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UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

RAMADA WORLDWIDE INC.

Plaintiff, Civil Action No. 1 :06-cv-00205-JD

v.

LBM FINANCIAL LLC,

MARCELLO MALLEGNI,

HTL CORP. and

SYLVESTER P. RUGGIERO, JR

Defendants. June 27, 2006

STIPULATED INJUNCTION

This matter having been opened to the Court by way of a Verified Complaint filed by

PlaintiffRamada Worldwide Inc . ("RWP) for the entry of a preliminary injunction against

Defendants LBM Financial LLC ("LBM") and Marcello Mallegni ("Mallegni") to enjoin

Defendants LBM and Mallegni from any further use of the RWI trade names or service marks

("Ramada Marks"), or the use of names and marks confusingly similar to the Ramada Marks,

and it appearing that the parties hereto have consented to the terms and conditions of the within

Order and good cause having been shown without prejudice to the right of Defendants LBM and

Mallegni to assert that they are not proper defendants with re spect to the monetary claims set

forth in the Verified Complaint: :

iT IS HEREBY ORDERED, ADJUDGED AND DECREED that :

1 . Defendants LBM and Mallegni and their officers, agents, members, affiliates,

subsidiaries, independent contractors, servants, employees and attorneys, and all persons i n

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active concert or participation with them who receive actual notice hereof by personal service or

otherwise, are hereby permanently enjoined and restrained from continuing to operate, market,

promote or rent guest rooms at the hotel located at 21 Front Street, Manchester, New Hampshire

(the "Hotel") such that the origin of the Hotel's goods or services are falsely designated as being

those of RWI, or designated in a manner that is confusingly similar to those of RWI, or from

otherwise using the names "Ramada" or "Ramada Inn" or any other form, version or variation of

Plaintiffs trademarks, service marks, trade names, proprietary trade dress or other intellectual

property.

2. The injunction described above encompasses, but is not limited to, the use of any

and all print or telecommunications advertisements, drafts, labels, signs, flyers, stationery,

envelopes, applications, booklets, brochures, catalogues, circulars, pamphlets, periodicals, bulletins,

instructions, minutes, other communications, purchase orders, contracts, agreements, options to

purchase, deeds, memoranda of agreements, assignments, licenses, books of account, orders,

accounts, working papers, plans, inte rnet sites, domain names and/or e-mail and e -mail addresses

that display, in any manner, the Ramada trade names and service marks, any derivation of the

Ramada trade names and service marks, or names and m arks confusingly similar to the Ramada

trade names and service marks, and it is fiuther

3. If they have not done so already, Defendants Mallegni and LBM shall

immediately cover any signs on or at the Hotel that contain the names ` Ramada" or "Ramada

lnn" or any other form, version or variation of Plaintiffs trademarks, service marks, trade names,

proprietary trade dress or other intellectual proper ty so that they are no longer visible to guests or

passers-by.

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4. Within fourteen days hereof, Defendants Mallegni and I. .BM shall cause any signs

on or at the Hotel that contain the names "Ramada" or "Ramada Inn" or any other form, version

or variation of Plaintiff s trademarks, service marks, trade names, proprietary trade dress or other

intellectual property to be physica lly and permanently removed from the property, rather than

merely covered.

5. This Stipulated Injunction is binding upon Defendants Mallegni and LBM and

their officers, agents, members, affiliates, subsidiaries, independent contractors, servants,

employees and attorneys, and those persons in active concert or participation with them who

receive actual notice hereof by personal service or otherwise, and these parties waive all right to

appeal from this Stipulated Injunction, including but not limited to all right to have the Stipulated

Injunction reviewed, approved, modified or vacated by a United States District Judge .

By:

y

Wiggm ind D

One Century Tower

P.O. Box 1832

New Haven, CT 06508-1832

(203) 498-440 0

(203) 782-2889 fax

bappleby®wiggin.com

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DEFENDANTS,

MARCELLO MALLEGNI a

L13M FINAI IAL LLC,

By: .

I

171 Locke Drive

Suite 101

Marlborough, MA 01752

(508) 624-773 3

(508) 229-2600 fax

mnonis@mjnattorney .com

Ilk

It is SO ORDERED this _2_day ofAtif;„., 2006.

nited"States District @eurt JU

CZQOY

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