[PROPOSED] STIPULATED PERMANENT INJUNCTION

VIRGINIA A. PHILLIPS, Chief District Judge.

This Court, makes the following findings of fact and conclusions of law pursuant to the parties' stipulation:

A. Plaintiff, Choice Hotels International, Inc. ("Choice Hotels" or "Plaintiff") filed suit against Defendants, Show Hotel, Inc. and Etour+, LLC (collectively "Defendants"), alleging that Defendants violated Choice Hotels' trademark rights under 15 U.S.C. sections 1114, 1125 (a), (c), and (d), and California common law (the "Lawsuit");

B. The Parties entered into a settlement agreement as of December 23, 2016 (the "Settlement Agreement"), which requires entry of the stipulated permanent injunction set forth herein;

For good cause appearing therefore, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT:

1. For the purpose of binding preclusive effect on Defendants as to future disputes with respect to the Lawsuit and/or the Settlement Agreement between Defendants on the one hand and Choice Hotels on the other hand, and only for such purposes, Defendants admit the following:

a. Choice Hotels is now, and has been at all times since the date of issuance the owner of the following United States Trademark Registration (collectively the "Marks") and of all rights thereto and thereunder:

viii. Choice Hotels is the owner of United States Trademark Registration No. 1,414,585 for the mark "RODEWAY INN + Design" for use in connection with the provision of hotel and motel services.

ix. Choice Hotels is the owner of United States Trademark Registration No. 3,449,309 for the mark "SLEEP INN + Design" for use in connection with the provision of hotel and motel services, hotel and motel reservation services for others, and online hotel and motel reservation services for others.

x. Choice Hotels is the owner of United States Trademark Registration No. 3,673,837 for the mark "SUBURBAN + Design" for use in connection with the provision of hotel services, hotel reservation services for others, and online hotel reservation services for others.

b. Defendants, by their actions described in the complaint in this action, have infringed upon Choice Hotels' Marks.

2. Defendants, and all those working on their behalf, including their respective owners, shareholders, principals, officers, agents, servants, employees, independent contractors, and partners, are permanently enjoined from using the Marks and/or any confusingly similar terms (collectively, the "Injunction"), unless and until, Defendants are provided prior written approval from Choice Hotels for such use. In order to be valid, a prior written approval by Choice Hotels must include execution of such a document by an attorney employed within Choice Hotels' in-house legal department.

3. Defendants are bound by the Injunction regardless of whether Choice Hotels assigns or licenses its intellectual property right to another for so long as such trademark rights are subsisting, valid, and enforceable. The Injunction inures to the benefit of Choice Hotels' successors, assignees, and licensees.

4. The Court's Magistrate Judge shall retain jurisdiction over all disputes between and among the Parties arising out of the Settlement Agreement and Injunction, the Stipulation which includes the Injunction, and this Permanent Injunction, including but not limited to interpretation and enforcement of the terms of the Settlement Agreement.

5. The Parties waive any rights to appeal this Permanent Injunction.

It is SO ORDERED.