Matthew A. Levin, OSB #003054 

MattLevin@MHGM.com 

Chad M. Colton, OSB #065774 

ChadColton@MHGM.com 

MARKOWITZ, HERBOLD, GLADE 

& MEHLHAF, P.C. 

1211 SW Fifth Avenue, Suite 3000 

Portland, OR 97204-3730 

Tel: (503) 295-3085 

Fax: (503) 323-9105 

Attorneys for Plaintiffs 

Susan Bristow-Ford, OSB #970362 

susan@bristow-fordlaw.com 

BRISTOW-FORD LAW 

522 SW 5th Avenue, Suite 1390 

Portland, OR 97204 

Tel: (503) 208-3554 

Attorney for Defendants 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION 

ABS-CBN CORPORATION, a Philippine 

corporation; ABS-CBN FILM 

PRODUCTIONS, INC. d/b/a Star Cinema, a 

Philippine corporation; and ABS-CBN 

INTERNATIONAL, a California 

corporation, 

Plaintiffs, 

vs. 

JEFFREY.ASHBY, an individual; LENIE 

ASHBY, an individual; jointly d/b/a 

WEBPINOYTAMBAYAN.COM; 

W ATCHFILIPINOTV.COM; 

W ATCHFILIPINOMOVIES.COM; 

PINOY-TVKO.COM; PINOYTVKO.BIZ; 

PINOY-TUBE.COM; 

Case No.: 3-14-CV-1275 BR 

STIPULATION FOR ENTRY OF 

CONSENT FINAL JUDGMENT AND 

PERMANENT INJUNCTION 

Case 3:14-cv-01275-BR Document 42 Filed 10/10/14 Page 1 of 7
MYPINOYTUBETV.COM; 

PINOYTALAGA.COM; 

PINOYSTREAMING.COM; 

PINOYMOVIEFAN.COM; 

PINOYTVEPISODES.NET; 

PINOYTVEPISODES.INFO; and DOES 1-

100, 

Defendants. 

Plaintiffs, ABS-CBN Corporation, ABS-CBN Film Productions, Inc. d/b/a Star Cinema, 

and ABS-CBN International, and Defendant Jeffrey Ashby d/b/a WatchFilipinoTV.com; 

WatchFilipinoMovies.com; PinoyTalaga.com; PinoyStreaming.com; and PinoyMovieFan.com 

(hereinafter, "Mr. Ashby"), by and through the undersigned counsel, hereby stipulates 

to entry of the proposed Stipulated Consent Final Judgment and Permanent 

Injunction in the form attached hereto as Exhibit "A." 

Dated this 9th day of October , 2014. ---- -----------------------

ABSC\408645 

Respectfully submitted, 

MARKOWITZ, HERBOLD, GLADE 

& MEHLHAF, P.C. 

B . Isl Matthew A. Levin 

Y·-------------~--------~--- Matthew A. Levin, OSB #003054 

(503) 295-3085 

Attorneys for Plaintiffs 

BRISTOW-FORD LAW 

B . Isl Susan B1istow-Ford 

Y·-----------------------~--- Susan Bristow-Ford, OSB 970362 

(503) 208-3554 

Attorney for Defendants 

Case 3:14-cv-01275-BR Document 42 Filed 10/10/14 Page 2 of 7
Matthew A. Levin, OSB #003054 

MattLevin@MHGM.com 

Chad M. Colton, OSB #065774 

ChadColton@MHGM.com 

MARKOWITZ, HERBOLD, GLADE 

& MEHLHAF, P.C. 

1211 SW Fifth Avenue, Suite 3000 

Portland, OR 97204-3730 

Tel: (503) 295-3085 

Fax: (503) 323-9105 

Attorneys for Plaintiffs 

Susan Bristow-Ford, OSB 970362 

susan@bristow-fordlaw.com 

BRISTOW-FORD LAW 

522 SW 5th Avenue, Suite 1390 

Portland, OR 97204 

Tel: (503) 208-3554 

Attorney for Defendants 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION 

ABS-CBN CORPORATION, a Philippine 

corporation; ABS-CBN FILM 

PRODUCTIONS, INC. d/b/a Star Cinema, a 

Philippine corporation; and ABS-CBN 

INTERNATIONAL, a California 

corporation, 

Plaintiffs, 

vs. 

JEFFREY ASHBY, an individual; LENIE 

ASHBY, an individual; jointly d/b/a 

WEBPINOYTAMBAYAN.COM; 

W ATCHFILIPINOTV.COM; 

Case No.: 3-14-CV-1275 BR 

CONSENT FINAL JUDGMENT AND 

PERMANENT INJUNCTION 

Case 3:14-cv-01275-BR Document 42 Filed 10/10/14 Page 3 of 7
WATCHFILIPINOMOVIES.COM; 

PINOY-TVKO.COM; PINOYTVKO.BIZ; 

PINOY-TUBE.COM; 

MYPINOYTUBETV.COM; 

PINOYTALAGA.COM; 

PINOYSTREAMING.COM; 

PINOYMOVIEFAN.COM; 

PINOYTVEPISODES.NET; 

PINOYTVEPISODES.INFO; and DOES 1-

100, 

Defendants. 

Plaintiffs, ABS-CBN Corporation, ABS-CBN Film Productions, Inc. d/b/a Star Cinema, 

and ABS-CBN International (hereinafter collectively, "Plaintiffs" or "ABS-CBN") and 

Defendant Jeffrey Ashby ("Mr. Ashby") d/b/a WatchFilipinoTV.com; 

WatchFilipinoMovies.com; PinoyTalaga.com; PinoyStreaming.com; and PinoyMovieFan.com 

(collectively, the "Subject Domain Names") stipulate and consent to the following: 

WHEREAS, ABS-CBN owns the registered trademarks: ABS-CBN and THE FILIPINO 

CHANNEL as well as all common law rights associated with the trademark ~ as identified in 

Paragraphs 14 and 19 of the Complaint, and is also the owner of shows and broadcasts identified 

on Exhibit "l" attached to the Complaint (collectively, the "ABS-CBN Intellectual Prope1ty"); 

WHEREAS, the patties have amicably resolved their dispute to each of their 

satisfaction; and 

WHEREAS, based upon ABS-CBN's good faith prior use of the ABS-CBN Intellectual 

Propetty, ABS-CBN has superior and exclusive rights in and to the ABS-CBN Intellectual 

Property in the United States and any confusingly similar names, marks or copyrights. 

IT IS STIPULATED, ORDERED, ADJUDGED AND DECREED that: 

1. Mr. Ashby and any of the Subject Domain Names' officers, agents, servants, 

Case 3:14-cv-01275-BR Document 42 Filed 10/10/14 Page 4 of 7
employees and attorneys, and all persons in active conceit and participation with them are hereby 

permanently restrained and enjoined from intentionally and/or knowingly: 

a. broadcasting, performing, and/or distributing any ABS-CBN content or 

copyrighted works; 

b. infringing, counterfeiting, or diluting the ABS-CBN Intellectual Prope1ty, or 

using any similar marks; 

c. falsely representing or implying that Mr. Ashby and/or the Subject Domain 

Names are connected with Plaintiffs; 

d. engaging in search engine optimization strategies using ABS-CBN name or 

trademarks (or colorable variations); 

e. unfairly competing with Plaintiffs; 

f. using the ABS-CBN Intellectual Prope1ty or any confusingly similar trademarks 

and copyrighted works or other broadcast content on or in connection with all 

Internet websites, and/or domain names owned, operated, or controlled by them; 

g. using the ABS-CBN Intellectual Property, or any confusingly similar trademarks 

within domain name extensions, metatags or other markers within website source 

code, from use on any webpage (including as the title of any web page), from any 

advertising links to other websites, from search engines' databases or cache 

memory, and any other form of use of such terms; and 

h. effecting assignments or transfers, forming new entities or associations or 

utilizing any other device for the purpose of circumventing or othe1wise avoiding 

the prohibitions set fo1th in subparagraphs (a) through (g). 

2 

Case 3:14-cv-01275-BR Document 42 Filed 10/10/14 Page 5 of 7
2. Mr. Ashby, on behalf of himself and the Subject Domain Names, stipulates to the 

immediate transfer to Plaintiff of all ownership, right, title and interest in and to all of the Subject 

Domain Names and associated websites. Mr. Ashby will assist Plaintiffs as necessary to 

complete the immediate transfer of the Subject Domain Names and associated websites. 

3. Should Mr. Ashby fail to·voluntarily transfer the appropriate Subject Domain 

Names as required by Paragraph 2 herein within ten (10) days of entry of this Order, the Subject 

Domain Names are hereby ordered to be immediately transferred by the Registrar to Plaintiffs' 

control. To the extent the then current Registrar does not transfer the Subject Domain Names to 

Plaintiffs' control within seven (7) days of receipt ofa copy of this Judgment, the Registry shall, 

within thirty (30) days of receipt of a copy of this Judgment, transfer the Subject Domain Names 

to a Registrar of Plaintiffs' choosing, and that Registrar shall transfer the Subject Domain Names 

to Plaintiffs. 

4. The JP Morgan Chase bank accounts ending in '7021, '1378, '6972, and 

'5006, as well as all funds currently restrained in connection with this matter are hereby 

released back to the custody and control of Mr. Ashby. 

5. ABS-CBN is awarded damages in the amount of$ I 0,000,000.00 against Mr. 

Ashby. 

6. Due to the circumstances giving rise to the filing of this action, the settlement 

amount due from Mr. Ashby to ABS-CBN under the parties' settlement agreement and the 

damage award detailed in Paragraph 5 above are deemed non-dischargeable debts under Section 

523(a)(6) of the United States Bankruptcy Code, Title 11 U.S.C. § 101, et seq. 

7. The causes of action between Plaintiffs and Jeffrey and Lenie Ashby and the 

domains (and only those domains) to which Jeffrey Ashby has admitted ownership (i.e. the 

3 

Case 3:14-cv-01275-BR Document 42 Filed 10/10/14 Page 6 of 7
Subject Domain Names) are hereby dismissed, subject to the terms of the Settlement Agreement 

between the parties. This Consent Final Judgment shall be conclusive for purposes of collateral 

estoppel regarding all issues that have been or could have been brought on the same operative 

facts against Jeffrey or Lenie Ashby. The Settlement Agreement and this Consent Final 

Judgment apply only to Defendants, d/b/a the Subject Domain Names, and do not apply to any 

owner or operator of any website that is not one of the Subject Domain Names. To the extent 

that this Consent Final Judgment operates as a dismissal of claims against 

WEBPINOYTAMBA YAN.COM; PINOY-TVKO.COM; PJNOYTVKO.BIZ; PINOYTUBE.COM; MYPINOYTUBETV.COM; PINOYTVEPISODES.NET; 

PINOYTVEPISODES.INFO or DOES 1-100, said dismissal is without prejudice. 

8. No pa1iy shall be awarded attorney's fees and/or costs in connection with this 

Consent Final Judgment. 

9. This Couti will retain continuing jurisdiction over this cause to enforce the terms 

of this Consent Final Judgment and the Settlement Agreement between the parties. 

IT IS SO ORDERED. 

Dated this \ o%ay of ~) ckvlx,./ '2014. 

ABSC\408644 

4 

Case 3:14-cv-01275-BR Document 42 Filed 10/10/14 Page 7 of 7