IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CBV, INC., Plaintiff v. CHANBOND, LLC, Defendant. C.A. No. 1:21-cv-01456-MN
AMENDED STIPULATION CONCERNING TEMPORARY RESTRAINING ORDER AND INTEREST
WHEREAS, Plaintiff CBV, Inc. (“CBV”) and Defendant ChanBond, LLC (“ChanBond”) are parties to this action (collectively, the “Parties”); and WHEREAS, non-parties Deirdre Leane and IPNAV, LLC (collectively, “Proposed Intervenors”) intend to intervene as Defendants in this action; and WHEREAS, CBV has filed a motion for a preliminary injunction restraining ChanBond from distributing the proceeds of ChanBond’s patent litigations referenced in CBV’s Amended Complaint (the “Complaint”) to the Proposed Intervenors (the “PI Motion”); and WHEREAS, CBV has sought a TRO in connection with that motion; and WHEREAS, the Parties and Proposed Intervenors have been able to reach an agreement that moots the need for a TRO or briefing relating to that application; NOW, THEREFORE, the Parties and Proposed Intervenors hereby stipulate and agree as follows: 1. ChanBond and its agents will voluntarily refrain from distributing the Settlement Funds to Proposed Intervenors until CBV’s Motion for Preliminary Injunction is heard and a decision rendered by the Court; 2. Proposed Intervenors shall not seek to recover post-judgment interest on the arbitration award in Leane et al. v. Unified Online, Inc. et al., Case No. 01-20-0015-0793 (AAA) for the period between execution of this stipulation and the preliminary injunction hearing if and only if: (1) ChanBond pays Proposed Intervenors any amounts due on the award (or such lesser sum as it is directed to pay over) within five (5) business days of a decision by the Court denying the relief requested in the PI Motion or by subsequent order of the Court lifting any restraint or otherwise directing the payment of any sums to Proposed Intervenors; and (2) the Court grants the preliminary injunction without requiring CBV to post a bond to cover the post-judgment interest generated by such relief. 3. In the event the Court grants the relief sought in the PI Motion and requires CBV to post a bond in connection therewith, such Court-ordered bond shall be retroactive to the date of this Stipulation. 4. CBV shall contemporaneously herewith withdraw its application for temporary restraining order, without prejudice and with reservation of all rights with respect thereto.
BUCHANAN INGERSOLL & ROONEY PC /s/ Geoffrey G. Grivner Geoffrey G. Grivner (No. 4711) Kody M. Sparks (No. 6464) 500 Delaware Avenue Suite 720 Wilmington, DE 19801 (302) 552-4200 geoffrey.grivner@bipc.com kody.sparks@bipc.com Attorneys Plaintiff CBV, Inc.
BAYARD, P.A. /s/ Stephen B. Brauerman Stephen B. Brauerman (No. 4952) Ronald P. Golden III (No. 6254) 600 North King Street Suite 400 Wilmington, DE 19801 (302) 655-5000 sbrauerman@bayardlaw.com rgolden@bayardlaw.com Attorneys for Defendant ChanBond, LLC
TROUTMAN PEPPER HAMILTON SANDERS LLP /s/ James H. S. Levine James H. S. Levine (No. 5355) Hercules Plaza, Suite 5100 1313 N. Market Street P.O. Box 1709 Wilmington, DE 19899-1709 302.777.6500 james.levine@troutman.com Attorneys for Deirdre Leane and IPNAV,LLC
IT IS SO ORDERED. Dated March 17, 2022.
The Honorable Maryellen Noreika United States District Judge
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