ROLEX WATCH U.S.A., INC. v. CHAN
United States District Court, C.D. California, Western Division.
July 24, 2012.
22. Rolex has suffered irreparable harm and damages as a result of Defendants' illegal acts. The injuries and damages sustained by Rolex have been directly and proximately caused by the Defendants' wrongful advertisement and promotion using the Rolex Registered Trademarks.
23. Defendants and their officers, agents, servants, employees and all persons in active concert and participation with Defendants are hereby permanently restrained and enjoined from:
a. imitating, copying or making unauthorized use of the Plaintiff's Rolex Registered Trademarks or any mark or combination of initials confusingly similar thereto in any manner;
b. engaging in any course of conduct likely to cause confusion, deception or mistake, or injure Rolex's business reputation or weaken the distinctive quality of the Rolex Registered Trademarks, Rolex's name, reputation or goodwill;
c. using false description or representation including words or other symbols tending to falsely describe or represent their services as being those of Rolex or sponsored by or associated with Rolex and from offering such services in commerce;
d. using any simulation, reproduction, counterfeit, copy or colorable imitation of the Rolex Registered Trademarks, or any words or initials confusingly similar, as a trademark, trade name, domain name or otherwise, in connection with the promotion, advertisement, display, sale, offering for sale, circulation or distribution of any services in such fashion or in any medium, as to relate or connect, or tend to relate or connect, such services in any way to Rolex, or to any goods or services sold, manufactured, sponsored or approved by, or connected with Rolex;
e. making any statement or representation whatsoever, or using any false designation of origin or false description, or performing any act, which can or is likely to lead the trade or public, or individual members thereof, to believe that any services provided, products manufactured, distributed, sold or offered for sale, licensed, or leased or rented by Defendants are in any way associated or connected with Rolex, or is provided, sold, manufactured, licensed, sponsored, approved or authorized by Rolex;