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Dwight C. Donovan (SBN 114785) 

ddonovan@foxrothschild.com 

Jack Praetzellis (SBN 267765) 

jpraetzellis@foxrothschild.com 

FOX ROTHSCHILD LLP 

345 California Street, Suite 2200 

San Francisco, California 94104 

Telephone: (415) 364-5540 

Facsimile: (415) 391-4436 

Attorneys for Plaintiff Rodan & Fields, LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

RODAN & FIELDS, LLC, a California limited CASE No. 16-cv-07242-JSC 

liability company, 

JPROPOSEDI STIPULATED FINAL 

Plaintiff, JUDGMENT AND PERMANENT INJUNCTION 

v. 

SHAZAD GILANI; et al., 

Defendants. 

Plaintiff, Rodan & Fields, LLC ("R+F"), and defendants Shaikh Kashif Ali ("Ali'), 

Shazad Gilani ("Gilani"), Darlin Gelilang ("Gelilang"), and Top Brands International, Inc. ("Top 

Brands") (collectively, "Named Defendants"), reached a compromise and an agreement to settle 

this action through the Confidential Settlement and Release Agreement, dated September 6, 2017 

(the "Agreement"). It is stipulated, agreed and acknowledged by R+F and Named Defendants 

that neither the Agreement nor this Stipulated Final Judgment and Permanent Injunction is an 

admission of liability by any party for any matter under the terms of the Agreement, and that the 

parties have consented to the form and substance of the following order. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED, pursuant to the stipulation 

and consent of the parties, that all claims against Named Defendants are hereby dismissed with 

prejudice, subject to: 

[PROPOSED] STIPULATED FINAL JUDGMENT 

AND PERMANENT INJUNCTION 

CASE No. 16-cv-07242-JSC 

Case 3:16-cv-07242-JSC Document 45 Filed 10/03/17 Page 1 of 5
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I. PERMANENT INJUNCTION 

Defendants Ali and Top Brands, including anyone acting on their behalf or at their direction, are hereby permanently restrained and enjoined from: 

(1) any use of R+F's trademarks registered with the United States Patent and Trademark 

Office with respect to its brand and products, including, but not limited to, Rodan & 

Fields® (U.S. Trademark Registration Nos. 2,372,867 and 2,371,069), Rodan + 

Fields® (U.S. Trademark Registration No. 3,165,883), and Rodan + Fields Enhancements® (U.S. Trademark Registration No. 3,841,995) (collectively, the "R+F Registered Trademarks"); 

(2) advertising, selling, or facilitating the advertisement or sale of, via the Internet or otherwise, any goods or products bearing any of the R+F Registered Trademarks; 

(3) facilitating the advertisement or sale of, via the Internet or otherwise, any goods or 

products bearing any of the R+F Registered Trademarks; 

(4) using the R+F Registered Trademarks in any manner, including advertising on the Internet; 

(5) purchasing or acquiring products bearing any of the R+F Registered Trademarks for 

the purpose of resale; and 

(6) importing, exporting, manufacturing, producing, distributing, circulating, shipping, 

selling, offering to sell, advertising, promoting, or displaying any goods or products 

bearing any of the R+F Registered Trademarks. 

H. MONITORING COMPLIANCE 

It is further ORDERED that defendants Ali and Top Brands shall: 

(1) Take all reasonable steps sufficient to monitor and ensure that all persons within Ali's 

or Top Brands' control or employment (whether independent contractors, employees, 

agents, partners, or otherwise) comply with this Order, including by not limited to, 

providing a copy of this Order to any person within their control or employment and 

requiring that such persons adhere to its terms; and 

[PROPOSED] STIPULATED FINAL JUDGMENT 

AND PERMANENT INJUNCTION 

-2- CASE No. 16-cv-07242-JSC 

Case 3:16-cv-07242-JSC Document 45 Filed 10/03/17 Page 2 of 5
(2) Taking all reasonable corrective action with respect to any individual within their control or employment whom defendants Ali and Top Brands determine is not in compliance with the terms of this Order, which may include training, disciplining, and/or 

terminating such individual, and notifying R+F in writing of the underlying conduct. 

III. PERSONS BOUND 

It is further ORDERED that, pursuant to Rule 65(d)(2) of the Federal Rules of Civil Procedure, this Order is binding upon the following persons who receive actual notice of it: the parties, the parties' officers, agents, servants, employees, and attorneys, and other persons who are in 

active concert or participation with the parties or the parties' officers, agents, servants, employees, and attorneys. 

IV. RETENTION OF JURISDICTION 

It is further ORDERED that this Court shall retain jurisdiction of this matter in law and in 

equity for the purposes of enforcing and/or adjudicating claims in violation of this Order or of 

disputes arising out of, or in connection with, the Confidential Settlement and Release Agreement 

entered into the parties hereto. Any such matters shall be raised by noticed motion. 

Each party shall bear its own costs, expenses and attorneys' fees. All claims against Defendants John Does 1-100 are hereby dismissed without prejudice. 

IT IS SO ORDERED. 

SIGNED and ENTERED this day of 2017. 

UNITED STATES MAGISTRATE JUDGE 

[PROPOSED] STIPULATED FINAL JUDGMENT 

AND PERMANENT INJUNCTION 

-3- CASE No. 16-cv-07242-JSC 

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Case 3:16-cv-07242-JSC Document 45 Filed 10/03/17 Page 3 of 5
Shazad Gilani, Defendant, Pro Se 

Darlin Gelilang, Defendant, Pro Se 

Dwight C. Donovan (SBN 114785) 

ddonovan®foxrothschild.com 

Jack Praetzellis (SBN 267765) 

jpraetzellis®foxrothschild.com 

FOX ROTHSCHILD LLP 

345 California Street, Suite 2200 

San Francisco, California 94104 

Telephone: (415) 364-5540 

Facsimile: (415) 391-4436 

Attorneys for Plaintiff Rodan & Fields, LLC 

[PROPOSED] STIPULATED FINAL JUDGMENT 

AND PERMANENT INJUNCTION 

-4- CASE No. 16-cv-07242-JSC 

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Case 3:16-cv-07242-JSC Document 45 Filed 10/03/17 Page 4 of 5
Darlin Defendant, Pro Se 

Top Brands International, Inc., Defendant 

By Shaikh . , if Ali, President 

t

L1 — 

Shazad , 1117) ant, Pro Se 

SEEN AND AGREED: 

Shaikh Kashif Ali, Defendant, Pro Se 

ight C. Donovan (SBN 114785) 

ddonovan@foxrothschild.com 

Jack Praetzellis (SBN 267765) 

jpraetzellis@foxrothschild.com 

FOX ROTHSCHILD LLP 

345 California Street, Suite 2200 

San Francisco, California 94104 

Telephone: (415) 364-5540 

Facsimile: (415) 391-4436 

Attorneys for Plaintiff Rodan & Fields, LLC 

[PROPOSED] STIPULATED FINAL JUDGMENT 

AND PERMANENT INJUNCTION 

-4- CASE No. 16-cv-07242-JSC 

Case 3:16-cv-07242-JSC Document 45 Filed 10/03/17 Page 5 of 5