FUNDS DISTRIBUTOR, INC. PRINCIPAL GENERATION PLANT, LLC PRINCIPAL GLOBAL COLUMBUS CIRCLE, LLC PRINCIPAL GLOBAL INVESTORS (ASIA) LIMITED PRINCIPAL GLOBAL INVESTORS (AUSTRALIA) LIMITED PRINCIPAL GLOBAL INVESTORS (AUSTRALIA) SERVICE COMPANY PTY LIMITED PRINCIPAL GLOBAL INVESTORS (EUROPE) LIMITED PRINCIPAL GLOBAL INVESTORS (HONG KONG) LIMITED PRINCIPAL GLOBAL INVESTORS (IRELAND) LIMITED PRINCIPAL GLOBAL INVESTORS (JAPAN) LIMITED PRINCIPAL GLOBAL INVESTORS (SINGAPORE) LIMITED PRINCIPAL GLOBAL INVESTORS HOLDING COMPANY, INC. PRINCIPAL GLOBAL INVESTORS PARTICIPACOES, LTDA PRINCIPAL GLOBAL INVESTORS TRUST PRINCIPAL GLOBAL INVESTORS, LLC PRINCIPAL GLOBAL SERVICES PRIVATE LIMITED 10 Business Names PRINCIPAL HOLDING CHILE SPA (CHILE) PRINCIPAL HOLDING COMPANY CHILE S.A. PRINCIPAL HOLDING COMPANY, LLC PRINCIPAL INSTITUTIONAL CHILE S.A. PRINCIPAL INSURANCE COMPANY (HONG KONG) LIMITED PRINCIPAL INTERNATIONAL (ASIA) LIMITED PRINCIPAL INTERNATIONAL DE CHILE S.A. PRINCIPAL INTERNATIONAL HOLDING COMPANY, LLC PRINCIPAL INTERNATIONAL LATIN AMERICA LTD. PRINCIPAL INTERANTIONAL SOUTH AMERICA I LTD. PRINCIPAL INTERANTIONAL SOUTH AMERICA II LTD. PRINCIPAL INTERANTIONAL SOUTH AMERICA II LTD., AGENCIA EN CHILE PRINCIPAL INTERNATIONAL, INC. PRINCIPAL INVESTORS CORPORATION PRINCIPAL LIFE INSURANCE COMPANY PRINCIPAL LIFE INSURANCE COMPANY OF IOWA PRINCIPAL MANAGEMENT CORPORATION PRINCIPAL MEXICO COMPANIA DE SEGUROS S.A. DE C.V., PRINCIPAL GRUPO FINANCIERO PRINCIPAL MEXICO SERVICIOS, S.A. DE C.V. PRINCIPAL NATIONAL LIFE INSURANCE COMPANY PRINCIPAL NOMINEE COMPANY (HONG KONG) LIMITED PRINCIPAL PENSIONES, S.A. DE C.V., PRINCIPAL GRUPO FINANCIERO PRINCIPAL PNB ASSET MANAGEMENT COMPANY PRIVATE LIMITED PRINCIPAL REAL ESTATE FUND INVESTORS, LLC. PRINCIPAL REAL ESTATE HOLDING COMPANY, LLC PRINCIPAL REAL ESTATE INVESTORS, LLC PRINCIPAL REAL ESTATE PORTFOLIO, INC. PRINCIPAL REINSURANCE COMPANY OF DELAWARE PRINCIPAL REINSURANCE COMPANY OF VERMONT PRINCIPAL RETIREMENT ADVISORS PRIVATE LIMITED PRINCIPAL SHAREHOLDER SERVICES, INC. PRINCIPAL TRUST COMPANY (ASIA) LIMITED PRINCIPAL TRUSTEE COMPANY PRIVATE (INDIA) LIMITED PRINCIPAL WELLNESS COMPANY CCB PRINCIPAL ASSET MANAGEMENT COMPANY, LTD CIMB PRINCIPAL ISLAMIC ASSET MANAGEMENT SDN. BHD. CIMB WEALTH ADVISORS BERHAD CIMB-PRINCIPAL ASSET MANAGEMENT (SINGAPORE) PTE LTD CIMB-PRINCIPAL ASSET MANAGEMENT BETHAD CIMB-PRINCIPAL ASSET MANAGEMENT COMPANY LIMITED (THAILAND) DISTRIBUIDORA PRINCIPAL MEXICO, S.A. DE C.V. HIPOTECARIA CRUZ DEL SUR PRINCIPAL, S.A. (CHILE) PFG DO BRASIL LTDA PGI FINISTERRE HOLDING COMPANY LTD PGI ORIGIN HOLDING COMPANY LTD PRINCOR FINANCIAL SERVICES CORPORATION PRINCORP WEALTH ADVISORS (ASIA) LIMITED PT CIMB PRINCIPAL ASSET MANAGEMENT Common Law Names PRINCIPAL ADMINISTRATIVE EASE PROGRAM PRINCIPAL ADVOCATE EDGE PRINCIPAL ADVANTAGE FOR EMERGING BUSINESS PRINCIPAL ADVISORY SELECT PORTFOLIOS PRINCIPAL ANNUITY EDGE PRINCIPAL ANNUITY LEGACY 11 Common Law Names PRINCIPAL ANNUITY NEWSWIRE PRINCIPAL ANNUITY PLUS PRINCIPAL ASSET RETENTION PROGRAM PRINCIPAL ASSET REWARD PROGRAM PRINCIPAL ASO ESSENTIALS PRINCIPAL AUTOMATIC STANDARD APPROVAL PROGRAM PRINCIPAL BANK AUTOMATIC LOAN PAYMENT PRINCIPAL BANK CASH ACCOUNT PRINCIPAL BANK CHANGE A RATE CD PRINCIPAL BANK CHOICE CHECKING PRINCIPAL BANK EASY LADDER CD PRINCIPAL BANK $50,000 HOME MAKEOVER SWEEPSTAKES PRINCIPAL BANK HIGH YIELD IRA PRINCIPAL BANK MONEY MARKET CASH SWEEP PRINCIPAL BANK MONEY MARKET IRA PRINCIPAL BANK MONEY MOVEMENT PRINCIPAL BANK SAFE HARBOR IRA PRINCIPAL BANK SECURE PRINCIPAL BENCHMARK REPORT: EMPLOYER SPONSORED RETIREMENT SOLUTIONS FOR KEY EMPLOYEES PRINCIPAL FUNDING DESIGN TOOL PRINCIPAL FUNDING EXCHANGE PRINCIPAL BUSINESS SUCCESSION REVIEW PRINCIPAL CAPITAL INCOME INVESTORS PRINCIPAL CANCER CARE PROGRAM PRINCIPAL CLASSIC COMPREHENSIVE MEDICAL PRINCIPAL CLASSIC PPO PRINCIPAL CLASSIC PPO PLUS PRINCIPAL CLASSIC VALUE PPO PRINCIPAL COACHES CHALLENGE PRINCIPAL COLLEGE BOUND FUND PRINCIPAL COLLEGE SAVINGS PROGRAM PRINCIPAL.COM PRINCIPAL COMMERCIAL MORTGAGE EDGE PRINCIPAL COMPREHENSIVE RETIREMENT PROGRAM PRINCIPAL DENTAL ACCESS NETWORK PRINCIPAL DENTAL HEALTH EDGE PRINCIPAL DENTAL MEMBER ADVANTAGE PROGRAM PRINCIPAL DENTAL SERIES PRINCIPAL DIRECT CONNECT PRINCIPAL DUE DILIGENCE PROGRAM PRINCIPAL DYNAMIC PORTFOLIOS BY IBBOTSON PRINCIPAL EARLY EDGE PRINCIPAL EASE PRINCIPAL EASE PROGRAM PRINCIPAL EASY ENROLLMENT PRINCIPAL ECONOMIC EDGE PRINCIPAL EDGE NETWORK PRINCIPAL EDGE NETWORK PREMIER PRINCIPAL EDGE NETWORK - SELECT PRINCIPAL EDGE VARIABLE ANNUITY PRINCIPAL EDUCATION NETWORK PRINCIPAL E-DISTRIBUTION SERVICES PRINCIPAL E-DIVERSIFICATION SERVICES PRINCIPAL E-ENROLL PRINCIPAL E-FINANCIAL PROFESSIONAL PRINCIPAL ELITE FIXED ANNUITY PRINCIPAL EMPLOYEE FINANCIAL CENTER 12 Common Law Names PRINCIPAL EMPLOYEE TERM LIFE PRINCIPAL EMPLOYER DRIVEN WELLNESS SOLUTION PRINCIPAL ENROLLMENT SUITE PRINCIPAL eRETIREMENT SOLUTIONS PRINCIPAL ESOP EDGE PRINCIPAL EXECUTIVE BONUS PLUS PRINCIPAL EXECUTIVE EXCHANGE PRINCIPAL EXECUTIVE RETIREMENT AND COMPENSATION SERVICE PRINCIPAL EZ DEFINED BENEFIT/ PRINCIPAL EZ DB PRINCIPAL FINANCIAL MILESTONES PROGRAM PRINCIPAL FINANCIAL SECURITY REVIEW PRINCIPAL FINANCIAL SECURITY SERIES PRINCIPAL FINANCIAL SOLUTIONS EXPLORER PRINCIPAL FINANCIAL WELL BEING PRINCIPAL FIXED ANNUITY PRINCIPAL FIXED ANNUITY PLUS PRINCIPAL FIXED ANNUITY SELECT PRINCIPAL FLOATING RATE SEPARATE ACCOUNT PRINCIPAL 403(b) CONSOLIDATOR PRINCIPAL FUNDS PRINCIPAL GLOBAL CREDIT OPPORTUNITIES FUND PRINCIPAL GLOBAL FINANCIAL WELL BEING STUDY PRINCIPAL GLOBAL INVESTORS COLLECTIVE INVESTMENT TRUST PRINCIPAL GLOBAL NET PRINCIPAL GLOBAL PROPERTY SECURITIES FUND PRINCIPAL GREEN FUND I PRINCIPAL GROWTH FIXED ANNUITY PRINCIPAL GUARANTEED FIXED ANNUITY PRINCIPAL GUARANTEED INCOME PRINCIPAL HEALTH ASSESSMENT PRINCIPAL HEALTH CARE PRINCIPAL HEALTH COACHING PRINCIPAL HEALTH INFO LINE PRINCIPAL HEALTH SAVINGS ACCOUNT PRINCIPAL HEALTH + WEALTH PRINCIPAL HEALTHY CONNECTIONS PRINCIPAL HEALTHY EDGE PRINCIPAL HEALTHY ESSENTIALS PRINCIPAL HEALTHY RESOURCES PRINCIPAL HIGH QUALITY CANADIAN FIXED INCOME PLUS FUND PRINCIPAL HOME ACCESS LINE PRINCIPAL HOME EQUITY ACCESS LOAN PRINCIPAL ILLUSTRATION EDGE PRINCIPAL IMPACTPLUS PRINCIPAL INCOME IRA PRINCIPAL INCOME MANAGER PRINCIPAL INCOME PROTECTOR PRINCIPAL INCOME PROVIDER PRINCIPAL INDUSTRIAL INVESTORS PRINCIPAL INVESTMENT PLUS VARIABLE ANNUITY PRINCIPAL IRA EXCHANGE PRINCIPAL LIFE CORE NOTES PRINCIPAL LIFE INCOME FUNDING PRINCIPAL LIFE INSURANCE COMPANY PRINCIPAL LIFERIGHT INSURANCE PROGRAM PRINCIPAL LIFETIME PRINCIPAL LIFETIME HORIZON FUND PRINCIPAL LIFETIME INCOME SOLUTIONS 13 Common Law Names PRINCIPAL, LLC PRINCIPAL LOAN CONNECTION PRINCIPAL MANAGED ACCOUNT PROGRAM PRINCIPAL MAXIMUM FUNDED VARIABLE UNIVERSAL LIFE PRINCIPAL MEDICAL WELLNESS SERIES PRINCIPAL MESSAGE CENTER PRINCIPAL MESSENGER PRINCIPAL MORTGAGE FUNDING PRINCIPAL® MULTI-ASSET ADVISORS & DESIGN PRINCIPAL NATIONAL LIFE INSURANCE COMPANY PRINCIPAL NONQUALIFIED BENEFIT EXCHANGE PRINCIPAL NONQUALIFIED EDGE PROGRAM PRINCIPAL OPEN DOOR CLOSED END SECONDS PRINCIPAL PARK PRINCIPAL PARTNERS PRINCIPAL PASSAGE DIRECT INVESTMENT PROGRAM PRINCIPAL PASSAGE FEE BASED BROKERAGE ACCOUNT PRINCIPAL PASSAGE MANAGED PORTFOLIO PRINCIPAL PASSAGE PREMIER ASSET ALLOCATION SERVICE PRINCIPAL PAYROLL PROGRAMS PRINCIPAL PERFORMANCE ANNUITY PRINCIPAL PERFORMANCE ANNUITY 7 PRINCIPAL PHYSICIAN REWARD PLAN PRINCIPAL PLAN MANAGER EXCHANGE PRINCIPAL PORTFOLIO CONSTRUCTION STRATEGIES PRINCIPAL PREFERRED JUMBO MORTGAGE PRINCIPAL PREVENTIVE SCREENING PRINCIPAL PRIVILEGED PARTNERS PROGRAM PRINCIPAL PRIVILEGES PARTNER PROGRAM PRINCIPAL PRIORITY PASSPORT CLUB PRINCIPAL PRIORITY ROLLOVER PRINCIPAL PRODUCER WORKSPACE PRINCIPAL REAL ESTATE SERVICES PRINCIPAL REIMBURSEMENT ARRANGEMENT PRINCIPAL RESIDENTIAL MORTGAGE DIRECT PRINCIPAL RESIDENTIAL MORTGAGE HOMEGEN JUMBO LINE PRINCIPAL RESOURCE CENTER PRINCIPAL RETIRE SECURE PRINCIPAL RETIREGUIDE PRINCIPAL RETIREMENT ACCOUNT PRINCIPAL RETIREMENT EDGE PROGRAM PRINCIPAL RETIREMENT INCOME EDGE PRINCIPAL RETIREMENT MILESTONES PROGRAM PRINCIPAL RETIREMENT NAVIGATOR PRINCIPAL RETIREMENT NETWORK FOR UNION MEMBERS PRINCIPAL RETIREMENT OUTSOURCING PRINCIPAL RETIREMENT PLANNING CENTER PRINCIAPL RETIREMENT + PRINCIPAL RETIREMENT RESOURCE CONSULTANT PRINCIPAL RETURN-TO-WORK RESOURCES PRINCIPAL RIVERWALK PRINCIPAL ROLLOVER CHOICE PRINCIPAL ROLLOVER OPTIONS PRINCIPAL RX EDGE PRINCIPAL SAVINGS BUILDER ANNUITY PRINCIPAL S-CORPS BONUS PLUS PRINCIPAL S OWNER PLUS PRINCIPAL SECURE DECISIONS 14 Common Law Names PRINCIPAL SECURE FIXED ANNUITY PRINCIPAL SECURE INCOME ANNUITY PRINCIPAL SECUREDLOAN PRINCIPAL SECURITY BUILDER RETIREMENT PROGRAM PRINCIPAL SECURITY BUILDER RETIREMENT PROGRAM INDIVIDUAL 401(K) PRINCIPAL SELECT DENTIST PROGRAM PRINCIPAL SELECT REWARD PLAN PRINCIPAL SELECT SERIES ANNUITY PRINCIPAL SERVICES TRUST COMPANY PRINCIPAL SINGLE PREMIUM DEFERRED ANNUITY PRINCIPAL SPLIT DOLLAR PLUS PRINCIPAL SPONSOR SERVICE CENTER PRINCIPAL STEP AHEAD RETIREMENT OPTION PRINCIPAL STRATEGIC ASSET MANAGEMENT PRINCIPAL SURVIVOR LIFE INSURANCE WITH THE IBIS OPTION PRINCIPAL SURVIVORSHIP UNIVERSAL LIFE PROTECTOR PRINCIPAL SWITCH KIT PRINCIPAL TOTAL RETIREMENT SUITE PRINCIPAL TPA EDGE PRINCIPAL TRAILBLAZER PRINCIPAL TRUST COMPANY PRINCIPAL TRUST INCOME FUND PRINCIPAL TRUST TARGET DATE FUNDS PRINCIPAL UNDERIGHT PRINCIPAL UNIVERSAL LIFE FLEX PRINCIPAL UNIVERSAL LIFE PREFERRED PRINCIPAL UNIVERSAL LIFE PROTECTOR PRINCIPAL UNIVERSAL LIFE PROTECTOR II PRINCIPAL VALUE BASED HEALTH BENEFIT PRINCIPAL VALUE UNIVERSAL LIFE PRINCIPAL VARIABLE UNIVERSAL LIFE ACCUMULATOR PRINCIPAL VARIABLE UNIVERSAL LIFE INCOME PRINCIPAL VOLUNTARY BENEFITS EDGE PRINCIPAL VOLUNTARY ROLLOVER INCOME PRINCIPAL WELLNESS CLASSIC HRA PRINCIPAL WELLNESS CLASSIC PPO PRINCIPAL WELLNESS FSA PRINCIPAL WELLNESS COMPANY PRINCIPAL WHOLESALE MORTGAGE PRINCIPAL WORK SECURE – 2004 PRINCIPAL YEAR ROUND WELLNESS PROGRAM MIDLANDS CHOICE - PRINCIPAL MY PRINCIPAL®EDGE MY PRINCIPAL®EDGE IN RETIREMENT MY PRINCIPAL®EDGE STRATEGY SOLUTIONS FOR ADVISORS FROM THE PRINCIPAL FINANCIAL GROUP THE PRINCIPAL CHILD DEVELOPMENT CENTER THE PRINCIPAL FINANCIAL GROUP® SECURE MAIL CENTER THE PRINCIPAL MY VISIT THE PRINCIPAL FINANCIAL DREAMS TOUR THE PRINCIPAL RETIREMENT NEWSLETTER THE PRINCIPAL® RIVER’S EDGE THE PRINCIPAL® SECURE MAIL CENTER THE PRINCIPAL® 10 BEST COMPANIES THE PRINCIPAL WARRANTY THE PRINCIPAL WELLNESS SOLUTION YOUR MONEY UPDATE BY THE PRINCIPAL 15 7. Since at least as early as 1960, Principal, via its affiliates, licensees and/or predecessors-in-interest, has used one or more of the marks making up its famous PRINCIPAL Family of Marks in interstate commerce in connection with Plaintiffs’ Services, specifically, financial analysis and consulting, management of securities and securities brokerage services. 8. Since at least as early as 1985, Principal and/or its affiliates, licensees or predecessors-in-interest have used one or more of the marks making up the PRINCIPAL Family of Marks in interstate commerce in the United States and throughout the world in connection with real estate, investment, investment management, investment advisory, lending, insurance, underwriting, employee benefits, estate planning, tax consultation, financial, banking, mutual funds, retirement, global asset management, and healthcare related services. 9. Plaintiffs have made an enormous investment, exceeding one billion dollars, in advertising and promoting its products and services under the PRINCIPAL Family of Marks. As a result, Plaintiffs have acquired extremely valuable goodwill in association with the PRINCIPAL Family of Marks, which has become famous and distinctive in connection with Plaintiffs’ Services. Plaintiffs’ customers have come to rely on the PRINCIPAL Family of Marks as a symbol of quality and reliability. 10. PFSI’s U.S. trademark registrations are valid and subsisting, and constitute prima facie and/or conclusive evidence of PFSI’s exclusive right to use its registered marks in connection with the goods and/or services covered by the registrations, e.g., real estate, investment, investment management, investment advisory, lending, insurance, underwriting, employee benefits, estate planning, tax consultation, financial, banking, 16 mutual funds, retirement, global asset management, and healthcare related services. See 15 U.S.C. §§ 1115(a) and (b). 11. Based on the inherent and/or acquired distinctiveness of the PRINCIPAL Family of Marks; the duration and extent of Plaintiffs’ use of the PRINCIPAL Family of Marks; the duration and extent of advertising featuring the PRINCIPAL Family of Marks; the geographic area in which Plaintiffs have sold and advertised goods and/or services featuring the PRINCIPAL Family of Marks; the nature of the trade channels Plaintiffs use to market goods and/or services featuring the PRINCIPAL Family of Marks compared to the channels through which Defendants sell their services; the degree of public recognition of the PRINCIPAL Family of Marks; and the various federal registrations for the PRINCIPAL Family of Marks, the PRINCIPAL Family of Marks has become famous as contemplated by Section 43(c) of the Lanham Act, 15 U.S.C. § 1125(c). 12. Since long before the acts of Defendants complained of herein, PFSI and/or its affiliates, licensees or predecessors-in-interest have continuously used one or more of the marks which comprise its PRINCIPAL Family of Marks in the State of Illinois and elsewhere in interstate commerce. 13. Defendant MAURICIO IZQUIERDO is an individual located at Pino 506 Col Arboledas, Puerto Vallarta, JA, Mexico, 48315, and is the sole proprietor of a business which operates under the name BIT MEDIA STUDIO, from the same address. 14. Defendant MAURICIO IZQUIERDO offers residential, commercial and industrial real estate management services as well as resale and rental of time share 17 memberships throughout the State of Illinois and in interstate commerce under the trade name and service mark PRINCIPAL GLOBAL INVESTORS LLC and at the website located at the URL’s http://www.principalglobalinvestorsllc.com and http://www.pglobalinvestors.com (hereinafter “Defendant’s Services”). 15. Despite actual and/or constructive notice of PFSI’s rights in and to its PRINCIPAL Family of Marks, on or about January 25, 2014, Defendant MAURICIO IZQUIERDO obtained a domain name registration for the domain name principalglobalinvestorsllc.com which fully incorporates and is confusingly similar to PFSI’s famous PRINCIPAL Family of Marks including, but not limited to, its PRINCIPAL GLOBAL INVESTORS trade name and service mark. 16. Despite actual and/or constructive notice of PFSI’s rights in and to its PRINCIPAL Family of Marks, at some time after January 25, 2014, Defendant MAURICIO IZQUIERDO commenced operation of and continues to operate an Internet web site at the URL http://www.principalglobalinvestorsllc.com where it offers residential, commercial and industrial real estate management services as well as resale and rental of time share memberships throughout the State of Illinois and in interstate commerce under the trade name and service mark PRINCIPAL GLOBAL INVESTORS LLC (hereinafter “Defendants’ Services”). 17. Defendant MAURICIO IZQUIERDO’s use of the PRINCIPAL GLOBAL INVESTORS LLC Mark has caused actual confusion and is likely to continue to cause actual confusion in the marketplace as to source, origin, sponsorship and/or affiliation with Plaintiffs’ PRINCIPAL Family of Marks. 18. Defendants MAURICIO IZQUIERDO’s PRINCIPAL GLOBAL INVESTORS LLC 18 Mark is identical or virtually identical and/or confusingly similar to Plaintiffs’ PRINCIPAL Family of Marks. 19. Plaintiffs’ Services and Defendants MAURICIO IZQUIERDO’s Services as well as the classes of consumers who purchase such services are identical and/or virtually identical. 20. Defendant MAURICIO IZQUIERDO adopted the PRINCIPAL GLOBAL INVESTORS LLC Mark with the intent to trade on and/or capitalize on the goodwill symbolized by the PRINCIPAL Family of Marks. 21. Any unauthorized advertising, promotion, distribution or sale of tax consultation, financial, banking, insurance, investment, investment management, investment advisory, estate planning, underwriting, lending, mutual funds, real estate, retirement, employee benefits, global asset management, and/or healthcare related services by Defendant MAURICIO IZQUIERDO utilizing a trademark or trade name incorporating PRINCIPAL and/or PRINCIPLE is likely to confuse, mislead or deceive the public into believing that such goods or services originate from or are sponsored or authorized by Plaintiff and constitutes trademark infringement, unfair competition, deceptive trade practices, cybersquatting and trademark dilution in violation of Federal and common law and the laws of the State of Illinois 22. Plaintiffs effectuated service of the duly and properly translated Complaint and court sealed Summons on Defendant MAURICIO IZQUIERDO, through the Central Authority of Mexico on Defendant MAURICIO IZQUIERDO, at the following address: Pino numero 506, Colonia Arboledas, Puerto Vallarta, Jalisco C.P., 48315, 19 which to the best of Plaintiffs’ knowledge is the address where Defendant, MAURICIO IZQUIERDO, resides. 23. Without any order permanently enjoining Defendant MAURICIO IZQUIERDO from using the PRINCIPAL GLOBAL INVESTORS LLC Mark or any other colorable imitation of any PRINCIPAL or PRINCIPLE formative trade name and trademark in any advertisement, promotion, offer for sale, or sale of any goods or services that are sufficiently similar to those offered by Plaintiffs, there is a substantial likelihood that Defendant MAURICIO IZQUIERDO will continue to infringe upon Plaintiff’s marks and violate the Lanham Act, Title 15, United States Code 1051, et seq., and the statutes and common laws of the State of Illinois. I. IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED that: A. Defendant MAURICIO IZQUIERDO’s use of the PRINCIPAL GLOBAL INVESTORS LLC Mark is likely to cause public confusion, mistake or deception as to the origin or source of Defendant MAURICIO IZQUIERDO’s Services, in violation of the Lanham Act, 15 U.S.C. § 1114(1). B. Defendant MAURICIO IZQUIERDO’s acts, as alleged herein, constitute willful trademark infringement as contemplated by the Lanham Act, 15 U.S.C. § 1117. C. Defendant MAURICIO IZQUIERDO’s use of the PRINCIPAL GLOBAL INVESTORS LLC Mark constitutes a false designation of origin, a false or misleading description of fact or a false or misleading representation of fact which is likely to cause confusion, mistake or deception in violation of the Lanham Act, Section 43(a), 15 U.S.C. § 1125(a). 20 D. The aforesaid willful and deliberate acts of Defendant MAURICIO IZQUIERDO, all occurring after the PRINCIPAL Family of Marks became famous, have caused and continue to cause dilution and/or are likely to cause dilution of the famous PRINCIPAL Family of Marks and thus constitute trademark dilution in violation of Section 43(c) of the Lanham Act, 15 U.S.C. § 1125(c). E. Defendant MAURICIO IZQUIERDO acts as complained of herein created a likelihood of confusion or of misunderstanding as to the source, sponsorship or approval of Plaintiffs’ and Defendant MAURICIO IZQUIERDO’s services, as well as a likelihood of confusion or of misunderstanding as to affiliation, connection or association of Plaintiffs and Defendants. F. By engaging in these deceptive trade practices, Defendant MAURICIO IZQUIERDO’s has directed these deceptive trade practices to the market generally, thereby directly implicating the consumer protection concerns invoked by the Illinois Deceptive Trade Practices Act. G. Such conduct by Defendant MAURICIO IZQUIERDO has violated and continues to violate the Illinois Deceptive Trade Practices Act, 815 ILCS 510/1 et seq. H. Defendant MAURICIO IZQUIERDO’s acts were conducted in bad faith, in conscious and deliberate disregard of Plaintiffs’ rights, and were performed with the intention of depriving Plaintiffs of their rights. I. Defendant MAURICIO IZQUIERDO registered, owns and continues to use the infringing domain name principalglobalinvestorsllc.com with a bad faith intent to profit from and/or trade off of the goodwill associated with Plaintiffs’ famous PRINCIPAL Family of Marks. 21 J. The infringing domain name is identical and/or confusingly similar to one or more of the famous PRINCIPAL Family of Marks including, but not limited to, Plaintiffs’ PRINCIPAL GLOBAL INVESTORS marks as referenced herein. II. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that: K. Defendant MAURICIO IZQUIERDO willfully violated Sections 32(1), 43(a), 43(c) and 43(d) of the Lanham Act, 15 U.S.C. § 1051 et seq.; L. Defendant MAURICIO IZQUIERDO committed acts of unfair competition and deceptive trade practices in violation of Illinois common law and 815 ILCS 510/1 et seq.; M. Defendant MAURICIO IZQUIERDO, as well as any officers, agents, servants, employees and attorneys, and all persons in active concert or participation with Defendant MAURICIO IZQUIERDO, are immediately and permanently enjoined and restrained from: a. using any PRINCIPAL and/or PRINCIPLE formative trademark, trade name and/or domain name in connection with any tax consultation, financial, banking, insurance, investment, investment management, investment advisory, estate planning, underwriting, lending, mutual funds, real estate, retirement, employee benefits, global asset management, and/or healthcare related services, including but not limited to any use on any signage, electronic materials, branding materials, domain names, web sites, social media and other printed or promotional materials relating to such services; 22 b. making any false and/or misleading statements in the advertising, promotion and offering for sale of tax consultation, financial, banking, insurance, investment, investment management, investment advisory, estate planning, underwriting, lending, mutual funds, real estate, retirement, employee benefits, global asset management, and/or healthcare related services that would be likely to confuse, mislead and/or deceive customers and/or potential customers into believing that such services originate from Plaintiff; and c. assisting, aiding and/or abetting any other person and/or business entity in engaging in and/or performing any of the activities enjoined herein. N. Pursuant to 15 U.S.C. § 1118, Defendant MAURICIO IZQUIERDO, as well as any officers, agents, servants, employees and attorneys, and all persons in active concert or participation with Defendant MAURICIO IZQUIERDO, are ordered to deliver up and destroy all products, labels, signs, packages, wrappers, advertisements, promotions and all other matter in custody or under the control of Defendant MAURICIO IZQUIERDO, as well as any officers, agents, servants, employees and attorneys, and all persons in active concert or participation with Defendant MAURICIO IZQUIERDO, that bear any of the PRINCIPAL Family of Marks or any other mark that is likely to be confused with one or more of the PRINCIPAL Family of Marks; O. If there are any violations of this Judgment, Plaintiff may or seek full damages and profits, trebled as prescribed by Section 35(a) of the Lanham Act, 15 U.S.C. § 1117(a), as well as its costs and attorneys’ fees and any such other and further 23 relief to which it may be entitled. The jurisdiction of this Court is retained for the purpose of making any other orders necessary or proper to construe, enforce or implement the terms of this Judgment and to punish or award damages or violations thereof. IT IS SO ORDERED. DATED:____________________ ______________________________ The Honorable Harry D. Leinenweber United States District Court Judge 24
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