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UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

COBBLER NEVADA, LLC,

Plaintiff,

v.

THOMAS GONZALES,

Defendant.

 Case No.: 3:15-cv-00866-ST 

STIPULATED CONSENT JUDGMENT

STIPULATED CONSENT JUDGMENT

As attested to by the signatures below, this matter comes before the Court on the parties’ 

joint stipulation.

Plaintiff Cobbler Nevada, LLC has filed a Complaint against the defendant in the Oregon 

district court for copyright infringement, 17 U.S.C. §§101, et seq, for the unlicensed copying, 

promotion and distribution of plaintiff’s motion picture titled The Cobbler, registered with the 

United States Copyright Office, Reg. No. PAu 3-744-688, 2014.

After initial discovery and investigation, defendant, initially identified as DOE24.21.136.125 has been affirmatively identified as Thomas Gonzales or Portland, Oregon, and as 

the proper defendant in this matter.

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The parties, after conferral and investigation, now appear 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.

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 parties and venue is proper.

2. Plaintiff Cobbler Nevada, LLC has valid and enforceable copyrights in the original 

copyrighted work, The Cobbler, (“motion picture”) registered with the United States 

Copyright Office, Reg. No. PAu 3-774-688, 2014.

3. Thomas Gonzales, formerly identified as DOE-24.21.136.125, is the proper named 

defendant in this case liable under plaintiff’s claims.

4. Plaintiff and Thomas Gonzales 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. Thomas Gonzales has been advised to obtain independent counsel and has been given 

opportunity to obtain independent counsel.

6. Thomas Gonzales has fully reviewed the Complaint and the allegations of the Complaint 

and specifically admit plaintiff’s investigations identifying the IP address used by the 

defendant, were accurate, in particular in accurately identifying the 67.189.7.71 IP 

address as the IP address used by defendant to download and distribute plaintiff’s motion 

picture identified with the Complaint.

7. With this matter, on compliance with the terms of the below Permanent Injunction, 

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plaintiff waives all claims to costs, fees and damages.

8. To settle this matter the parties further agree and require pursuant to the settlement the 

below Permanent Injunction be entered against Thomas Gonzales.

PERMANENT INJUNCTION

Thomas Gonzales is hereby PERMANENTLY ENJOINED from directly, contributorily 

or indirectly infringing plaintiff’s rights in their motion pictures, including without limitation by 

using the internet to reproduce or copy any plaintiff owned or branded motion pictures, to 

distribute any plaintiff owned or branded motion pictures, or to make plaintiff owned or branded 

motion pictures available for distribution to the public, except pursuant to a lawful written 

license from plaintiff; 

Thomas Gonzales 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) he owns or controls together with all other software used to obtain media through 

the Internet by peer-to-peer transfer or exchange; and

///

///

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Thomas Gonzales is hereby PERMANENTLY ENJOINED from directly, contributorily 

or indirectly participating or facilitating in peer-to-peer BitTorrent file exchanges without an 

express written license from all rights holders as to specific content exchanged.

SO ORDERED, this day: .

United States Judge

So Stipulated and Respectfully Submitted:

Defendant:

 

Thomas Gonzales 

12567 SE Bush St. 

Portland, OR 97236

On Behalf of Plaintiff:

/s/ Carl D. Crowell

Carl D. Crowell, OSB # 982049

email: carl@crowell-law.com

Drew P. Taylor, OSB # 135974

email: drew@crowell-law.com

Crowell Law

P.O. Box 923

Salem, OR 97308-0923

Phone: 503-581-1240

Of counsel for plaintiff

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