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Home Court filings Blueacorn Beringer Nced 187990 Proposed Order regarding 8 MOTION for Temporary Restraining Order and PRELIMINARY… — Bl…

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Proposed Order regarding 8 MOTION for Temporary Restraining Order and PRELIMINARY… — Blueacorn Beringer (Dkt. 13)

No. 5:21-cv-00251-BO · Doc. 13 · Docket on CourtListener

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                      IN THE UNITED STATES DISTRICT COURT
                  FOR THE EASTERN DISTRICT OF NORTH CAROLINA
                                 WESTERN DIVISION
                           Civil Action No. 5:21-cv-00251-BO

 BERINGER COMMERCE, INC. d/b/a
 BLUE ACORN iCi,

                   Plaintiff,

                                v.
                                                    PROPOSED ORDER GRANTING
                                                     MOTION FOR TEMPORARY
 FIN CAP, INC. d/b/a “BLUEACORN.CO,”
                                                     RESTRAINING ORDER AND
 BLUE ACORN PPP, LLC, BLUE OAK
                                                  PRELIMINARY INJUNCTIVE RELIEF
 FOREST, LLC, MICHAEL S. COTA,
 JIMMY FLORES, STEPHANIE
 HOCKRIDGE REIS, and NATHAN REIS,

                     Defendants.


       Upon consideration of Plaintiff’s Motion for Temporary Restraining Order and Preliminary

Injunctive Relief, the Court GRANTS the motion and FINDS that Plaintiff has sufficiently

demonstrated irreparable injury in the form of actual consumer confusion, the likelihood of

continued consumer confusion, Plaintiff’s inability to conduct its own business affairs due to the

volume of Defendants’ customer complaints directed to Plaintiff, and serious reputational harm,

warranting entry of a Temporary Restraining Order.

       This Court has considered the necessity of security pursuant to Rule 65 and finds that

security in the amount of ________ shall be given by Plaintiff.

       For the foregoing reasons, Plaintiff’s Motion for Temporary Restraining Order is

GRANTED, and the Court ORDERS as follows: Defendants BLUEACORN.CO, FIN CAP, INC.,

BLUE OAK FOREST, LLC, MICHAEL S. COTA, JIMMY FLORES, STEPHANIE

HOCKRIDGE REIS and NATHAN REIS are directed to take the following actions:




        Case 5:21-cv-00251-BO         Document 13        Filed 06/11/21     Page 1 of 3
       1.      Cease, desist, and permanently refrain from all use of the words “acorn,” “blue

acorn,” or “blueacorn” or any of their formatives in any manner and on any print or electronic

platform of any kind, including but not limited to any website, social media platforms, or any

online or print advertising or marketing materials;

       2.      Cease, desist, and permanently refrain from all use of any acorn images, including

a copy of the Acorn Logo, in any manner, including but not limited to any electronic platform, any

advertising, and on any public forum;

       3.      Place a prominent disclaimer on the landing or home page for all websites

associated with Defendants’ business, explaining that the website and services at issue are not

affiliated with, sponsored by, or otherwise connected to Blue Acorn iCi;

       4.      Set up an actively monitored email address and dedicated customer service line for

customer inquiries and maintain sufficient trained personnel to monitor and respond to such

inquiries on a timely basis;

       5.      Provide detailed information that is prominently displayed on all websites

associated with Defendants’ business, explaining how, where, and when to contact Defendants by

phone and by email;

       6.      Deactivate the “blueacorn.co” and “getblueacorn.com” websites and any other

website associated with Defendants’ business in which any form of the name “blue acorn” is used

in the domain name;

       7.      Reroute all traffic from the websites noted in the previous paragraph to a non-

fringing website that is actively monitored by Defendants;




                                                 2

        Case 5:21-cv-00251-BO           Document 13      Filed 06/11/21     Page 2 of 3
       8.      Change Defendants’ company name(s) with the Wyoming and Arizona Secretaries

of State and any other state in which an infringing name is used; and inform Defendants’ customers

of the new name; and

       9.      Destroy all materials, including advertising and promotional materials, bearing the

infringing “blue acorn” name, logo, images, acorn image, and marks.



       This Temporary Restraining Order shall be effective until ___________.



       SO ORDERED, this the ___ day of June, 2021.



                                                            United States District Judge




                                                3

        Case 5:21-cv-00251-BO         Document 13        Filed 06/11/21     Page 3 of 3


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