[PROPOSED] CONSENT DECREE AND PERMANENT INJUNCTION

ANDRÉ BIROTTE, Jr., District Judge.

The Court, having read and considered the Joint Stipulation for Entry of Consent Decree and Permanent Injunction that has been executed by Plaintiff DeVry/Becker Educational Development Corporation ("Plaintiff") and Defendants Teodor Brestnichki d/b/a William Camper ("Brestnichki") and Mary Kostov a/k/a Marinela Kostova ("Kostov") (collectively "Defendants"), in this action, and good cause appearing therefore, hereby:

ORDERS that based on the Parties' stipulation and only as to Defendants, their successors, heirs, and assignees, this Injunction 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 17 U.S.C. § 101 et seq., and 28 U.S.C. §§ 1331 and 1338. Service of process was properly made against Defendants.

2) Plaintiff is the owner of all rights in and to the copyright and trademark registrations listed in Exhibits A and B attached hereto and incorporated herein by this reference (collectively referred to herein as "Plaintiff's Properties").

3) Plaintiff has alleged that Defendants have made unauthorized uses of Plaintiff's Properties or substantially similar likenesses or colorable imitations thereof.

4) Defendants and their agents, servants, employees and all persons in active concert and participation with them who receive actual notice of the Injunction are hereby restrained and enjoined from:

5) Each side shall bear its own fees and costs of suit.

6) Except as provided herein, all claims alleged in the First Amended Complaint against Defendants are dismissed with prejudice.

7) This Injunction shall be deemed to have been served upon Defendants at the time of its execution by the Court.

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

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 Injunction.

10) The above-captioned action, shall, upon filing by Plaintiff of the Settlement Agreement, Stipulation for Entry of Judgment and Judgment Pursuant to Stipulation, and requesting entry of judgment against Defendants, be reopened should Defendants default under the terms of the Settlement Agreement. 11) This Court shall retain jurisdiction over Defendants, for a period of ten (10) years from the date of entry of this Consent Decree and Permanent Injunction on PACER, pursuant to Kokkonen vs. Guardian Life Insurance Corporation, 511 U.S. 375 (1994), for the purpose of making further orders necessary or proper for the construction or modification of this consent decree and judgment; the enforcement hereof; the punishment of any violations hereof; and for the possible entry of a further Judgment Pursuant to Stipulation in this action.

EXHIBIT A

COPYRIGHT REGISTRATIONS

EXHIBIT B

TRADEMARK REGISTRATIONS

Trademark Registration No.: Title of Work: Rights Owner: DeVry/Becker Educational 3823222 Becker Navigator Development Corp. DeVry/Becker Educational 3792821 The Becker Promise Development Corp. DeVry/Becker BECKER Educational 3797392 PROFESSIONAL EDUCATION Development Corp. DeVry/Becker BECKER Educational 3804616 PROFESSIONAL EDUCATION Development Corp. DeVry/Becker Educational 3797284 Becker Professional Education Development Corp. DeVry/Becker Educational 3602482 Fastpass Development Corp. DeVry/Becker Educational 3601875 Becker Fastpass Development Corp. DeVry/Becker Educational 2752526 Stalla Development Corp. DeVry/Becker Educational 3514613 Passmaster Development Corp.