Free Motion for TRO - District Court of Delaware - Delaware

Case 1:07-cv-00087-JJF Document 3 Filed O2/16/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
TODAY MEDIA, INC. :
Plaintiff, 2
v. Civil Action No.:
CBR MEDIA LLC JURY OF 12 DEMANDED
Defendant. :
PLAINTIFF TODAY MEDIA, INC.’S
MOTION FOR TEMPORARY RESTRAINING ORDER
Plaintiff Today Media, Inc., by its undersigned counsel, hereby files this motion for a
Temporary Restraining Order to be issued against Defendant CBR Media to maintain the status
quo until such time as the merits ofthe Complaint can be determined. The grounds for this
motion are fully explained in the Verified Complaint and Memorandum of Law in Support of
said Motion.
WHEREFORE, Plaintiff respectfully requests that its motion be granted and that the
Court enter the proposed Temporary Restraining Order submitted herewith.
SAUL EWING LLP
C Eichaé F. Bonkowsii (No. 2219$
Kin erly M. Large (No. 4422)
222 Delaware Avenue, Suite 1200
Wilmington, DE 19899-1266
(302) 42l-6863 (phone)
(302) 421-5869 (fax)
[email protected]
[email protected]
Attorney for Plaintiff, Today Media, Inc.
OfCounsel:
Sherry H. Flax
SAUL EWING LLP
500 E. Pratt St. Suite 900
Baltimore, MD 21202
(410) 332.-8784

Case 1 :07-cv-00087-JJF Document 3-2 Filed 02/16/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
TODAY MEDIA, INC. :
Plaintiff, :
v. Civil Action No.:
CBR MEDIA LLC JURY OF 12 DEMANDED
Defendant. :
ORDER
Upon consideration ofthe Motion of Plaintiff Today Media, Inc. for a Temporary
Restraining Order, together with the Verified Complaint and Memorandum of Law in Support of
said Motion, it is this Y day ofFebruary, 2007, by the United States District Court for the
District ol` Delaware, hereby ORDERED:
I. That Plaintiffs Motion be and the same hereby is GRANTED; and
2. That Defendant CBR Media, LLC ("Defendant") shall immediately cease and
desist hom any and all use ofthe term MAINLIN E, or any colorable imitation ofthe MAIN
LINE TODAY trademark, in connection with the title ofits magazines, including:
a. Removing the term MAINLINE from the cover ofthe magazine on
Defendants Internet site,
b. Recalling and removing all magazines that bear the title MAINLINE Hom
vendors and retail establishments; and
c. Ccasing production or printing of magazine covers that bear the title
MAINLINE.
3. The requirement for posting ofa Bond with surety is waived based on the lack of
any apparent damages that Defendant may sustain by reason ofthe issuance ofthis temporary
restraining order.

Case 1:07-ev-00087-JJF Document 3-2 Filed 02/16/2007 Page 2 of 2
4. This ORDER shall be served upon the Defendants (either personally or on their
agent or counsel) by no later than .
5. This ORDER shall expire ten (IO) days from date of entry by the Clerk unless
further extended bythe Court; and
6. This matter shall be set for a hearing on Plaintiffs Motion for Preliminary
injunction, said hearing to occur within days ofthe date hereof
United States District Judge
Milli} I Z. lt»tJ7 -2-