STIPULATED PERMANENT INJUNCTION

RICARDO S. MARTINEZ, Chief District Judge.

STIPULATION

Plaintiffs Amazon.com, Inc. and Otter Products, LLC, and Defendants Ngullen Alejandro Rivera and NGS ICommerce Enterprises Corp., by and through their respective counsel of record, hereby stipulate and agree to entry of the permanent injunction below in connection with a settlement of all claims in this case.

PERMANENT INJUNCTION

Pursuant to the above stipulation of the parties, IT IS SO ORDERED that Defendants Ngullen Alejandro Rivera and NGS ICommerce Enterprises Corp., and their directors, principals, officers, successors and assigns, and all others in active concert or participation with them, are enjoined and restrained from:

1. Using any trademarks registered by or otherwise associated with Otter Products, LLC (the "Otter Products Trademarks") or any simulation, reproduction, counterfeit, copy, or colorable imitation of the Otter Products Trademarks, in any manner in connection with the manufacture, assembly, production, distribution, offering for distributing, circulation, sale, offering for sale, import, advertisement, promotion, or display of any product by Otter Products;

2. Advertising, selling, or facilitating the advertisement or sale of, via the Internet or otherwise, any Otter Products product or any products bearing any of the Otter Products Trademarks, and shall not use any of the Otter Products Trademarks, in any manner, including advertising on the Internet;

3. Manufacturing, assembling, producing, distributing, offering for distribution, circulating, selling, offering for sale, advertising, importing, promoting or displaying any products bearing any simulation, reproduction, counterfeit, copy, or colorable imitation of any of the Otter Products Trademarks, except as permitted by law or as otherwise authorized or allowed by Otter Products;

4. Using any false designation of origin or false or misleading description or false or misleading representation that can or is likely to lead the trade or public or individuals erroneously to believe that any product has been manufactured, assembled, produced, distributed, displayed, licensed, sponsored, approved or authorized by or for Otter Products, when such is not true in fact;

5. Engaging in any other activity constituting an infringement of any of Otter Products' Trademarks, or of Otter Products, LLC's rights in, or right to use or to exploit, such trademarks, services marks and/or copyrights;

6. Selling products on any of Amazon's websites or any websites participating in any Amazon Affiliate Program;

7. Applying for, opening, or using an Amazon seller account, or applying for participation in any Amazon Affiliate Program; or

8. Assisting, aiding, or abetting any other person or business entity in engaging in or performing any of the activities listed above.