`
`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`
`FEDERAL TRADE COMMISSION,
`
`Plaintiff,
`
`v.
`
`ALCAZAR NETWORKS INC., a
`corporation, and
`
`GAVIN GRABIAS, individually and as an
`officer and owner of ALCAZAR
`NETWORKS INC.,
`
`Defendants.
`
`Case No. 6:20-cv-02200
`
`CONSENT MOTION TO
`APPROVE (PROPOSED)
`STIPULATED FINAL ORDER
`FOR PERMANENT INJUNCTION
`AND MONETARY JUDGMENT
`AS TO DEFENDANTS ALCAZAR
`NETWORKS INC. AND GAVIN
`GRABIAS
`
`CONSENT MOTION TO APPROVE (PROPOSED) STIPULATED FINAL ORDER FOR
`PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO DEFENDANTS
`ALCAZAR NETWORKS INC. AND GAVIN GRABIAS
`
`Plaintiff, the Federal Trade Commission (“FTC”), respectfully asks the Court to enter the
`
`attached proposed Stipulated Final Order for Permanent Injunction and Civil Penalty Judgment
`
`(“Stipulated Final Order”) as to Defendants Alcazar Networks Inc. and Gavin Grabias
`
`(“Defendants”).
`
`The proposed Stipulated Final Order is attached as Exhibit 1 to this Motion.
`
`The FTC and Defendants have agreed to the terms of the proposed Stipulated Final
`
`Order, as evidenced by their signatures and the signatures of their counsel.
`
`Defendants consent to the filing of this Motion. Accordingly, the FTC respectfully asks
`
`the Court to enter the proposed Stipulated Final Order.
`
`Entry of the proposed Stipulated Final Order will resolve this case in its entirety.
`
`
`
`Case 6:20-cv-02200-PGB-DCI Document 3 Filed 12/03/20 Page 2 of 2 PageID 23
`
`Dated: __12/3/2020____________
`
`Respectfully submitted,
`
` ____________________________________
`Ian L. Barlow
`Virginia G. Rosa
`Federal Trade Commission
`600 Pennsylvania Ave. NW, Mailstop 8525
`Washington, DC 20580
`202-326-3120 (Barlow)
`202-326-3068 (Rosa)
`ibarlow@ftc.gov
`vrosa@ftc.gov
`Attorneys for Plaintiff
`FEDERAL TRADE COMMISSION
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on December 3, 2020, I caused the foregoing Consent Motion to
`Approve the Proposed Stipulated Final Order for Permanent Injunction and Monetary Judgment
`on counsel for Defendants by U.S. mail and e-mail as follows:
`
`Michael A. Gruin, Esq.
`STEVENS & LEE
`17 N. 2nd Street, 16th Fl.
`Harrisburg, PA 17101
`Tel: (717) 255-7365
`mag@stevenslee.com
`Attorney for Defendants
`
`Joseph E. Wolfson, Esq.
`STEVENS & LEE
`1818 Market Street, 29th Fl.
`Philadelphia, PA 19103
`Tel: (215) 751-1249
`jwo@stevenslee.com
`Attorney for Defendants
`
`Christopher Van de Verg, Esq.
`VAN DE VERG LAW OFFICE, LLC
`145 W. Ostend Street, Suite 600
`Baltimore, MD 21230
`Tel: (410) 622-3878
`chris@vandeverglaw.com
`Attorney for Defendants
`
`_________________________________
`Ian L. Barlow
`
`2
`
`
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