8:19-cv-00353-SMB Doc # 18 Filed: 10/15/19 Page 1 of 3 - Page ID # 37

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA

YOUTUBE,L.L.C.,

CASE NO. 8:19-cv-353

a Delaware corporation,
Plaintiff,

STIPULATION FOR ENTRY OF
JUDGMENT AND PERMANENT
INJUNCTION

vs.

CHRISTOPHER L. BRADY,an individual.
Defendant.

IT IS HEREBY STIPULATED by and between Plaintiff YouTube L.L.C. and Defendant

Christopher L. Brady, that a Judgment shall be entered to fully and finally dispose of this civil
action in favor of YouTube L.L.C. and against Defendant Christopher L. Brady.

IT IS FURTHER STIPULATED that this Judgment shall permanently enjoin Defendant
Christopher L. Brady and other persons who are in active concert or participation with him,from
directly or indirectly:

a.

Submitting any notices of alleged copyright infnngement to YouTube that

misrepresent that material hosted on the YouTube service is infringing copyrights held or claimed
to be held by Brady or anyone Brady claims to represent; and

b.

Misrepresenting or masking their identities in future interactions on or with services

offered by Google LLC or its affiliates, including but not limited to YouTube services.
The Parties therefore respectfully request that the Court enter the Proposed Judgment and
Permanent Injunction, attached hereto.

 8:19-cv-00353-SMB Doc # 18 Filed: 10/15/19 Page 2 of 3 - Page ID # 38

DATED October 14, 2019

YOUTUBE,L.L.C., Plaintiff
s/ David H. Kramer

David H. Kramer(pro hac vice)
WILSON SONSINI GOODRICH & ROSATI

Professional Corporation
650 Page Mill Road
Palo Alto, California 94304

Telephone:(650)493-9300
Facsimile:(650)565-5100
Email: dkramer@wsgr.com
and

Sam King(#19422)
Erin R. Robak(#23407)
MCGILL, GOTSDINER, WORKMAN «&
LEPP,P.O., L.L.O.
11404 West Dodge Road, Suite 500
Omaha,Nebraska 68154
Telephone:(402)492-9200
Email: SamKing@mgwl.com
ErinRobak@mgwl.com

Attorneysfor Plaintiff
YOUTUBE,L.L.C.

DATED: October 14,2019

CHRISTOPHER L. BRADY,Defendant,
s/ Daniel E. Klaus

Daniel E. Klaus(#17889)
Sheila A. Bentzen(#25020)
REMBOLT LUDTKE LLP

3 Landmark Centre

1128 Lincoln Mall, Suite 300
Lincoln, NE 68508

Telephone:(402)475-5100

Email: sbentzen@remboltlawfirm.com
dklaus@remboltlawfirm.com
Attorneysfor Defendant
CHRISTOPHER L. BRADY

 8:19-cv-00353-SMB Doc # 18 Filed: 10/15/19 Page 3 of 3 - Page ID # 39

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA

YOUTUBE,L.L.C.,

CASE NO.8:19-cv-353

a Delaware corporation,

[PROPOSED]
Plaintiff,

JUDGMENT AND
PERMANENT INJUNCTION

vs.

CHRISTOPHER L. BRADY,an individual.
Defendant.

This matter is before the Court on the parties' Stipulation to Entry of Judgment and
Permanent Injunction (Filing No.

). The Court has reviewed this Stipulation and concludes

that it should be approved, and that judgment and a permanent injunction should be entered in
favor of Plaintiff YouTube L.L.C. and against Defendant Christopher L. Brady. Accordingly,
IT IS HEREBY ORDERED,ADJUDGED,AND DECREED THAT:

Defendant Christopher L. Brady and other persons who are in active concert or
participation with him, are permanently enjoined from directly or indirectly:

a.

Submitting any notices of alleged copyright infnngement to YouTube that

misrepresent that material hosted on the YouTube service is infiinging copyrights held or claimed
to be held by Brady or anyone Brady claims to represent; and

b.

Misrepresenting or masking their identities in future interactions on or with

services offered by Google LLC or its affiliates, including but not limited to YouTube services.
Dated:
Hon.

United States District Court Judge