[Proposed] Order — United States ex rel. Blockquote, Inc. v. VIX Technology (USA) Inc. (Dkt. 12-1, W.D. Wash.)

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A proposed order filed on July 1, 2025 as Document 12-1 in United States ex rel. Blockquote, Inc. v. VIX Technology (USA) Inc., Case No. 2:24-cv-904-JCC in the Western District of Washington, would act on the stipulation of dismissal filed by the United States and the relator, Blockquote, Inc., under 31 U.S.C. § 3730(b)(1). It recites that the parties agreed to settle certain claims. All claims in the complaint would be dismissed with prejudice to the relator, and with prejudice to the United States only as to the 'Covered Conduct' defined in the Settlement Agreement concluded on March 17, 2025, otherwise without prejudice to the United States. The court would keep jurisdiction to enforce the settlement. Assistant United States Attorney Nickolas Bohl and Malaika M. Eaton of McNaul Ebel Nawrot & Helgren PLLC presented it for Judge John C. Coughenour; the date line is left blank.

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Case 2:24-cv-00904-JCC           Document 12-1       Filed 07/01/25      Page 1 of 2




 1                                                                    The Honorable John C. Coughenour

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                                UNITED STATES DISTRICT COURT FOR THE
 6                                WESTERN DISTRICT OF WASHINGTON
                                            AT SEATTLE
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   UNITED STATES OF AMERICA, ex rel.                      CASE NO. 2:24-cv-904-JCC
 8 BLOCKQUOTE, INC.,
                                                          [PROPOSED] ORDER
 9                                 Plaintiff,

10                         v.

11 VIX TECHNOLOGY (USA) INC.,

12                                 Defendant.

13          The Court, having considered the Stipulation of Dismissal filed by the United States and the

14 Relator Blockquote, Inc., it is hereby ORDERED, pursuant to 31 U.S.C. ' 3730(b)(1), that:

15          1.     The Parties having agreed to a settlement of certain claims raised in this matter;

16          2.     All of the claims set forth in the Complaint shall be dismissed against Defendant with

17 prejudice to the Relator, and with prejudice to the United States to the extent of the “Covered

18 Conduct,” as that term is defined in the Settlement Agreement concluded among the United States,

19 the Relator, and Defendant on March 17, 2025, but otherwise without prejudice to the United States;

20 and

21          3.     The Court shall retain jurisdiction to enforce the terms of the Settlement Agreement.

22 //

23 //


     [PROPOSED] ORDER - 1                                                    UNITED STATES ATTORNEY
     2:24-cv-904-JCC                                                        700 STEWART STREET, SUITE 5220
                                                                              SEATTLE, WASHINGTON 98101
                                                                                    (206) 553-7970

           Case 2:24-cv-00904-JCC       Document 12-1   Filed 07/01/25     Page 2 of 2




 1          DATED this __________ day of _____________________, 2025.

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                                                  JOHN C. COUGHENOUR
                                                  United States District Judge
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 7 Presented by:

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     s/ Nickolas Bohl
 9   NICKOLAS BOHL, WA #48978
     Assistant United States Attorney
10   United States Attorney’s Office
     700 Stewart Street, Suite 5220
11   Seattle, Washington 98101-1271
     Phone: 206-553-7970
12   Fax: 206-553-4067
     Email: nickolas.bohl@usdoj.gov
13

14 s/ Malaika M. Eaton
   MALAIKA M. EATON, WA #32837
15 McNaul Ebel Nawrot & Helgren PLLC
   600 University Street, Suite 2700
16 Seattle, Washington 98101
   Phone: 206-467-1816
17 Email: meaton@mcnaul.com

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      [PROPOSED] ORDER - 2                                           UNITED STATES ATTORNEY
      2:24-cv-904-JCC                                               700 STEWART STREET, SUITE 5220
                                                                      SEATTLE, WASHINGTON 98101
                                                                            (206) 553-7970

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