AMENDED ORDER FOR ASSET SEIZURE AND IMPOUNDMENT

ROBERT C. JONES, District Judge.

The Court issued its Order for Asset Seizure and Impoundment against Defendants AF LLC, ART LLC, Inkredible LLC LLC, Andriy Kravchuk, Igor Bielov, Artem Koshkalda and Vitalli Maliuk on August 22, 2017, Docket No. 159.

On October 10, 2017, the Court issued an Order setting a hearing on Plaintiffs Seiko Epson Corporation and Epson America, Inc.'s (collectively "Plaintiffs") Emergency Ex Parte Application for Order to Show Cause re Contempt as to Artem Koshkalda and Vladimir Westbrook, Docket No. 155 ("Motion to Show Cause"), providing Defendant Koshkalda an extension to respond to the Motion to Show Cause and requiring Defendants Koshkalda and Westbrook's personal appearance before the Court on October 23, 2017 at 11:00 am. Docket No. 222. Defendant Koshkalda filed his response to the Motion to Show Cause on October 18, 2017, Docket No. 228, and Plaintiffs filed their Objections and Reply on October 20, 2017. Docket Nos. 229-230. Notice of the Hearing Location was also issued on October 20, 2017. Docket No. 227. Plaintiffs also served Notices of the October 10, 2017, Order, as well as the Notice of the Hearing Location on Defendants. Docket Nos. 234-235, 248. Despite notice of the October 10, 2017, Order, Defendants Koshkalda and Westbrook did not personally appear at the hearing on October 23, 2017 at 11:00 am, and therefore, the Court hereby finds Defendants Koshkalda and Westbrook in contempt of Court and AMENDS its Order for Asset Seizure and Impoundment as set forth herein as against Defendants Artem Koshkalda, ART LLC, and any other company owned or controlled by him ("Defendants"), as well as any individuals acting in concert with them, including Vladimir Slobodianiuk a/k/a Volodymyr Slobodianiuk a/k/a Vladimir Westbrook ("Westbrook"), having made the following findings:

1. Plaintiffs have made a strong showing of success on the merits in showing that Defendants are using Plaintiffs' trademarks or marks confusingly similar to Plaintiffs' trademarks, including those attached hereto as Exhibit A ("Plaintiffs' Trademarks") in connection with the importation, manufacture, distribution, sale and offer for sale of counterfeit and/or infringing ink cartridges bearing unauthorized reproductions or substantially similar copies of registered trademarks owned by Plaintiffs ("Unauthorized Products").

2. Defendants' discovery defaults further strengthen the conclusion of Plaintiffs' likelihood of success on the merits.

3. Plaintiffs have shown that proceeds from Defendants' infringement were deposited into a large number of bank accounts and also used to purchase valuable real estate, among other things,

4. Plaintiffs have shown that Defendants have and are likely to further liquidate or dissipate assets, that they have a history of transferring money to family members and using shell companies to hide assets or the source of money, and that they are a flight risk such that Plaintiffs will be unable to obtain an equitable accounting or recover Defendants' profits if the relief is not granted.

5. The Defendants' dissipation, secreting, and hiding of assets will result in immediate and irreparable injury to Plaintiffs if this relief is not ordered.

6. The harm to Plaintiffs of denying the requested injunction outweighs the harm to the legitimate interest of Defendants from granting such order,

7. The public interest is served by entry of the present order to prevent Defendants from profiting from their infringement.

8. The Court has jurisdiction over the subject matter of this action and over Plaintiffs and Defendants.

9. Plaintiffs have shown that Defendants have access to funds outside of this Court's prior Temporary Restraining Order and Order for Asset Freeze and Impoundment and that Defendant Koshkalda, and others, have acted in violation and in willful contempt of those Orders despite service and actual notice of the Orders.

10. THEREFORE, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that Defendants, any person acting in concert with them, whether acting directly or through any entity, corporation, subsidiary, division, affiliate or other device, or any third-party service provider who is served with a copy of this Order, other than Inksystem LLC and Lucky Print LLC, or has knowledge of this Order by personal service or otherwise, are enjoined and restrained from:

11. IT IS FURTHER ORDERED that Defendants may pay any monetary Court ordered sanction without leave of Court.

12. IT IS FURTHER ORDERED that the assets affected by this Order shall include both existing assets and assets acquired after the effective date of this Order expressly excluding those of Inksystem LLC and Lucky Print LLC.

13. IT IS FURTHER ORDERED that Defendants' third-party service providers or others acting in concert with them, specifically including but not limited to Westbrook, or any financial or brokerage institution, business entity, or person served with a copy of this Order that holds, controls, or maintains custody of any account or asset of Defendants, or that has held, controlled, or maintained custody of any such account or asset at any time since the date of entry of this Order, expressly excluding those of Inksystem LLC and Lucky Print LLC, shall:

14. IT IS FURTHER ORDERED that during the pendency of this action all bank accounts owned by Defendants or any of their corporate entities, other than Inksystem LLC and Lucky Print LLC, to which at least one of the Defendants own some interest, including but in no way limited to those accounts identified in Exhibit B, expressly excluding those of Inksystem LLC and Lucky Print LLC, are hereby impounded.

15. IT IS FURTHER ORDERED that Defendants' third-party service providers or others acting in concert with them, or any financial or brokerage institution, business entity, or person served with a copy of this Order that holds, controls, or maintains custody of any account or asset of Defendants, expressly excluding those of Inksystem LLC and Lucky Print LLC, or that has held, controlled, or maintained custody of any such account or asset at any time since the date of entry of this Order shall comply with paragraphs 9-14 herein.

16. IT IS FURTHER ORDERED that the Court may appoint a special master or receiver to which Defendants and any of their corporate entities to which at least one of the Defendants own some interest, expressly excluding those of Inksystem LLC and Lucky Print LLC, must report and request authorization to transfer any assets.

17. IT IS FURTHER ORDERED that this Preliminary Injunction is issued without the posting of any additional bond. The bond or surety in the form of a check or cash in the amount of $100,000, Docket No. 11, currently on file in this case will also be used to secure the payment of any costs or damages, not to exceed twice the sum as may be suffered or sustained by any party who is wrongfully restrained thereby.

18. IT IS FURTHER ORDERED that this Order may be recorded, filed and/or lodged with any local, state or other authority including but not limited to the County Recorder's Office where any real property at issue is located.

19. IT IS FURTHER ORDERED that the Court may change this Order at any time upon application.

20. IT IS FURTHER ORDERED that with respect to Defendants Artem Koshkalda and ART LLC only, this Order will supersede the prior Order for Asset Freeze and Impoundment. Docket No. 159. The Order for Asset Freeze and Impoundment, Docket No. 159, will remain in full force and effect as to all other defendants identified therein and in all other respects except as set forth herein.

21. This Order shall be deemed to have been served upon Defendants at the time of the signing thereof by the Court.

IT IS SO ORDERED.

EXHIBIT A

SEC'S TRADEMARKS

EXHIBIT B

PROOF OF SERVICE

I, the undersigned, certify and declare that I am over the age of 18 years, employed in the County of Los Angeles, and not a party to the above-entitled cause. I am employed by a member of the Bar of the United States District Court of Nevada. My business address is 520 East Wilson Avenue, Suite 200, Glendale, California 91206.

On October 26, 2017, I served on the interested parties in this action with: NOTICE OF LODGING OF [PROPOSED] ORDERS RE CONTEMPT AS TO ARTEM KOSHKALDA AND VLADIMIR WESTBROOK

in support for the following civil action:

Seiko Epson Corporation, et al. v. InkSystem LLC, et al.

x via the United States District Court CM/ECF system;

x by email to artemkoshkalda@gmail.com for Defendants Artem Koshkalda and ART LLC per Defendant Koshkalda's request;

x by placing a true copy thereof in an envelope to be immediately sealed thereafter to the below Defendants. I am readily familiar with the office's practice of collecting and processing correspondence for mailing. Under that practice it would be deposited with the United States Postal Service on the same day with postage thereon fully prepaid at Glendale, California in the ordinary course of business. I am aware that on motion of the party served, service presumed invalid if postal cancellation date or postage meter is more than one day after date of deposit for mailing in affidavit.

Place of Mailing: Glendale, California

Executed on October 26, 2017 at Glendale, California