THIS CAUSE comes before the Court on Plaintiff’s Motion for Entry of Final Default Judgment (DE [30]) (the “Motion”). The Court granted the Motion in a separate Order. Pursuant to Federal Rule of Civil Procedure 58(a), the Court hereby ENTERS THIS SEPARATE FINAL JUDGMENT. Accordingly, it its ORDERED AND ADJUDGED that Final Default Judgment is hereby entered in favor of Plaintiff, THE KYJEN COMPANY, LLC (“Plaintiff”), and against Defendant, the Individual, Corporation, Limited Liability Company, Partnership, and/or Unincorporated Association Identified on Schedule A hereto (the “Defendant”) as follows: (1) Permanent Injunctive Relief: Defendant and its officers, directors, employees, agents, subsidiaries, distributors, and all persons acting in concert and participation with Defendant are hereby permanently restrained and enjoined from: a. manufacturing or causing to be manufactured, importing, advertising, Case 0:25-cv-60699-AHS Document 35 Entered on FLSD Docket 01/06/2026 Page 1 of 9 2 or promoting, distributing, selling or offering to sell counterfeit and infringing goods bearing Plaintiff’s trademarks, or any confusingly similar trademarks identified in Paragraph 2 of the Amended Complaint (the “Outward Hound Trademarks”), b. using the Outward Hound Trademarks identified in Paragraph 2 of the Amended Complaint in connection with the sale of any unauthorized goods; c. using any logo, and/or layout which may be calculated to falsely advertise the services or products of the Defendant as being sponsored by, authorized by, endorsed by, or in any way associated with Plaintiff; d. falsely representing themselves as being connected with Plaintiff, through sponsorship or association; e. engaging in any act which is likely to falsely cause members of the trade and/or of the purchasing public to believe any goods or services of the Defendant are in any way endorsed by, approved by, and/or associated with Plaintiff; f. using any reproduction, counterfeit, copy, or colorable imitation of the Outward Hound Trademarks in connection with the publicity, promotion, sale, or advertising of any goods sold by the Defendant; g. affixing, applying, annexing, or using in connection with the sale of any goods, a false description or representation, including words or other symbols tending to falsely describe or represent goods offered for sale or sold by the Defendant as being those of Plaintiff or in any way endorsed by Plaintiff; h. using the Outward Hound Trademarks or any confusingly similar trademarks or works on e-commerce marketplace sites, domain name extensions, metatags or other markers within website source code, from use on any webpage Case 0:25-cv-60699-AHS Document 35 Entered on FLSD Docket 01/06/2026 Page 2 of 9 3 (including as the title of any web page), from any advertising links to other websites, from search engines’ databases or cache memory, and from any other form of use of such terms which are visible to a computer user or serves to direct computer searches to ecommerce stores, websites, and/or Internet businesses registered, owned, or operated by the Defendant; and i. effecting assignments or transfers, forming new entities or associations, or utilizing any other device for the purpose of circumventing or otherwise avoiding the prohibitions set forth above. Defendant and its officers, directors, employees, agents, subsidiaries, distributors, and all persons acting in concert and participation with Defendant are hereby permanently restrained and enjoined from: a. manufacturing or causing to be manufactured, importing, advertising, or promoting, distributing, selling or offering to sell or unauthorized and unlicensed products which either utilize the technology of, or embody the designs of the patents identified in Paragraph 2 of the Amended Complaint (the “Outward Hound Patents”) (DE [6]); b. From making, using, selling, importing and/or offering to sell products that infringe the Outward Hound Patents (together, the Outward Hound Trademarks, and Outward Hound Patents “the Outward Hound IP”); c. From: i. passing off, inducing, or enabling others to sell or pass off any product as a genuine Outward Hound Product or any other product produced by Plaintiff, that is not Plaintiff’s or not Case 0:25-cv-60699-AHS Document 35 Entered on FLSD Docket 01/06/2026 Page 3 of 9 4 produced under the authorization, control, or supervision of Plaintiff and approved by Plaintiff for sale under Plaintiff’s Outward Hound IP; ii. committing any acts calculated to cause consumers to believe that Defendant’s products are those sold under the authorization, control or supervision of Plaintiff, or are sponsored by, approved by, or otherwise connected with Plaintiff; iii. further infringing Plaintiff’s Outward Hound Patents and damaging Plaintiff’s goodwill; iv. shipping, delivering, holding for sale, transferring or otherwise moving, storing, distributing, returning, or otherwise disposing of, in any manner, products or inventory not manufactured by or for Plaintiff, nor authorized by Plaintiff to be sold or offered for sale, and which embody or infringe Plaintiff’s Outward Hound IP or any reproductions or colorable imitations thereof; v. using, linking to, transferring, selling, exercising control over, or otherwise owning the Online Marketplace Accounts, the Internet Stores, or any other domain name or online marketplace account that is being used to sell or is the means by which Defendant could continue to sell counterfeit Outward Hound Products; vi. operating and/or hosting websites at the Internet Stores or Case 0:25-cv-60699-AHS Document 35 Entered on FLSD Docket 01/06/2026 Page 4 of 9 5 any other domain names registered or operated by Defendant that are involved with the distribution, marketing, advertising, offering for sale, or sale of any product infringing Plaintiff’s Outward Hound IP or any reproductions or colorable imitations thereof that is not a genuine Outward Hound Product or not authorized by Plaintiff to be sold in connection with Plaintiff’s Outward Hound Patents; and vii. effecting assignments or transfers, forming new entities or associations or utilizing any other device for the purpose of circumventing or otherwise avoiding the prohibitions set forth above. (2) Additional Equitable Relief: a. Upon Plaintiff’s request, the Internet marketplace website operators and/or administrators for the Internet based e-commerce stores operating under the seller identification names identified on Schedule A hereto (the “Seller ID”), including but not limited to Hong Kong Limited, which operates the AliExpress.com platform, Amazon, DHgate, eBay, Etsy, Temu, Walmart.com, and ContextLogic, Inc., which operates the Wish platform, shall permanently remove any and all listings and associated images of goods infringing the Outward Hound Trademarks and Outward Hound Patents via the ecommerce stores operating under the Seller ID, and any other listings and images of goods infringing the Outward Hound IP associated with the same sellers or linked to any other alias seller identification names or e-commerce stores being used and/or controlled by Defendant to promote, offer for sale and/or sell goods infringing the Outward Hound Case 0:25-cv-60699-AHS Document 35 Entered on FLSD Docket 01/06/2026 Page 5 of 9 6 IP; and b. Upon Plaintiff’s request, any Internet marketplace website operator and/or administrator who is in possession, custody, or control of Defendant’s goods infringing the Outward Hound IP, including but not limited to Hong Kong Limited, which operates the AliExpress.com platform, Amazon, DHgate, eBay, Etsy, Temu, Walmart.com, and ContextLogic, Inc., which operates the Wish platform, shall permanently cease fulfillment of and sequester those goods, and surrender the same to Plaintiff. (3) Statutory damages in favor of Plaintiff pursuant to 15 U.S.C. § 1117(c): a. Award Plaintiff damages of $200,000.00 against the Defendant, for which let execution issue, based upon the Court’s finding that the Defendant infringed at least one trademark on one type of good. The Court considered both the willfulness of the Defendant’s conduct and the deterrent value of the award imposed, and th