Arasan Chip Systems, Inc. v. Stream TV Networks, Inc.

Background

Arasan requested entry of a stipulated judgment under a written settlement agreement with Stream TV. The agreement provided that Arasan would not file or enforce the judgment while Stream TV timely made the required payments. If Stream TV defaulted, the agreement allowed Arasan to seek judgment for the remaining amount, plus applicable interest, attorney’s fees, and costs, without prior notice to Stream TV.

The parties later amended the payment schedule. According to a declaration from Arasan’s attorney, Stream TV initially paid $30,000, then made one additional $10,000 payment on August 13, 2020, and made no further payments. Arasan stated that $135,000 remained due and requested a stipulated judgment totaling $140,500: $135,000 in unpaid settlement amounts, $5,000 in attorney’s fees, and $500 in costs.

Court’s analysis

The court explained that a court may enforce a settlement agreement in a pending case and may enter a stipulated judgment according to the settlement’s terms. It found that Arasan had provided evidence of Stream TV’s default and of the amount requested. Stream TV had not appeared or opposed the request, although the court noted that Arasan had not filed proof that it served the request on Stream TV. The court also noted that Stream TV had been served with the summons and complaint and that the settlement allowed Arasan to seek judgment without prior notice after a default.

Ruling and next steps

Magistrate Judge Susan Van Keulen ordered the case reassigned to a district judge. She recommended that the district judge grant Arasan’s request for entry of the stipulated judgment. She also ordered Arasan to immediately serve Stream TV with the order and file proof of service. Any party could object to the recommendation within 14 days after service. This order recommended entry of the judgment; it did not itself state that the district judge had entered it.