e.Digital Corporation (fka EDIG)

[Cassandra]

Most of the language about the injunction came from the original complaint with some changes and additions by the author of what appears the be a settlement agreement which formed the basis of the motion for a consent judgment.

From the Apple complaint which is most likely boiler plate for all of the cases:

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for relief and judgment as follows:

1. That Defendant be declared to have infringed the Patents-in-Suit;

2. That Defendant’s infringement of the Patents-in-Suit has been deliberate and willful;

3. Preliminarily and permanently enjoining the Defendant’s officers, agents, servants, employees, and attorneys, and those persons in active concert or participation with them, from infringement of the Patents-in-Suit, including but not limited to any making, using, offering for sale, selling, or importing of unlicensed infringing products within and without the United States;

4. Compensation for all damages caused by Defendant’s infringement of the Patents-in-Suit to be determined at trial;

5. Enhancing Plaintiff’s damages up to three (3) times their amount pursuant to 35 U.S.C. § 284;

6. Granting Plaintiff pre-and post-judgment interest on its damages, together with all costs and expenses; and,

7. Awarding such other relief as this Court may deem just and proper

.
From the apparent settlement agreement (the parts in bold are the changes):

Permanent Injunction shall issue against Grundig and Smoltz, enjoining each of them as well as their officers , agents , servants , employees , US distributors , attorneys and those in acting concert with them permanently from making , using or selling the accused products , and any derivation thereof which infringe any claim of the Asserted patents in the United States , until individually, each of the patent expires .The parties acknowledge that Grundig still manufacture and distribute analog voice recorder (Non – Accused Products).