[PROPOSED] ORDER FOR STIPULATED PERMANENT INJUNCTION

RICHARD F. BOULWARE, II, District Judge.

WHEREAS, on December 9, 2016, Plaintiffs Equalia LLC and Hoverboard Technologies Corporation (collectively, "Equalia"), filed a civil action seeking relief for patent infringement under 35 U.S.C. §271, and unfair and deceptive trade practices under 15 U.S.C. §45, entitled Equalia LLC, et al. v. Kushgo LLC, et al., in the United States District Court, District of Nevada, Case No. 2:16-cv-2851-RFB (the "Nevada Litigation") against Defendants Kushgo LLC, Halo Board LLC, and Arthur Andreasyan (collectively, "Defendants");

WHEREAS, on February 19, 2017, Defendants filed an appeal with the United States Court of Appeals for the Federal Circuit, entitled Equalia LLC, et al. v. Kushgo LLC, et al., Case No. 17-1658 (the "Appellate Litigation");

WHEREAS, Equalia and Defendants (collectively, "Parties") have reached an agreement ("Settlement Offer") to resolve the Nevada Action and the Appellate Litigation, and now wish to stipulate to the entry of a Permanent Injunction;

NOW, THEREFORE, the Parties, by and through their counsel, hereby STIPULATE to the entry of the following Permanent Injunction and request an Order for an injunction pursuant to 35 U.S.C. §283 and Fed. R. Civ. P. 65, that Defendants Kushgo, LLC, Halo Board, LLC, and Arthur Andreasyan, as well as their officers, agents, servants, employees, attorneys, and any other persons in active concert or participation with them are PERMANENTLY ENJOINED from marketing, displaying, making, using, offering to sell, or selling within the United States, or importing into the United States, the accused "Halo Board" product(s) and all other products any substantially similar version thereof, online within the United States or in any physical location within the United States.

This permanent injunction is understood to be consistent with the Court's order of January 20, 2017 as entered in Case No. 16-CV-02851. Docket 50.

IT IS SO STIPULATED.

IT IS SO ORDERED.