CONSENT JUDGMENT – STIPULATED Page 1 of 4

Carl D. Crowell, OSB No. 982049

email: carl@crowell-law.com

Drew P. Taylor, OSB No. 135974

email: drew@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

COBBLER NEVADA, LLC,

Plaintiff,

v.

ANONYMOUS USERS OF POPCORN 

TIME: DOES 1 - 11,

Defendants.

 Case No.: 3:15-cv-01550-ST 

STIPULATED CONSENT JUDGMENT

Doe #05: IP: 71.59.218.131

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 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. Voltage Pictures, LLC, an 

aggrieved and injured party joins in this settlement for purposes of releasing liability and 

resolution of claims.

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CONSENT JUDGMENT – STIPULATED Page 2 of 4

After initial discovery and investigation, defendant, identified as Doe No. 05, assigned IP 

address 71.59.218.131 (“Doe #05”) was affirmatively identified as the proper defendant in this 

matter.

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 #05 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 parties and venue is proper.

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

copyrighted work, Cobbler Nevada, LLC, (“motion picture”) registered with the United 

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

3. Doe #05 is the proper named defendant in this case liable under plaintiff’s claims.

4. Plaintiff and Doe #05 expressly consent to have a United States Magistrate Judge conduct 

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CONSENT JUDGMENT – STIPULATED Page 3 of 4

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 #05 and Doe’s counsel have fully reviewed the Complaint and the allegations of the 

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

by Doe #05 were accurate, in particular in accurately identifying Doe #05’s IP address 

as the IP address used to download and distribute plaintiff’s motion picture and other 

content identified with the Complaint..

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

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

#05 .

PERMANENT INJUNCTION

Doe #05 is hereby PERMANENTLY ENJOINED from directly, contributorily or 

indirectly infringing plaintiffs’ rights in their motion pictures, including without limitation by 

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

to distribute any Voltage Pictures owned or branded motion pictures, or to make Voltage 

Pictures owned or branded motion pictures available for distribution to the public, except 

pursuant to a lawful written license from Voltage Pictures; and

///

///

Case 3:15-cv-01550-SB Document 28 Filed 10/27/15 Page 3 of 4
CONSENT JUDGMENT – STIPULATED Page 4 of 4

Doe #05 is hereby directed to immediately delete all unlicensed content in which Voltage 

Pictures, LLC has any rights or interest, together with any and all BitTorrent clients on any 

computer(s) he or she owns or controls together with all other software used to obtain media 

through the Internet by BitTorrent peer-to-peer transfer or exchange.

SO ORDERED, this day: .

United States Magistrate Judge

So Stipulated and Respectfully Submitted:

On Behalf of Defendant Doe #05:

By: s/ Benjamin R. Justus_______ 

Benjamin R. Justus (WSBA # 38855)

Lybeck Pedreira & Justus, PLLC 

Fifth Floor – Chase Bank Building

7900 SE 28th Street

Mercer Island, WA 98040

(206) 230-4255 /phone

(206) 230-7791 /fax

On Behalf of Plaintiff:

/s/ 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 plaintiffs

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