ROLEX WATCH U.S.A., INC. v. CHAN
United States District Court, C.D. California, Western Division.
July 24, 2012.
f. engaging in any conduct constituting an infringement of the Rolex Registered Trademarks, or any words confusingly similar, of Rolex's rights in or to use or to exploit said trademarks, or constituting any weakening of Rolex's name, reputation and good will;
g. using or continuing to use the Rolex Registered Trademarks or trade name in any variation thereof on the Internet (either in the text of a website, as a domain name, or as a keyword, search word, metatag, or any part of the description of the site in any submission for registration of any Internet site with a search engine or index) in connection with any goods or services not directly authorized by Rolex;
h. acquiring, maintaining, registering or applying to register as a trademark, trade name, service mark, domain name or any other source identifier the Rolex Registered Trademarks or any other trademarks owned by Plaintiff, or any other mark or name that infringes or is likely to be confused with Plaintiff's trademarks or trade names, or transferring conveying or assigning any such domain names to any entity other than Rolex;
i. otherwise unfairly competing with Rolex; and
j. effecting assignments or transfers, forming new entities or associations or utilizing any other device for the purpose of circumventing or otherwise avoiding the prohibitions set forth in subparagraphs (a) through (i).
24. Judgment shall be entered jointly and severally against each person or entity herein referred to collectively as "Defendants" in the amount of $2,500.00 USD for Rolex's damages as a result of Defendants' conduct.
25. In the event Defendant(s) breach any term of this Consent Judgment and Permanent Injunction, or otherwise infringe or dilute Rolex's trademark rights, Rolex shall be entitled to injunctive relief, damages and profits and Defendant(s) shall pay Rolex attorneys' fees and costs incurred as a result of such infringement, dilution, and/or breach.