[PROPOSED] JUDGMENT PURSUANT TO ENTRY OF DEFAULT

MAXINE M. CHESNEY, District Judge.

This cause having come before this Court on the motion of Plaintiff Adobe Systems Incorporated ("Adobe" or "Plaintiff") for entry of default judgment and permanent injunction against Defendant Wireless International, LLC ("Defendant");

AND, the Court having read and considered the pleadings, declarations and exhibits on file in this matter and having reviewed such evidence as was presented in support of Plaintiff's Motion;

AND, GOOD CAUSE APPEARING THEREFORE, the Court finds the following facts:

Plaintiff is the owner of all rights in and to certain copyright registrations including but not limited to, the copyrights which are the subject of the registrations listed in Exhibit A ("Plaintiff's Copyrights");

Plaintiff has complied in all respects with the laws governing copyrights and secured the exclusive rights and privileges in and to Plaintiff's Copyrights;

The appearance and other qualities of Plaintiff's Copyrights are distinctive and original;

Plaintiff is the owner of all rights in and to certain trademark registrations listed in Exhibit B, including (collectively "Plaintiff's Trademarks").

Plaintiff has complied in all respects with the laws governing trademarks and secured the exclusive rights and privileges in and to Plaintiff's Trademarks;

Defendant engages in the unauthorized business of importing, distributing, promoting, selling and/or offering for sale through prohibited channels featuring Plaintiff's Copyrights and Trademarks ("Unauthorized Product").

Defendant's importing, advertising, displaying, promoting, marketing, distributing, providing, offering for sale and selling of the Unauthorized Product was engaged in willfully and intentionally, without leave or license from Plaintiff, in violation of Plaintiff's rights in and to Plaintiff's Copyrights and Trademarks. The devices, emblems, and artwork on the Unauthorized Product are not just "confusingly similar" to Plaintiff's Copyrights and Trademarks, they are identical.

Plaintiff has instituted this action for an entirely proper and appropriate purpose, solely to vindicate and enforce compliance with its rights which have been knowingly and willfully infringed by Defendant and to recover for infringement of such rights. Plaintiff's action was not brought frivolously. In contrast, Defendant's infringing conduct, is a clear and unmistakable violation of Plaintiff's rights. Defendant's conduct has been patently unreasonable and egregious, violating Plaintiff's rights by appropriating and featuring Plaintiff's Copyrights and Trademarks on unauthorized product, when Defendant's intended, or knew or should have known, that such infringing activity would likely injure Plaintiff's name and reputation, requiring Plaintiff to institute and prosecute this action, and incur fees and costs in so doing, in order to attempt to obtain Defendant's recognition and compliance with Plaintiff's rights.

The liability of the Defendant in the above-referenced action for its acts in violation of Plaintiff's rights is knowing and willful, and as such the Court expressly finds that there is no just reason for delay in entering the default judgment and permanent injunction sought herein.

Therefore, based upon the foregoing facts, and

GOOD CAUSE APPEARING THEREFORE, THE COURT ORDERS that this Judgment, for the reasons set forth in Plaintiff's motion, shall be and is hereby entered in the within action as follows:

1) This Court has jurisdiction over the parties to this action and over the subject matter hereof pursuant to 15 U.S.C. § 1051 et seq., 28 U.S.C. §§ 1331 and 1338, and 28 U.S.C. § 1367. Service of process was properly made on the Defendant.

2) Defendant has distributed, sold, and offered for sale unauthorized merchandise which infringes upon Plaintiff's Copyrights and Trademarks.

3) The Defendant and its agents, servants, employees and all persons in active concert and participation with it who receive actual notice of the injunction are hereby restrained and enjoined from:

4) Defendant is ordered to deliver forthwith for destruction all Unauthorized Product, and any other unauthorized products which picture, reproduce, copy or use the likenesses of or bear a substantial similarity to any of Plaintiff's Copyrights and Trademarks and any labels, signs, prints, packages, dyes, wrappers, receptacles and advertisements relating thereto in their possession or under their control bearing any of Plaintiff's Copyrights and Trademarks or any simulation, reproduction, copy or colorable imitations thereof, and all plates, molds, heat transfers, screens, matrices and other means of making the same.

5) Defendant is ordered to pay damages to Plaintiff pursuant to 17 U.S.C. § 504 in the sum of Fifty Thousand Dollars ($50,000.00).

6) Defendant is ordered to pay interest on the principal amount of the judgment to Plaintiff at the statutory rate pursuant to 28 U.S.C. §1961(a).

7) This Plaintiff shall serve this Judgment shall be deemed to have been served upon Defendant at the time of its execution by the Court.

8) The Court finds there is no just reason for delay in entering this Judgment and, pursuant to Rule 54(a) of the Federal Rules of Civil Procedure, the Court directs immediate entry of this Judgment against Defendant.

9) The Court shall retain jurisdiction of this action to entertain such further proceedings and to enter such further orders as may be necessary or appropriate to implement and enforce the provisions of this Judgment.

EXHIBIT A

Copyright Registrations

EXHIBIT B

Trademark Registrations

Trademark Title of Work: Rights Owner: Registration No.: 2,081,343 A Adobe Systems Incorporated 1,988,710 A Adobe Systems Incorporated 3,032,288 A Adobe Systems Incorporated 3,652,388 Adobe Systems Incorporated STYLIZED 3,652,387 Adobe Systems Incorporated STYLIZED 3,652,386 Adobe Systems Incorporated STYLIZED 1,901,149 A Adobe Adobe Systems Incorporated 1,852,943 "A" STYLIZED (ACROBAT DESIGN) Adobe Systems Incorporated 1,988,711 A Adobe Systems Incorporated 3,652,384 ACROBAT Adobe Systems Incorporated 3,652,383 ACROBAT Adobe Systems Incorporated 3,652,382 ACROBAT Adobe Systems Incorporated 2,068,523 ACROBAT Adobe Systems Incorporated 1,833,219 ACROBAT Adobe Systems Incorporated 1,997,398 ACROBAT CAPTURE Adobe Systems Incorporated 3,380,847 ACTIONSCRIPT Adobe Systems Incorporated 2,221,926 ACTIVETEST Macromedia, Inc. 1,475,793 ADOBE Adobe Systems Incorporated 1,486,895 ADOBE Adobe Systems Incorporated 1,956,216 ADOBE Adobe Systems Incorporated 1,988,712 ADOBE Adobe Systems Incorporated 3,029,061 ADOBE Adobe Systems Incorporated 3,548,719 ADOBE AIR Adobe Systems Incorporated 2,861,671 ADOBE AUDITION Adobe Systems Incorporated 1,855,098 ADOBE DIMENSIONS Adobe Systems Incorporated 2,916,709 ADOBE ENCORE Adobe Systems Incorporated 1,631,416 ADOBE GARAMOND Adobe Systems Incorporated 1,479,408 ADOBE ILLUSTRATOR Adobe Systems Incorporated 3,065,143 ADOBE LIVECYCLE Adobe Systems Incorporated 1,673,308 ORIGINALS DESIGN Adobe Systems Incorporated 1,651,380 ADOBE PHOTOSHOP Adobe Systems Incorporated 1,769,184 ADOBE PREMIERE Adobe Systems Incorporated 1,605,378 ADOBE TYPE MANAGER Adobe Systems Incorporated 1,707,807 ADOBE WOOD TYPE Adobe Systems Incorporated 1,970,781 AFTER EFFECTS Adobe Systems Incorporated 1,977,310 ALEXA Adobe Systems Incorporated 3,548,718 AIR Adobe Systems Incorporated 2,234,653 ANDREAS Adobe Systems Incorporated 3,438,976 ARNO Adobe Systems Incorporated

3,484,805 ARNO Adobe Systems Incorporated 1,961,762 AUTHORWARE Adobe Systems Incorporated 2,034,149 BALZANO Adobe Systems Incorporated 2,137,197 BANSHEE Adobe Systems Incorporated 2,024,607 BENSON SCRIPTS Adobe Systems Incorporated 2,137,890 BICKHAM SCRIPT Adobe Systems Incorporated 1,692,614 BIRCH Adobe Systems Incorporated 1,692,613 BLACKOAK Adobe Systems Incorporated 2,523,062 BLUE ISLAND Adobe Systems Incorporated 3,502,888 IGN Adobe Systems Incorporated 3,065,084 BREEZE Adobe Systems Incorporated 2,864,988 BREEZE Adobe Systems Incorporated 2,799,082 BRIOSO Adobe Systems Incorporated 3,688,153 BUSINESSCATALYST Adobe Systems Incorporated 3,422,754 BUZZWORD Adobe Systems Incorporated 1,892,606 CAFLISCH SCRIPT Adobe Systems Incorporated 2,449,593 CALCITE Adobe Systems Incorporated 1,982,999 CALIBAN Adobe Systems Incorporated 3,184,511 CAPTIVATE Adobe Systems Incorporated 3,136,772 CAPTIVATE Adobe Systems Incorporated 3,189,917 CAPTIVATE Adobe Systems Incorporated 1,582,280 CARTA Adobe Systems Incorporated 2,089,496 CHAPARRAL Adobe Systems Incorporated 1,629,024 CHARLEMAGNE Adobe Systems Incorporated 3,502,888 CILE AND BLACK MARK Adobe Systems Incorporated 1,901,215 CLASSROOM IN A BOOK Adobe Systems Incorporated 2,993,457 CO-AUTHOR Adobe Systems Incorporated 1,971,442 COLD FUSION Adobe Systems Incorporated 2,113,033 CONGA BRAVA Adobe Systems Incorporated 3,143,377 CONTRIBUTE Adobe Systems Incorporated 1,982,985 COPAL Adobe Systems Incorporated 2,164,702 CORIANDER Adobe Systems Incorporated 1,628,152 COTTONWOOD Adobe Systems Incorporated 3,111,341 CREATIVE SUITE Adobe Systems Incorporated 1,873,167 CRITTER Adobe Systems Incorporated 2,093,645 CRONOS Adobe Systems Incorporated 1,665,322 CUSTOMERFIRST Adobe Systems Incorporated 3,109,946 CUSTOM INSIGHT Adobe Systems Incorporated 1,600,438 DIRECTOR Adobe Systems Incorporated 1,843,525 DISTILLER Adobe Systems Incorporated 3,484,827 DNG Adobe Systems Incorporated 2,294,926 DREAMWEAVER Adobe Systems Incorporated 3,276,189 DV RACK Adobe Systems Incorporated 2,949,766 ENCORE Adobe Systems Incorporated 2,893,662 EPAPER Adobe Systems Incorporated 2,005,020 EX PONTO Adobe Systems Incorporated 3,578,808 F Adobe Systems Incorporated 2,043,911 FIREWORKS Adobe Systems Incorporated 2,855,434 FLASH Adobe Systems Incorporated 2,852,245 FLASH Adobe Systems Incorporated 3,819,617 FLASH ACCESS Adobe Systems Incorporated

2,971,613 O Adobe Systems Incorporated 3,375,906 OFFERMATICA Adobe Systems Incorporated 3,021,696 OMNITURE Adobe Systems Incorporated 3,287,161 OMNITURE DISCOVER Adobe Systems Incorporated 3,386,437 OMNITURE DISCOVER Adobe Systems Incorporated 3,539,388 OMNITURE GENESIS Adobe Systems Incorporated 3,282,842 OMNITURE SEARCHCENTER Adobe Systems Incorporated 2,137,926 OUCH! Adobe Systems Incorporated 3,665,058 OVATION Adobe Systems Incorporated 3,427,904 P Adobe Systems Incorporated 3,660,906 P Adobe Systems Incorporated 2,091,087 PAGEMAKER Adobe Systems Incorporated 1,486,556 PAGEMAKER Adobe Systems Incorporated 2,979,463 PDF JOBREADY Adobe Systems Incorporated 1,984,563 PENUMBRA Adobe Systems Incorporated 1,882,825 PEPPERWOOD Adobe Systems Incorporated 1,850,242 PHOTOSHOP Adobe Systems Incorporated 2,920,764 PHOTOSHOP Adobe Systems Incorporated 3,702,607 PHOTOSHOP Adobe Systems Incorporated 3,693,558 PIXEL BENDER Adobe Systems Incorporated 2,066,675 GLE LINE RECTANGLES Adobe Systems Incorporated 1,760,600 POETICA Adobe Systems Incorporated 1,692,610 POPLAR Adobe Systems Incorporated 2,233,952 POSTINO Adobe Systems Incorporated 1,544,284 POSTSCRIPT Adobe Systems Incorporated 1,463,458 POSTSCRIPT Adobe Systems Incorporated 1,383,131 POSTSCRIPT Adobe Systems Incorporated 2,066,675 POSTSCRIPT LOGO Adobe Systems Incorporated 1,887,832 QUAKE Adobe Systems Incorporated 1,935,820 RAD Adobe Systems Incorporated 2,548,832 READER Adobe Systems Incorporated 3,629,002 REAL-TIME ANALYTICS Adobe Systems Incorporated 2,204,266 RELIQ Adobe Systems Incorporated 2,953,255 ROBOENGINE Adobe Systems Incorporated 1,732,772 ROBOHELP Adobe Systems Incorporated 2,498,876 ROBOHELP Adobe Systems Incorporated 1,882,826 ROSEWOOD Adobe Systems Incorporated 2,993,082 RYO Adobe Systems Incorporated 1,893,565 SANVITO Adobe Systems Incorporated 2,893,840 SAVA Adobe Systems Incorporated 2,690,899 SCENE7 Adobe Systems Incorporated 3,410,080 SEE WHAT'S POSSIBLE Adobe Systems Incorporated 3,829,118 BARS-BANDS DESIGN Adobe Systems Incorporated 3,829,117 BARS-BANDS DESIGN Adobe Systems Incorporated 2,603,706 SHOCKWAVE Adobe Systems Incorporated 2,606,691 SHOCKWAVE Adobe Systems Incorporated 1,901,566 SHOCKWAVE Adobe Systems Incorporated 2,648,129 SHOCKWAVE Adobe Systems Incorporated 2,388,945 SHOCKWAVE Adobe Systems Incorporated