CONSENT JUDGMENT – STIPULATED Page 1 of 4

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 plaintiffs

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

VOLTAGE PICTURES, LLC, a California 

Limited Liability Company, and

DALLAS BUYERS CLUB, LLC, a Texas 

Limited Liability Company,

Plaintiffs,

v.

DOE-74.92.164.133,

Defendant.

 Case No.: 3:14-cv-01782-AC

STIPULATED CONSENT JUDGMENT

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:

Plaintiffs Voltage Pictures, LLC and Dallas Buyers Club, LLC have filed a Complaint 

against the defendant in the Oregon District Court for copyright infringement, 17 U.S.C. §§101, 

et seq, and for enforcement of trademark rights for the unlicensed copying, promotion and 

distribution 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-74.92.164.133, 

was identified as the proper defendant in this matter.

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CONSENT JUDGMENT – STIPULATED Page 2 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-74.92.164.133 has been personally identified to 

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

Plaintiffs do 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 Dallas Buyers Club, LLC has valid and enforceable copyrights in the 

original copyrighted work, Dallas Buyers Club (the “motion picture”) 

registered with the United States Copyright Office, Reg. No. PA 1-873-195.

3. Plaintiff Voltage has valid and enforceable trademark rights in the branding 

associated with the motion picture and related promotional materials.

4. DOE-74.92.164.133 is the proper defendant in this case and liable under 

plaintiffs’ claims.

5. Plaintiffs and DOE-74.92.164.133 expressly consent to have a United States 

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

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CONSENT JUDGMENT – STIPULATED Page 3 of 4

of orders, including this stipulation or any other final judgment or orders 

arising therefrom.

6. DOE-74.92.164.133 and Doe’s counsel have fully reviewed the Complaint 

and the allegations of the Complaint and specifically admit plaintiffs’ 

investigations identifying the IP address used by DOE-74.92.164.133 were 

accurate, in particular in accurately identifying DOE-74.92.164.133’s IP 

address as per the allegations of the Complaint.

7. 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-74.92.164.133.

PERMANENT INJUNCTION

DOE-74.92.164.133 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 owned or branded 

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

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

pursuant to a lawful written license from Voltage; 

DOE-74.92.164.133 is hereby directed to immediately delete all unlicensed content in 

which Voltage has any rights or interest; and

///

///

Case 3:14-cv-01782-AC Document 15 Filed 03/07/15 Page 3 of 4
CONSENT JUDGMENT – STIPULATED Page 4 of 4

DOE-74.92.164.133 is hereby PERMANENTLY ENJOINED from directly, 

contributorily or indirectly participating or facilitating in peer-to-peer or BitTorrent file 

exchanges of any content in which Voltage has any rights without an express written license.

SO ORDERED, this day: .

United States Magistrate Judge

So Stipulated and Respectfully Submitted:

On Behalf of Defendant:

/s/ Leigh Gill

Leigh Gill, OSB #121737

email:leigh.gill@immixlaw.com 

Immix Law Group PC

121 SW Salmon St. Suite 1000

Portland, OR 97204

Phone: (503) 802.5542

Of counsel for defendant

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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