STIPULATED JUDGMENT AND PERMANENT INJUNCTION

ANDREW J. GUILFORD, District Judge.

Plaintiff Experian Information Solutions, Inc. ("Experian"), and Defendant Ellypsis, Inc., a corporation doing business as Go Clean Credit, have stipulated to entry of judgment and this permanent injunction as part of their Settlement Agreement dated August 8, 2017. Based on this stipulation, and good cause appearing therefor,

IT IS HEREBY ORDERED, ADJUDGED AND DECREED that:

1. Judgment shall be entered in favor of Experian and against Ellypsis, Inc. in the amount of One Million Dollars ($1,000,000.00) and enforceable as otherwise provided in the Settlement Agreement. This monetary Judgment shall expire five (5) years after the date it is entered.

2. Ellypsis, Inc., its officers, agents, servants, employees, and attorneys, and other persons who are in active concert or participation with the foregoing regarding Ellypsis' operations as a credit repair organization, and who receive notice of this Order, are permanently ENJOINED from:

a. violating the Credit Repair Organizations Act, 15 U.S.C. § 1679 et seq. and the California Credit Services Act, Cal. Civil Code § 1789.10 et seq.; and

b. transmitting by any means, including by deposit in the U.S. Mail, a letter or other communication disputing the completeness or accuracy of any item of information contained in a consumer file at a consumer reporting agency.

c. This injunction will apply with full force and effect to any corporation, limited liability company, sole proprietorship or other entity in which Michael McCraw or Dawn McCraw, either separately or jointly, own a controlling interest of at least 50.1 percent and operating as a credit repair organization as defined by The Credit Repair Organizations Act, 15 U.S.C. §1679 et. seq.

This Court retains jurisdiction of this matter and of the parties for the purpose of enforcing the provisions of this judgment and decree.

IT IS SO ORDERED, ADJUDGED AND DECREED.