Case 1:13-cv-00890-LJO-SAB Document 58 Filed 05/23/14 Page 1 of 2 1 2 IN THE UNITED STATES DISTRICT COURT 3 EASTERN DISTRICT OF CALIFORNIA 4 FRESNO DIVISION 5 6 ASSYRIAN AMERICAN NATIONAL Case No. 1:13-CV-00890-LJO-SAB 7 FEDERATION, INC., a New York not-for- profit corporation, 8 STIPULATED PERMANENT INJUNCTION Plaintiff, AGAINST DEFENDANTS 9 vs. 10 ASSYRIAN AMERICAN NATIONAL 11 FEDERATION, INC., a California corporation, et al. 12 Defendants. 13 14 Pursuant to a stipulation filed May 23, 2014, signed by all parties, Plaintiff, ASSYRIAN 15 AMERICAN NATIONAL FEDERATION, INC., a New York not-for-profit corporation ("AANF" or 16 "Plaintiff") and Defendants Assyrian American National Federation, Inc., a California corporation, 17 Assyrian American National Federation, Inc., an Illinois corporation, Alphonse Odisho, Ramin Odisho, 18 Atour Golani, Hawel Hawel, Pierre Toulakany, and Amir Younan ("Defendants"), have stipulated and 19 agreed to waive the findings of fact and conclusions of law required by Rule 65(d) of the Federal Rules 20 of Civil Procedure, and to the entry of a permanent injunction against the Defendants as set forth below, 21 without further notice or process: 22 1. This Court has jurisdiction over the subject matter of the Complaint filed on or about 23 June 11, 2013 in Case No. 1:13-CV-00890-LJO-SAB, seeking, among other things, injunctive relief 24 against the Defendants, for Trademark infringement and related claims (the "Action"). This Court shall 25 retain jurisdiction over this Action for purposes of implementing and enforcing this Stipulated 26 Permanent Injunction and Order. 27 28 1 STIPULATED PERMANENT INJUNCTION Case 1:13-cv-00890-LJO-SAB Document 58 Filed 05/23/14 Page 2 of 2 1 2. Defendants expressly consent to personal jurisdiction and venue in the United States 2 District Court for the Eastern District of California for any and all proceedings pertaining to this 3 Permanent Injunction, including but not limited to implementation and/or enforcement of the provisions 4 of this Permanent Injunction. Defendants agree to be bound by the terms of this Permanent Injunction 5 and waive the right to trial and the right to appeal. 6 3. Defendants, whether acting directly or through any other person, together with all of 7 their directors, officers, employees, and agents, are hereby permanently restrained and enjoined from: 8 (a) Using the AANF’s name, Assyrian American National Federation, Inc., or any 9 confusingly similar variation thereof, in the marketing, advertising, or promotion of their 10 business activities; 11 (b) Using the AANF’s mark, which consists of an insignia depicting a five-legged, 12 winged lion standing over a chain strewn above an open book bearing traditional Christian and 13 intellectual symbols with the name Assyrian American National Federation, Inc. printed along 14 the bottom of the seal and Aramaic writing printed along the top, or any confusingly similar 15 variation thereof, in the marketing, advertising, or promotion of their business activities; 16 (c) Using the AANF's name and mark (identified above) in marketing, advertising 17 or promoting any events, including but limited to any conventions targeting Assyrians and/or 18 Assyrian-Americans; and 19 (d) Marketing, advertising, or promoting any conventions to Assyrians and/or 20 Assyrian Americans as the "80th Annual Convention," or any confusingly similar variation 21 thereof. 22 The Clerk of Court is directed to close this case. 23 24 SO ORDERED Dated: May 23, 2014 25 /s/ Lawrence J. O’Neill United States District Judge 26 27 28 2 STIPULATED PERMANENT INJUNCTION .