STIPULATED FINAL JUDGMENT AND PERMANENT INJUNCITON

RONALD S.W. LEW, District Judge.

Plaintiffs Audi AG, Volkswagen AG, and Volkswagen Group of America, Inc. (collectively "Audi and VW") on the one hand, and defendants Onunwa Kelechi Iwuagwu and OKIXTREME dba Audibadges.com, Auto Accessories.com, Autobadges.com, Chromecarletters.com, Eurobadgez.com, Okixtreme.com, and Zzpdecals.com (collectively "Defendants") on the other hand, by and through their attorneys of record, hereby agree and stipulate to the following Permanent Injunction and Order of Dismissal With Prejudice regarding Defendants' use of Audi's and VW's trademarks and trade dress, including, but not limited to, AUDI®, the AUDI RINGS®, the AUDI GRILLE DESIGN®, RS4®, VW®, and the B IN WINGS® trademarks (hereinafter the "Audi and VW Marks").

PERMANENT INJUNCTION

1. Defendants and their owners, shareholders, officers, directors, employees, agents, successors, and all persons acting in concert or in participation with any of them are hereby permanently enjoined from:

(a) imitating, copying, or making unauthorized use of any of the Audi and/or VW Marks, counterfeits thereof, or any confusingly similar variations thereof;

(b) importing, manufacturing, producing, distributing, circulating, selling, offering for sale, advertising, promoting or displaying any product or good, including, but not limited to, any grilles, automobile badges, or other goods bearing the Audi and/or VW Marks or any simulation, reproduction, counterfeit, copy, or any confusingly similar variation of any of the Audi and/or VW Marks;

(c) using any simulation, reproduction, counterfeit, copy or confusingly similar variation of the Audi and/or VW Marks or trade dress in Defendants' business name, Internet domain name(s) (i.e. audibadges.com), or in connection with the promotion, advertisement, display, sale, offering for sale, manufacture, production, circulation or distribution of any service or product;

(d) using, registering, maintaining registrations for, or transferring to anyone other than to Audi and VW any Internet domain name that incorporates the Audi and/or VW Marks, including but not limited to audibadges.com. Defendants are further ordered to transfer immediately to Audi and VW audibadges.com, or any other domain names that use names, words, or designations, similar to the Audi and/or VW Marks;

(e) using any false designation of origin or false description, including without limitation, any letters or symbols constituting the Audi and/or VW Marks or trade dress, or performing any act, which can, or is likely to lead members of the trade or public to believe that Defendants and/or any service or product manufactured, distributed or sold by Defendants is in any manner associated or connected with Audi and/or VW, or is sold, manufactured, licensed, sponsored, approved or authorized by Audi and/or VW; and

(f) instructing, assisting, aiding or abetting any other person or business entity in engaging in or performing any of the activities referred to in subparagraphs (a) through (e) above.

2. Defendants are further ordered to deliver to Audi and VW and their counsel for destruction all products, labels, tags, signs, prints, packages, videos, and advertisements in their possession or under their control, bearing or using any or all of the Audi and/or VW Marks or any confusingly similar variation thereof, and all plates, molds, matrices and other means of making the same, pursuant to 15 U.S.C. § 1118. Alternatively, the parties have agreed to allow Defendants to destroy these items locally, rather than engage in the extra expense of delivering these items to Audi and VW

3. Defendants are further ordered to file with the Court and serve upon Audi's and VW's counsel within thirty (30) days after entry of this judgment, a report in writing under oath, setting forth in detail the manner and form in which Defendants have complied with the above.

4. Defendants are further ordered to permit Audi and VW, counsel for Audi and VW, and/or auditors for Audi and VW, to audit and inspect the books and records, and to inspect the premises of Defendants for a period of twelve months after entry of this judgement to assess Defendants' compliance with this Permanent Injunction.

PARTIES' SETTLEMENT AGREEMENT

Audi and VW, on the one hand, and Defendants, on the other hand, have entered into a Settlement Agreement for the resolution of the claims asserted in this matter. The Court retains jurisdiction to enforce the terms of said Settlement Agreement.

DISMISSAL OF CLAIMS

Based upon the parties' Stipulation and Settlement, all claims asserted by Audi and VW against Defendants in this action are hereby DISMISSED with prejudice. However, the Court retains and shall have continuing jurisdiction to enforce the terms of this Final Judgment and Permanent Injunction as well as the Settlement Agreement described above, but the clerk will close the case.

The Motion for Preliminary Injunction [11], filed September 14, 2017, is VACATED as MOOT.

SO ORDERED AND ADJUDGED.