This template is a settlement agreement for settling a copyright infringement litigation brought in a U.S. district court, with terms favorable to the copyright holder (plaintiff). This template includes practical guidance, drafting notes, and alternate and optional clauses. This settlement agreement is intended to be used in tandem with a Consent Order that includes a stipulated permanent injunction. Federal copyright disputes are settled in more than 70% of cases, and settlement agreements are commonly used to settle such disputes. This form may be used to resolve a case that is already in litigation, or be adapted for settling a dispute in the pre-litigation phase. Counsel should always make sure that any resolution is memorialized in a binding, written agreement, even if the client itself engages in direct oral negotiations with a potential adversary or reaches an oral resolution. Note that ABA Model Rule 4.2 (the "no contact" rule) forbids a lawyer from communicating with a client ...