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Case 1:22-cv-00396-TWP-TAB Document 32 Filed 08/31/22 Page 1 of 4 PageID #: 178
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF INDIANA
`INDIANAPOLIS DIVISION
`
`Case No. 1:22-cv-396-TWP-TAB
`
`STIPULATED MOTION FOR
`PERMANENT INJUNCTION
`
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`MICROSOFT CORPORATION, a Washington
`corporation,
`
`Plaintiff,
`
`v.
`SOLUTION HAT, LLC, an Indiana limited liability
`company, dba Think Global; and Saurabh Seth, an
`individual,
`
`Defendants.
`
`STIPULATION
`
`Plaintiff Microsoft Corporation (“Microsoft”) and Defendants Solution Hat LLC d/b/a
`
`ThinkGlobal and Saurabh Seth (collectively, “Defendants”) by and through their respective
`
`counsel of record, notify the Court that the parties have reached a settlement of all claims in this
`
`matter. Pursuant to the terms of that settlement, the Parties stipulate and agree to entry of the
`
`attached permanent injunction.
`
`DATED: August 31, 2022
`
`DAVIS WRIGHT TREMAINE LLP
`
`ADVITAM IP, LLC
`
`By s/ Meagan Himes______________
`Bonnie MacNaughton (admitted pro hac)
`920 Fifth Avenue, Suite 3300
`Seattle, Washington 98104
`(206) 757-3150 (Telephone)
`(206) 757-7700 (Facsimile)
`bonniemacnaughton@dwt.com
`
`By s/ Michele S. Katz (with permission)
`Michele S. Katz (admitted pro hac)
`150 S. Wacker Drive, Suite 2400
`Chicago, IL 60606
`(312) 332-7710 (Telephone)
`(312) 332-7701 (Facsimile)
`mkatz@advitamip.com
`
`1
`
`

`

`Case 1:22-cv-00396-TWP-TAB Document 32 Filed 08/31/22 Page 2 of 4 PageID #: 179
`
`Meagan Himes (admitted pro hac vice)
`1300 SW Fifth Avenue, Suite 2400
`Portland, Oregon 97210
`(503) 241-2300 (Telephone)
`(503) 778-5299 (Facsimile)
`meaganhimes@dwt.com
`
`BARNES & THORNBURG LLP
`Jeff M. Barron (27730-49)
`11 South Meridian Street
`Indianapolis, IN 46204-3535
`317-236-1313 (Telephone)
`317-231-7433 (Facsimile)
`jeff.barron@btlaw.com
`
`Attorneys for Plaintiff Microsoft Corporation
`
`HOOVER HULL TURNER LLP
`Alice M. Morical (18418-49)
`Christopher D. Wagner (32189-82)
`111 Monument Circle, Suite 4400
`P.O. Box 44989
`Indianapolis, IN 46244
`(317) 822-4400 (Telephone)
`(317) 822-0234 (Facsimile)
`amorical@hooverhullturner.com
`cwagner@hooverhullturner.com
`
`Attorneys for Defendants Solution Hat LLC
`d/b/a ThinkGlobal and Saurabh Seth
`
`2
`
`

`

`Case 1:22-cv-00396-TWP-TAB Document 32 Filed 08/31/22 Page 3 of 4 PageID #: 180
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF INDIANA
`INDIANAPOLIS DIVISION
`
`Case No. 1:22-cv-396-TWP-TAB
`
`STIPULATED PERMANENT
`INJUNCTION
`
`))
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`MICROSOFT CORPORATION, a Washington
`corporation,
`
`Plaintiff,
`
`v.
`
`SOLUTION HAT, LLC, an Indiana limited liability
`company, dba Think Global; and Saurabh Seth, an
`individual,
`
`Defendants.
`
`PERMANENT INJUNCTION
`
`Pursuant to the stipulation of the parties, IT IS HEREBY ORDERED that Defendant
`
`Solution Hat LLC d/b/a ThinkGlobal and its directors, principals, officers, employees,
`
`shareholders, agents, successors, assigns, and all others in active concert or participation with
`
`them, including but not limited to Defendant Saurabh Seth, are enjoined and restrained from:
`
`1.
`
`Using any trademarks registered by or otherwise associated with the Microsoft
`
`Corporation (the “Microsoft Trademarks”) or any simulation, reproduction, counterfeit, copy, or
`
`colorable imitation of them, in any manner in connection with any advertising, marketing, offer
`
`for sale, promotion, display, publication, website, email, or software, without Microsoft’s prior
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`written consent (which it has sole discretion to provide or withhold for any reason);
`
`2.
`
`Using any false designation of origin or false or misleading description or false or
`
`misleading representation that can or is likely to lead the trade or public or individuals
`
`erroneously to believe that any website, email, advertisement, pop-up, or other marketing
`
`3
`
`

`

`Case 1:22-cv-00396-TWP-TAB Document 32 Filed 08/31/22 Page 4 of 4 PageID #: 181
`
`material has been produced, distributed, displayed, licensed, sponsored, approved or authorized
`
`by or for Microsoft, when such is not true in fact;
`
`3.
`
`Engaging in any other activity constituting an infringement or dilution of any of
`
`the Microsoft Trademarks, or of Microsoft’s rights in, or right to use or to exploit, such
`
`trademarks or services marks; and
`
`4.
`
`Knowingly assisting any other person or business entity in engaging in or
`
`performing any of the activities listed above.
`
`This Court shall retain continuing jurisdiction over this matter for the limited purposes of
`
`enforcing the terms of the Parties’ settlement agreement and this Stipulated Permanent
`
`Injunction.
`
`DATED THIS ______ day of _____________, 2022.
`
`____________________________________
`UNITED STATES DISTRICT JUDGE
`
`Service will be made electronically on all ECF-registered
`counsel of record via email generated by the Court’s ECF system.
`
`4
`
`

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