In People ex rel. Brown v. iMergent, Inc. (2009) 170 Cal.App.4th 333, the defendants challenged a preliminary injunction which prohibited them from selling their products and services without complying with statutory consumer protection disclosure requirements and false advertising prohibitions. They asserted it was a mandatory injunction that did not meet the requirements for mandatory relief. (Id. at p. 341.) The court rejected the defendants' argument concluding "any aspects of the injunctions that require defendants to engage in affirmative conduct are merely incidental to the injunction's objective to prohibit defendants from further violating California's consumer protection laws. Accordingly, the injunction is prohibitory in nature (prohibitory injunction). ." (Id. at p. 342.)