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Case 2:13-cv-01580-CJC-JC Document 12 Filed 07/11/13 Page 1 of 5 Page ID #:76




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RUSS AUGUST & KABAT
Alexander C.D. Giza, State Bar No. 212327
Email: [email protected]
Irene Y. Lee, State Bar No. 213625
Email: [email protected]
Robert F. Gookin, State Bar No. 251601
Email: [email protected]
Twelfth Floor
12424 Wilshire Boulevard
Los Angeles, California 90025
Telephone: 310.826.7474
Facsimile: 310.826.6991

Attorneys for Plaintiffs Must Win, Inc. and Urban Expressions, Inc.

JS-6

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

MUST WIN, INC., a California
corporation; and URBAN
EXPRESSIONS, INC., a California
corporation,


Plaintiff,





v.



Case No. CV-13-01580-CJC(JCx)

Assigned to The Honorable
Cormac J. Carney
Courtroom No.: 9B

FINAL JUDGMENT AND
PERMANENT INJUNCTION

US PROMOTIONS, INC., dba
MEGHAN LOS ANGELES, a Nevada
corporation; SACHA HASON, an
individual; DOES 1 through 5

Defendants.






3283-009 130625 Final Judgment.doc
___________________________________________________________________________

[PROPOSED] FINAL JUDGMENT AND PERMANENT INJUNCTION




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Case 2:13-cv-01580-CJC-JC Document 12 Filed 07/11/13 Page 2 of 5 Page ID #:77



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WHEREAS, Plaintiffs Must Win, Inc. and Urban Expressions, Inc.
(collectively, “Plaintiffs” or “Urban Expressions”) are the exclusive and sole
owner of the rights in various URBAN EXPRESSIONS marks in connection with
making, marketing and selling high-quality, vegan and animal-free bags, including
United States Trademark Registration Nos. 3,878,378 and 4,211,669 (collectively,
the “URBAN EXPRESSIONS Mark”);

WHEREAS, Defendants US Promotions, Inc. dba Meghan Los Angeles and
Sacha Hason (jointly, severally and collectively “Defendants”) removed,
obliterated or otherwise covered the URBAN EXPRESSIONS Mark from Urban
Expressions bags and falsely represented and sold Urban Expressions bags under
their own MEGHAN LOS ANGELES logo (collectively, the “Infringing
Products”);

WHEREAS, a dispute has arisen between Urban Expressions and
Defendants in that Urban Expressions has alleged that Defendants’ removing,
obliterating and/or covering the URBAN EXPRESSIONS Mark and falsely
representing and selling Urban Expressions bags under the MEGHAN LOS
ANGELES
the URBAN
EXPRESSIONS Mark and constitutes, among other things, false designation of
origin and unfair competition;

logo violates Urban Expressions’

rights

in

WHEREAS, on or about March 5, 2013, Urban Expressions commenced the
above-captioned action (“Action”) against Defendants, alleging, among other
things, claims of trademark infringement, false designation of origin and unfair
competition;

WHEREAS, Urban Expressions and Defendants have reached a full and
final settlement of the Action, which settlement was memorialized in a certain
document dated June 25, 2013 (the “Agreement”); and

WHEREAS, the Agreement provides, in pertinent part, that Defendants
consent to the entry of a permanent injunction enjoining Defendants from
3283-009 130625 Final Judgment.doc

___________________________________________________________________________

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FINAL JUDGMENT AND PERMANENT INJUNCTION

Case 2:13-cv-01580-CJC-JC Document 12 Filed 07/11/13 Page 3 of 5 Page ID #:78



removing, obliterating and/or covering or assisting others to remove, obliterate or
cover the URBAN EXPRESSIONS Mark from Urban Expression products and
using or assisting others to use any other mark, logo, name or designation on
Urban Expression products.

NOW, THEREFORE, it is,
ORDERED, ADJUDGED and DECREE that:
1.

This Court has jurisdiction over the subject matter of this Action and

over the parties hereto.

2.

Urban Expressions is the owner of the URBAN EXPRESSIONS

Marks, which are valid, enforceable, well-known and highly recognized.

3.

Defendants engaged in reverse passing off by removing, obliterating
and/or covering the URBAN EXPRESSIONS Marks on Urban Expressions
products and offering to sell and selling Urban Expression products under other
mark, logo, name or designation, such as the MEGHAN LOS ANGELES logo.

4.

Each Defendant and its officers, members, principals, agents,
servants, employees and all persons and entities in active concert or participation
with any of them, be and hereby are permanently restrained and enjoined from
engaging in violating Urban Expressions’ rights with respect to the URBAN

EXPRESSIONS Marks, either directly or indirectly, in any manner, including:
distributing, circulating, advertising, marketing, promoting,
importing, exporting, displaying, shipping, offering for sale or selling Urban
Expression products under a mark, logo, name or designation that is not URBAN
EXPRESSIONS, including, without limitation, the MEGHAN LOS ANGELES
logo, after June 25, 2013;

(a)

(b)

committing any other acts calculated to cause purchasers to
believe that Urban Expressions’ genuine products are Defendants’ products or
associated with either Defendant in any way; and

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FINAL JUDGMENT AND PERMANENT INJUNCTION

Case 2:13-cv-01580-CJC-JC Document 12 Filed 07/11/13 Page 4 of 5 Page ID #:79



(c)

assisting, aiding or attempting to assist or aid any other person
or entity in performing any of the prohibited activities referred to in Paragraphs
5(a) and 5(b) above.

5.

Each party shall bear its own costs, expenses, and attorneys’ fees

associated with this Action.

6.

The execution of this Final Judgment shall serve to bind and obligate

the parties hereto.

7.

The jurisdiction of this Court is retained for the purpose of making
any further orders necessary or proper for the construction or modification of this
Final Judgment, the enforcement thereof and the punishment of any violations
thereof. Except as otherwise provided herein, this Action is fully resolved in favor
of Urban Expressions with prejudice as to Defendants.

8.

After the Court has entered this Judgment, Urban Expressions shall
promptly provide a copy of it to Defendants, and Urban Expressions shall file with
the Court a proof of service thereof within thirty (30) days thereafter.


Dated: July 11, 2013





Cormac J .Carney
United States District Judge




































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3283-009 130625 Final Judgment.doc

___________________________________________________________________________

FINAL JUDGMENT AND PERMANENT INJUNCTION

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Case 2:13-cv-01580-CJC-JC Document 12 Filed 07/11/13 Page 5 of 5 Page ID #:80



The undersigned parties to this Action consent to the entry of this Final

CONSENTS


















By:
Date:


Judgment and Permanent Injunction upon consent.

US Promotions, Inc.
dba Meghan Los Angeles


By:
Name:
Title:
Date:

Must Win, Inc.

By:

Name:
Title:
Date:


DATED: July 11, 13




























Sacha Hason








Urban Expressions, Inc.

By:

Name:
Title:
Date:






























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Respectfully submitted,
RUSS, AUGUST & KABAT



By:

Robert F. Gookin
Attorneys for Plaintiffs
Must Win, Inc. and Urban Expressions, Inc.



3283-009 130625 Final Judgment.doc

___________________________________________________________________________

FINAL JUDGMENT AND PERMANENT INJUNCTION



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