d
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for judgment and relief against the Defendants, jointly and
severally, as follows:
A. Compensatory damages in an amount to be determined at trial but presently believed to be
well in excess of $750 million;
B. Enhanced damages based on the willfulness of Defendants’ wrongful acts;
C. Disgorgement of all profits earned by Defendants through their wrongful acts;
D. Punitive damages in an amount to be determined at trial;
E. A declaration that Lynwood owns all copyright rights and/or other rights in and to the
NGINX Software, NGINX Plus, all of the other Copyrighted Works, and all related business
opportunities comprising the NGINX Enterprise;
F. A permanent injunction prohibiting Defendants from further infringement of the NGINX
Software, NGINX Plus and all of the other Copyrighted Works, and ordering Defendants to destroy
all copies of such works made in violation of Plaintiff’s exclusive rights;
G. Cancellation of the fraudulent trademarks registered by Defendants;
H. A permanent injunction prohibiting Defendants from use of the NGINX trademark, the
NGINX (Stylized) trademark, the NGINX PLUS trademark, the NGINX CONTROLLER trademark,
the NGINX UNIT trademark, the NGINX APP PROTECT trademark and any other trademark that
includes NGINX or any mark confusingly similar therewith;
I. A declaration that Lynwood owns the NGINX trademark, the NGINX (Stylized) trademark,
the NGINX PLUS trademark, the NGINX CONTROLLER trademark, the NGINX UNIT trademark,
the NGINX APP PROTECT trademark and any other trademark that includes NGINX;
J. Plaintiff’s Attorneys’ Fees and costs; and
K. A grant to Plaintiff of such other and further relief as the Court may deem just and proper
WHEREFORE, Plaintiff prays for judgment and relief against the Defendants, jointly and
severally, as follows:
A. Compensatory damages in an amount to be determined at trial but presently believed to be
well in excess of $750 million;
B. Enhanced damages based on the willfulness of Defendants’ wrongful acts;
C. Disgorgement of all profits earned by Defendants through their wrongful acts;
D. Punitive damages in an amount to be determined at trial;
E. A declaration that Lynwood owns all copyright rights and/or other rights in and to the
NGINX Software, NGINX Plus, all of the other Copyrighted Works, and all related business
opportunities comprising the NGINX Enterprise;
F. A permanent injunction prohibiting Defendants from further infringement of the NGINX
Software, NGINX Plus and all of the other Copyrighted Works, and ordering Defendants to destroy
all copies of such works made in violation of Plaintiff’s exclusive rights;
G. Cancellation of the fraudulent trademarks registered by Defendants;
H. A permanent injunction prohibiting Defendants from use of the NGINX trademark, the
NGINX (Stylized) trademark, the NGINX PLUS trademark, the NGINX CONTROLLER trademark,
the NGINX UNIT trademark, the NGINX APP PROTECT trademark and any other trademark that
includes NGINX or any mark confusingly similar therewith;
I. A declaration that Lynwood owns the NGINX trademark, the NGINX (Stylized) trademark,
the NGINX PLUS trademark, the NGINX CONTROLLER trademark, the NGINX UNIT trademark,
the NGINX APP PROTECT trademark and any other trademark that includes NGINX;
J. Plaintiff’s Attorneys’ Fees and costs; and
K. A grant to Plaintiff of such other and further relief as the Court may deem just and proper
