Carl D. Crowell, OSB No. 982049 

email: carl@crowell-law.com 

CROWELL LAW 

P.O. Box 923 

Salem, OR 97308 

(503) 581-1240 

Of attorneys for plaintiff 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

Case No.: 6:15-cv-00177-AC 

DALLAS BUYERS CLUB, LLC, a Texas 

Limited Liability Company, 

STIPULATED CONSENT JUDGMENT 

Plaintiffs, 

v. 

DOE-71.193.181.123, 

Defendant. 

STIPULATED CONSENT JUDGMENT 

As attested to by the signatures of counsel for the parties below, this matter comes before 

the Court on the parties' joint stipulation. 

Plaintiff Dallas Buyers Club, LLC has filed a Complaint against the defendant in the 

Oregon district court for copyright infringement, 17 U.S.C. §§ 101, et seq., of plaintiffs motion 

picture titled Dallas Buyers Club, registered with the United States Copyright Office, Reg. No. 

PA 1-873-195. 

After initial discovery and investigation, defendant, identified as DOE-71.193.181.123 

was affirmatively identified as the proper defendant in this matter. 

CONSENT JUDGMENT - STIPULATED Page 1of4 

Case 6:15-cv-00177-AC Document 11 Filed 04/01/15 Page 1 of 4
The parties, after conferral and investigation, now appear through counsel to fully and 

finally resolve all claims between the parties and the matters before the Court and have moved 

for entry of this Stipulated Consent Judgment to effect the terms of their settlement. 

Identity of the Defendant 

The defendant identified herein as DOE-71.193.181.123 has been personally identified to 

plaintiff but wishes to remain anonymous and has requested leave to proceed anonymously. 

Plaintiff does not oppose this request. The parties are granted leave to separately file the true 

identity of the defendant under seal, which absent breach of the parties' settlement agreement, or 

action to enforce this Stipulated Consent Judgment may remain under seal. 

WHEREFORE IT IS HEREBY STIPULATED AND ORDERED for all matters relevant to this 

case between the parties as follows: 

1. This court has jurisdiction over the patties and venue is proper. 

2. Plaintiff Dallas Buyers Club, LLC has valid and enforceable copyrights in the original 

copyrighted work, Dallas Buyers Club, ("motion picture") registered with the United 

States Copyright Office, Reg. No. PA 1-873-195. 

3. DOE-71.193.181.123 is the proper named defendant in this case liable under plaintiffs 

claims. 

4. Plaintiff and DOE-71.193.181.123 expressly consent to have a United States Magistrate 

Judge conduct any and all proceedings in this case, including entry of orders, including 

this stipulation or any other final judgment or orders arising therefrom. 

5. DOE-71.193.181.123 and Doe's counsel have fully reviewed the Complaint and the 

CONSENT JUDGMENT - STIPULATED Page 2 of 4 

Case 6:15-cv-00177-AC Document 11 Filed 04/01/15 Page 2 of 4
allegations of the Complaint and specifically admit plaintiffs investigations identifying 

the IP address used by DOE-71.193.181.123 were accurate, inpatiicular in accurately 

identifying DOE-71.193.181.123 and DOE-71.193.181.123's IP address as the IP address 

used to download and distribute plaintiffs motion picture and other content identified 

with the Complaint. 

6. In addition to other terms in a separate settlement agreement, the patties further agree and 

require pursuant to the settlement the below Permanent Injunction be entered against 

DOE-71.193.181.123. 

PERMANENT INJUNCTION 

DOE-71.193.181.123 is hereby PERMANENTLY ENJOINED from directly, 

contributory or indirectly infringing plaintiffs rights in their motion pictures, including without 

limitation by using the Intemet to reproduce or copy plaintiffs motion picture or to make 

plaintiffs motion picture available for distribution to the public, except pursuant to a lawful 

written license from plaintiff; 

DOE-71.193.181.123 is hereby directed to immediately delete all unlicensed content in 

which plaintiff has any rights or interest, together with any and all BitTorrent clients on any 

computer(s) they own or control together with all other software used to obtain media through 

the Intemet by BitTorrent peer-to-peer transfer or exchange; and 

Ill 

Ill 

CONSENT JUDGMENT- STIPULATED Page 3 of4 

Case 6:15-cv-00177-AC Document 11 Filed 04/01/15 Page 3 of 4
DOE-71.193.181.123 is hereby PERMANENTLY ENJOINED from directly, 

contributorily or indirectly patticipating or facilitating in peer-to-peer BitTorrent file exchanges 

without an express license from all rights holders as to the specific content exchanged. 

SO ORDERED, this day: Q,7 f //'~I-? , 

So Stipulated and Respectfully Submitted: March 31, 2015 

On Behalf of Defendant: 

Isl Benjamin R. Justus 

Benjamin R. Justus, WSBA #38855 

Attorney for Defendant 

L1ibeck Pedreira & Justus PLLC 

5

1

' Floor Chase Bank Building 

7900 SE 281

h Street 

Mercer Island, WA 98040 

Phone: 206-230-4255 

Email: ben@lpjustus.com 

CONSENT JUDGMENT - STIPULATED 

On Behalf of Plaintiff: 

Isl Carl D. Crowell 

Carl D. Crowell, OSB # 982049 

email: carl@crowell-law.com 

Crowell Law 

P.O. Box 923 

Salem, OR 97308-0923 

Phone: 503-581-1240 

Of counsel for plaintiff 

Page 4 of 4 

Case 6:15-cv-00177-AC Document 11 Filed 04/01/15 Page 4 of 4