prestige flag v. par aide - complaint

8/10/2019 Prestige Flag v. Par Aide - Complaint

1/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

SHEPPARD MULLIN RICHTER & HAMPTON LLP A Limited Liability Partnership

Including Professional CorporationsMICHAEL MURPHY (Cal. Bar No. 234695)

[email protected] Mullin Richter & Hampton LLP12275 El Camino Real, Suite 200San Diego, California 92130Telephone: (858) 720-8900Facsimile: (858) 509-3691

Attorney for PlaintiffPRESTIGE FLAG MFG. CO., INC.

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF CALIFORNIA

PRESTIGE FLAG MFG. CO., INC.,a California corporation,

Plaintiff,

v.PAR AIDE PRODUCTS CO.,a Minnesota corporation, and

DOES 110, inclusive,

Defendants.

Case No. COMPLAINT FOR:

(1) PATENT INFRINGEMENT;

(2) TRADE DRESS INFRINGEMENTUNDER 15 U.S.C. 1125(a);

(3) UNFAIR COMPETITION UNDER15 U.S.C. 1125(a);

(4) COMMON LAW UNFAIRCOMPETITION; AND

(5) UNFAIR COMPETITION UNDERSTATE LAW.

DEMAND FOR JURY TRIAL

'14 CV2711 JMAJAH

Case 3:14-cv-02711-JAH-JMA Document 1 Filed 11/14/14 Page 1 of 21


2/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

Plaintiff Prestige Flag Mfg. Co., Inc. (Prestige) complains and alleges as

follows against Defendant Par Aide Products Co. (Par Aide).THE PARTIES

1. Plaintiff is a California corporation, having a principal place of

business at 591 Camino De La Reina # 917, San Diego, California 92108.

2. On information and belief, Defendant Par Aide is a Minnesota

corporation, having a principal place of business at 6800 Otter Lake Road, Lino

Lakes, Minnesota 55038.

3. The true names, identities and capacities, whether individual, associate,

corporate or otherwise, of Defendants DOES 1 to 10, inclusive, and each of them

(the DOE Defendants), are unknown to Prestige at this time, who therefore suesthe DOE Defendants by such fictitious names. When the true names and capacities

or participation of the DOE Defendants are ascertained, Prestige will amend this

complaint to assert the true names, identities and capacities. Prestige is informed

and believes and thereon alleges that each of the DOE Defendants sued herein is

responsible for the wrongful acts alleged herein, and is therefore liable to Prestige in

some manner for the events and happenings alleged in this complaint. Prestige is

informed and believes and thereon alleges that at all times herein mentioned, the

DOE Defendants were and are doing business and/or residing in this District.

NATURE OF THE ACTION4. This is a civil action against Defendants for infringement of United

States Design Patent Numbers D564,405 (the D405 Patent), D546,243 (the

D243 Patent) and D536 637 (the D637 Patent) (collectively the Asserted



3/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

JURISDICTION AND VENUE

5. This Court has original subject matter jurisdiction of this action under15 U.S.C. 1121(a) (federal question), 28 U.S.C. 1331 (federal question), and 28

U.S.C. 1338(a) and (b) (any Act of Congress relating to patents and trademarks

and related unfair competition), and under the supplemental jurisdiction of this

Court, as embodied in 28 U.S.C. 1367(a).

6. This Court has specific and general personal jurisdiction over

Defendants pursuant to due process and/or the California Long Arm Statute because

Defendants have committed and continue to commit acts of infringement in

violation of 35 U.S.C. 271(a), (b), and (c), and place infringing products into the

stream of commerce, with the knowledge or understanding that such products aresold in the State of California, including in this judicial district. Moreover,

Defendants acts, including both unfair competition and other violations of

California law, caused and are causing injury to Prestige within this judicial district.

On information and belief, Defendants derive substantial revenue from the sale of

infringing products within this judicial district, expect their actions to have

consequences within this judicial district, and derive substantial revenue from

interstate and international commerce, including within this judicial district.

7. Venue is proper within this judicial district under 28 U.S.C. 1391(b)

because a substantial portion of the events giving rise to the claims for relief statedin this Complaint arose in this judicial district. Specifically, Defendants have sold

or offered for sale infringing products in this district, and have committed other acts

complained of infra within this district In addition venue is proper because



4/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

accessories, including a line of reflection rangefinder products for gauging distance.

Customers use Prestiges high quality products in many places throughout theworld, including the United States, Canada, Mexico, Europe, and Asia.

9. On October 25, 2013, Prestige duly acquired a golf stick and reflector

business from Golf Solutions I, L.L.C. d/b/a Laser Link Golf (the Laser Link

Business) pursuant to an asset purchase agreement between the two companies and

in exchange for substantial consideration. Further, pursuant to this asset purchase

agreement, Prestige acquired the intellectual property, goodwill, and physical assets

related to the Laser Link Business.

10. The acquired Laser Link Business includes reflection products such as

flagstick reflectors, sold under the names SmartStick (flagstick-embeddedreflectors) and Smarty (flagstick screw-on reflectors). The SmartStick is a golf

flagstick that contains reflective prism inserts embedded in the body thereof. The

Smarty 5 Reflector screws into the top of a golf flagstick, and contains five prisms

that reflect laser light. Coupled with a rangefinder, a device that sends laser light

toward the flagstick and receives laser light reflected back from reflectors in the

flagstick, each of Prestiges SmartStick and Smarty 5 Reflector (collectively,

Reflection Products), enable a golfer to accurately determine the distance between

the golfer and the flagstick.

11. In connection with its acquisition of the Laser Link Business and theassociated intellectual property and goodwill, Prestige acquired and owns all right,

title, and interest in the asserted design patents: (1) the D405 Patent, titled

Flagpole Reflector a copy of which is attached as Exhibit A ; (2) the D243



5/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

products. Prestige also acquired all of Golf Solutions Is rights and goodwill in the

trade names SmartStick and Smarty and the trade dress embodied in the SmartStickand Smarty.

12. Since acquiring the Laser Link Business, Prestige has continuously

offered for sale its Smarty and SmartStick products in interstate commerce, and has

vigorously protected its intellectual property, including the innovative and

distinctive designs of Prestiges Smarty and SmartStick that are protected through

the above-mentioned design patents issued by the United States Patent and

Trademark Office and duly assigned to Prestige. Prestiges design patents cover the

distinctive ornamental features of the Smarty 5 Reflector and SmartStick products,

including, for example, their overall appearances, shapes, and the location anddistribution of prisms throughout the devices. Prestige is informed and believes that

customers in the marketplace have come to associate these distinctive ornamental

features and overall appearances with Prestiges high quality products, including its

Smarty and SmartStick products.

13. On information and belief, Defendant Par Aide is a worldwide provider

of a number of golf course accessories. On information and belief, Par Aides

products are on sale and in use throughout the United States, including in the State

of California. As early as 2010, Par Aide offered for sale the SmartStick and

Smarty Reflector products. For example, Par Aides 2010 catalog, a copy of whichis attached as Exhibit D , offered the SmartStick products for sale according to

specific part numbers (e.g., 730-079, 740-079, etc.). Par Aide likewise offered the

Smarty Reflector for sale in its 2010 catalog under the part number 1736 Par Aide



6/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

14. Prestige is informed and believes that in 2014, Par Aide began offering

its own knock-off reflector products, dubbed Prism Flagsticks and PinSite Reflector,in lieu of the previously offered SmartStick and Smarty products. Prestige did not

authorize Par Aide to practice the designs claimed in the Asserted Patents. Nor has

Prestige authorized Par Aide to offer products confusingly similar to Prestiges

SmartStick and Smarty products. Similarly, Prestige has never authorized Par Aide

to use Prestiges duly held goodwill and intellectual property associated with the

Laser Link Business, including the distinctive trade dress customers have come to

recognize when seeking the SmartStick and Smarty Reflector.

15. Par Aides knock-off Prism Flagsticks bear a striking resemblance to

Prestiges SmartStick products. Par Aides Prism Flagsticks are shown in theattached Exhibit F , which is a screen shot from Par Aides website. On information

and belief, this resemblance includes overall the appearance of the SmartStick

products, for example, the shape and arrangement of the prisms in the sticks, and the

colors and overall design of the sticks. Thus, Par Aides Prism Sticks are

confusingly similar to the previously offered SmartStick products. Moreover, Par

Aid sells its Prism Flagsticks under the very same part numbers it previously used

for the SmartStick products, as demonstrated by the attached Exhibit G , which is a

screen shot from Par Aides website.

16. Additionally, Par Aides knock-off PinSite Reflector bears a strikingresemblance to Prestiges Smarty products. Par Aides PinSite Reflector is shown

in the attached Exhibit H , which is a screen shot from Par Aides website. On

information and belief this resemblance includes overall appearance of the Smarty



7/65


8/65


9/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

20. On information and belief, the resemblance between Par Aides Prism

Flagstick and Prestiges SmartStick products (and the designs claimed in theAsserted Patents) is such as to deceive an ordinary observer, giving such attention as

a purchaser usually gives, including inducing the purchaser to purchase one

supposing it to be the other. Par Aides Prism Flagsticks have an overall appearance

that is confusingly similar and substantially the same, in view of the prior art and in

the eyes of an ordinary observer, as Prestiges SmartStick products (and the designs

claimed in the Asserted Patents), as demonstrated by the side-by-side comparison

below (Table 2).

Table 2

Figure 8D637

PrismFlagstick

Figure 6D637

PrismFlagstick



10/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

FIRST CAUSE OF ACTION

Infringement of Design Patent D40521. Prestige incorporates and realleges Paragraphs 1 through 20 of this

Complaint.

22. Under 35 U.S.C. 271(a), Defendants have infringed and continue to

infringe, literally or under the doctrine of equivalents, the D405 Patent by making,

using, selling, and/or offering to sell in the United States, and/or importing into the

United States the PinSite Reflector identified in this Complaint, which PinSite

Reflector embodies the design covered by the D405 Patent.

23. Moreover, Defendants have infringed and continue to infringe the

D405 Patent indirectly, under 35 U.S.C. 271(b) and (c), by inducing others toinfringe the D405 Patent, and by committing acts that constitute contributory

infringement of the D405 Patent.

24. On information and belief, Defendants have gained profits by virtue of

their infringement of the D405 Patent.

25. On information and belief, Prestige has sustained damages as a direct

and proximate result of Defendants infringement of the D405 Patent, and, as such,

Prestige is entitled to damages pursuant to 35 U.S.C. 284 and/or 289.

26. Moreover, Prestige is informed and believes that Defendants

infringement of the D405 Patent is and has been willful. On information and belief,Defendants have acted and continue to act with objective recklessness by

proceeding despite an objectively high likelihood that their actions constitute

infringement of Prestiges valid patents and Defendants are aware of Prestiges



11/65


12/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

including the D243 Patent, and know of the high likelihood that they cover

Defendants products.35. This is an exceptional case warranting an award of treble damages to

Prestige under 35 U.S.C. 284, and an award of attorneys fees under 35 U.S.C.

285.

36. On information and belief, Prestige will suffer and is suffering

irreparable harm from Defendants infringement of the D243 Patent. Prestige has

no adequate remedy at law and is, under 35 U.S.C. 283, entitled to an injunction

against Defendants continuing infringement of the D243 Patent. Unless enjoined,

Defendants will continue their infringing conduct.

THIRD CAUSE OF ACTION Infringement of Design Patent D637

37. Prestige incorporates and realleges Paragraphs 1 through 36 of this

Complaint.

38. Under 35 U.S.C. 271(a), Defendants have infringed and continue to

infringe, literally or under the doctrine of equivalents, the D637 Patent by making,

using, selling, and/or offering to sell in the United States, and/or importing into the

United States the Prism Flagsticks identified in this Complaint, which Prism

Flagsticks embody the design covered by the D637 Patent.

39. Moreover, Defendants have infringed and continue to infringe theD637 Patent indirectly, under 35 U.S.C. 271(b) and (c), by inducing others to

infringe the D637 Patent, and by committing acts that constitute contributory

infringement of the D637 Patent



13/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

42. Moreover, Prestige is informed and believes that Defendants

infringement of the D637 Patent is and has been willful. On information and belief,Defendants have acted and continue to act with objective recklessness by

proceeding despite an objectively high likelihood that their actions constitute

infringement of Prestiges valid patents, and Defendants are aware of these patents,

including the D637 Patent, and know of the high likelihood that they cover

Defendants products.

43. This is an exceptional case warranting an award of treble damages to

Prestige under 35 U.S.C. 284, and an award of attorneys fees under 35 U.S.C.

285.

44.

On information and belief, Prestige will suffer and is sufferingirreparable harm from Defendants infringement of the D637 Patent. Prestige has

no adequate remedy at law and is, under 35 U.S.C. 283, entitled to an injunction

against Defendants continuing infringement of the D637 Patent. Unless enjoined,

Defendants will continue their infringing conduct.

FOURTH CAUSE OF ACTION

Trade Dress Infringement, 15 U.S.C. 1125(a)(3))


Complaint.

46. Prestiges trade dress consists of the following elements as actuallyused on the SmartStick products: a combination of a golf flagpole with reflectors

embedded in the body of the flagpole. These elements have consistently been

marketed under the trade name SmartStick and have generated goodwill and


C 3 14 02711 JAH JMA D 1 Fil d 11/14/14 P 14 f 21


14/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

offering its infringing Prism Flagsticks there was no other product on the market

bearing the SmartStick trade dress.48. Prestige is informed and believes, and thereon alleges, that Par Aide

has been designing, marketing, offering for sale and selling products that

incorporate Prestiges SmartStick trade dress.

49. Par Aide is not now, and never has been, authorized by Prestige to use

Prestiges trade dress or any confusingly similar trade dress in connection with the

marketing and/or sale of Par Aides infringing Prism Flagstick.

50. Previously, Par Aide sold Prestiges SmartSticks in its catalogs. See

Exs. D and E. Catalogs offering the SmartSticks associated the SmartStick products

with the SmartStick trade name. See id. Par Aides marketing and sale of copies ofinfringing flag sticks is likely to cause confusion, mistake, and/or deception among

consumers as to the source, quality, and nature of Prestiges SmartSticks.

51. Prestige has suffered actual damages from Par Aides conduct in an

amount to be proven at trial.

52. Par Aide has received wrongful gains from its conduct in an amount to

be proven at trial.

53. Prestige is informed and believes, and thereon alleges that, unless

restrained by the Court, Par Aide will continue to infringe Prestiges SmartStick

trade dress, thus engendering a multiplicity of judicial proceedings, and that pecuniary compensation will not afford Prestige adequate relief for the damage to its

trade dress in the public perception. Further, Prestige is informed and believes, and

thereon alleges that in the absence of injunctive relief customers are likely to


C 3 14 02711 JAH JMA D t 1 Fil d 11/14/14 P g 15 f 21


15/65

1

23

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

deceive, and to cause injury to the reputation and goodwill associated with Prestige

and its SmartSticks. Pursuant to 15 U.S.C. 1117, Prestige is therefore entitled torecover three times its actual damages or three times Par Aides profits, whichever is

greater, together with Prestiges attorneys' fees. In addition, pursuant to 15 U.S.C.

1118, Prestige is entitled to an order requiring destruction of all infringing products

and promotional materials in Par Aides possession.

FIFTH CAUSE OF ACTION

Unfair Competition Under 15 U.S.C. 1125(a)


Complaint.

56.

The acts of Par Aide complained of above are likely to cause confusion,or to cause mistake, or to deceive as to the affiliation, connection, or association as

to the origin, sponsorship, or approval of Par Aides and Prestiges goods.

Moreover, the acts of Par Aid complained of above misrepresent the nature,

characteristics, or qualities of Par Aides and Prestiges goods. These acts thus

constitute false designation of origin and/or affiliation, false or misleading

description of fact, or false or misleading representation of fact, in violation of 15

U.S.C. 1125(a).

57. Prestige is informed and believes that Par Aides acts include, for

example, offering Par Aides Prism Flagsticks and PinSite Reflector for sale and piggybacking off Prestiges goodwill, not only by copying the distinctive designs

and appearances of Prestiges SmartSticks and Smarty products, but also by

retaining the same part numbers that Par Aide previously used to identify these


Case 3:14 cv 02711 JAH JMA Document 1 Filed 11/14/14 Page 16 of 21


16/65

1

2

3

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

60. Prestige is informed and believes, and thereon alleges that, unless

restrained by the Court, Par Aide will continue to designate falsely the origin of itsgoods, causing irreparable damage to Prestige and engendering a multiplicity of

lawsuits. Pecuniary compensation will not afford Prestige adequate relief for its

resulting damages. Further, Prestige is informed and believes, and thereon alleges,

that in the absence of injunctive relief, customers are likely to continue being

mistaken or deceived as to the true source, origin, sponsorship, and affiliation of Par

Aides goods.

61. Prestige is informed and believes, and thereon alleges, that Par Aides

acts were committed, and continue to be committed, with actual notice of Prestiges

exclusive rights and with intent to cause confusion, to cause mistake, and/or todeceive, and to cause injury to the reputation and goodwill associated with Prestige

and its SmartSticks. Pursuant to 15 U.S.C. 1117, Prestige is therefore entitled to

recover three times its actual damages or three times Par Aides profits, whichever is

greater, together with Prestiges attorneys' fees. In addition, pursuant to 15 U.S.C.

1118, Prestige is entitled to an order requiring destruction of all infringing products

and promotional materials in Par Aides possession.

SIXTH CAUSE OF ACTION

Common Law Unfair Competition

62.

Prestige incorporates and realleges Paragraphs 1 through 61 of thisComplaint.

63. The acts of Par Aide complained of above constitute unfair competition

under the common law of the State of California Prestige expended significant time




17/65

1

2

3

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

suffered harm as a resultincluding, for example, lost sales and customer

confusion.64. Prestige is informed and believes that further examples of Par Aides

acts of unfair competition include sales of confusingly similar Par Aide products.

65. Prestige has suffered actual damages from Par Aides conduct in an

amount to be proven at trial.

66. Par Aide has received wrongful gains from its conduct in an amount to

be proven at trial.

67. Par Aides acts complained of above were committed with fraud,

malice, and oppression as those terms are defined in Cal. Civ. Code 3294. Par

Aides actions were intended to cause harm to Prestige, and Par Aide carried on itsconduct with a willful and conscious disregard for Prestiges rights. Par Aide

intentionally misrepresented, deceived, and/or concealed its conduct and Prestiges

relationship with the SmartStick and Smarty products, thereby depriving Prestige of

its legal rights and causing Prestige injury.

SEVENTH CAUSE OF ACTION

Statutory Unfair Competition Under Cal. Bus. & Prof. Code 17200 & 17500


Complaint.

69.

Par Aides acts complained of above constitute unlawful, unfair, orfraudulent business practices, and deceptive, untrue, or misleading advertising in

violation of California statutory law, including violation of Cal. Bus. & Prof. Code

17200 and 17500 all to Prestiges injury Moreover the above-described acts




18/65

1

2

3

4

5

6

7

8

9

10

1112

13

14

15

16

17

18

19

2021

22

23

71. Prestige is entitled to an injunction restraining Par Aide and its officers,

against, and employees, and all persons acting in concert or participation with them,from further engaging in any such acts of unfair competition as alleged above.

Prestige has no adequate remedy at law for Par Aides continuing violation of

Prestiges rights.

72. Prestige is further entitled to recover from Par Aide the damages,

including attorneys fees, it has sustained and will sustain, and any gains, profits,

and advantages obtained by Par Aide as a result of Par Aides acts of unfair

competition alleged above. At present, Prestige cannot fully ascertain the amount of

such damages, gains, profits, and advantages. Par Aide should be required to fully

restore to Prestige any and all profits earned as a result of Par Aides unlawful andfraudulent actions, or to provide Prestige with any other restitutionary relief as the

Court deems appropriate.

73. Prestige is informed and believes and on that basis alleges that the

alleged acts of Par Aide were willful and malicious, entitling Prestige to punitive

damages.

PRAYER

WHEREFORE, Prestige prays:

(a) For a judgment that Defendants have infringed one or more

claims of Prestiges Asserted Patents and Prestiges SmartStick trade dress;(b) For an order and judgment preliminarily and permanently

enjoining Defendants and their officers, directors, agents, servants, employees,

affiliates attorneys and all others acting in privity active concert or participation

Case 3:14 cv 02711 JAH JMA Document 1 Filed 11/14/14 Page 18 of 21



19/65

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

2021

22

23

(c) That Defendants be directed to file with this court, within thirty

days after entry of any injunction in this case, a written statement, under oath,

setting forth in detail the manner in which Defendants have complied with the

injunction;

(d) For a judgment awarding Prestige all damages, in an as yet

undetermined amount, adequate to compensate for Defendants infringement of

Prestiges Asserted Patents, and in no event less than a reasonable royalty for

Defendants acts of infringement, including all pre-judgment and post-judgment

interest at the maximum rate permitted by law;

(e) For a judgment awarding Prestige all damages, including treble

damages, based on any infringement found to be willful, pursuant to 35 U.S.C. 284, together with prejudgment interest;

(f) For a judgment that Defendants and their officers, agents,

distributors, employees, attorneys, subsidiaries, assigns, or related companies, and

those in active concert or participation with any of them, who receive actual notice

of the judgment by personal service or otherwise, be permanently enjoined from

using, offering for sale, or employing, directly or indirectly, any device, product, or

the like, that is confusingly similar to, or is likely to confuse or deceive as to the

affiliation, connection, sponsorship, or association of, the Reflection Products or

commercial activities of Defendants with Plaintiff or the Reflection Products, orwith Plaintiffs commercial activities;

(g) That an accounting be directed to determine Defendants profits

resulting from their false designation of origin and affiliation and unfair

g



20/65

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

2021

22

23

(i) That Prestige be awarded punitive damages in an amount to be

determined;

(j) For costs of suit and reasonable attorneys fees; and

(k) For any other remedy to which Prestige may be entitled under

the law, and any other further relief as the Court may deem appropriate.

DEMAND FOR JURY TRIAL

Prestige requests a trial by jury on all issues so triable in this action.

Respectfully submitted,

Dated: November 14, 2014

SHEPPARD, MULLIN, RICHTER& HAMPTON LLP

By /s/ Michael MurphyMICHAEL MURPHYAttorney for Plaintiff

PRESTIGE FLAG MFG. CO., INC.

g



21/65

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

2021

22

23

CIVIL COVER SHEET

Case 3:14-cv-02711-JAH-JMA Document 1-1 Filed 11/14/14 Page 1 of 1


22/65

CIVIL COVER SHEET

(SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

(b) (EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

(c) (Firm Name, Address, and Telephone Number) (If Known)

II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff (For Diversity Cases Only) and One Box for Defendant)

PTF DEF PTF DEF (U.S. Government Not a Party) or

and (Indicate Citizenship of Parties in Item III)

IV. NATURE OF SUIT (Place an X in One Box Only)CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

PERSONAL INJURY PERSONAL INJURY PROPERTY RIGHTS

LABOR SOCIAL SECURITY

PERSONAL PROPERTY

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS FEDERAL TAX SUITS Habeas Corpus: IMMIGRATION

Other:

V. ORIGIN (Place an X in One Box Only)

PRESTIGE FLAG MFG. CO., INC.,a California corporation

San Diego

MICHAEL MURPHY (Cal. Bar No. 234695) 858.720.8900Sheppard Mullin Richter & Hampton LLP12275 El Camino Real, Suite 200, San Diego, CA 92130

PAR AIDE PRODUCTS CO.,a Minnesota corporation

Anoka County

'14 CV2711 JMAJAH


23/65



24/65

USOOD564405S

c12) United States Design Patent c1o) Patent No.: US D564,405 S** Mar. 18, 2008Loughlin et al. (45) Date of Patent:

(54) FLAGPOLE REFLECTOR(75) Inventors: Robert F. O Loughlin, Madison, WI

(US); Michael D. Plitman,Minneapolis, MN (US); Daniel Steiner,Waunakee, WI (US); WayneTimberman, Carmel, IN (US)

(73) Assignee: Golf Solutions I, L.L.C., Madison, WI(US)

(**) Term: 14 Years

(21) Appl. No.: 29/276,640(22) Filed: Jan. 31, 2007(51) LOC (8) Cl. ................................................. 11-05(52) U.S. Cl. ..................................................... Dll/181(58) Field of Classification Search ....... Dll/165-167,

Dll/180--183; 116/173-175, 202; Dl0/70;D21/759, 790; 362/190, 296

See application file for complete search history.(56) References Cited

U.S. PATENT DOCUMENTSD242,775 S * 12/1976 Williams, Jr . . . . . . . . . . . . . . . . D10/70

(Continued)

OTHER PUBLICATIONS

Internet World Wide Web Page, www.laserlinkgolf.com/smartyPressRelease.htrn, dated Jan. 12, 2005.

Primary Examiner Ian SimmonsAssistant Examiner Anhdao Doan(74) Attorney Agent or Firm Foley & Lardner LLP

(57) CLAIM

We claim the ornamental design for a flagpole reflector, asshown and described.

DESCRIPTION

FIG. 1 is a perspective view of a first embodiment of theclaimed design;FIG. 2 is a first side view of the embodiment of FIG. 1;

FIG. 3 is a second side view of the embodiment of FIG. 1with the flagpole reflector rotated approximately 90 degreesfrom the view of FIG. 2;

FIG. 4 is a third side view of he embodiment of FIG. 1, withthe flagpole reflector rotated approximately 90 degrees fromthe view of FIG. 3;FIG. 5 is a fourth side view of the embodiment of FIG. 1,with the flagpole reflector rotated approximately 90 degreesfrom the view of FIG. 4;FIG. 6 is a top view of the embodiment of FIG. 1;FIG. 7 is a bottom view of the embodiment of FIG. 1;FIG. 8 is a perspective view of a second embodiment of the

claimed design;FIG. 9 is a first side view of the embodiment of FIG. 8;FIG. 10 is a second side view of the embodiment of FIG. 8with the flagpole reflector rotated approximately 90 degreesfrom the view of FIG. 9;FIG. 11 is a third side view of the embodiment of FIG. 8with the flagpole reflector rotated approximately 90 degreesfrom the view of FIG. 10;FIG. 12 is a fourth side view of the embodiment of FIG. 8with the flagpole reflector rotated approximately 90 degrees

from the view of FIG. 11;FIG. 13 is a top view of the embodiment of FIG. 8;FIG. 14 is a bottom view of the embodiment of FIG. 8;FIG. 15 is a perspective view of a third embodiment of theclaimed design;FIG. 16 is a first side view of the embodiment of FIG. 15;FIG. 17 is a second side view of the embodiment of FIG. 15,with the flagpole reflector rotated approximately 90 degreesfrom the view of FIG. 16;FIG. 18 is a third side view of the embodiment of FIG. 15,

with the flagpole reflector rotated approximately 90 degreesfrom the view of FIG. 17;FIG. 19 is a fourth side view of the embodiment of FIG. 15,with the flagpole reflector rotated approximately 90 degreesfrom the view of FIG. 18;FIG. 20 is a top view of the embodiment of FIG. 15; and,FIG. 21 is a bottom view of the embodiment of FIG. 15.The broken lines in FIGS. 1-5, 7-12, 14-19, and 21 are forillustrative purposes only and form no part of the claimeddesign.

1 Claim, 9 Drawing Sheets



25/65

US D564,405 SPage 2

U.S. PATENT DOCUMENTS 6,346,055 B1 * 212002 Rege .......................... 473/199

4,136,394 A *4,905,624 A *D379,436 s *

111979 Jones eta . ................. 367/1083/1990 Krolzick .................. ... 116/1735/1997 Palmer ...................... D10/109

D526,930 S * 8/2006 Plitman .... ..... ..... .... ... D111182

* cited by examiner


26/65



27/65

U.S. Patent Mar.18,2008 Sheet 2 of 9 US D564,405 S

::::::.

-



28/65

U.S. Patent Mar.18,2008 Sheet 3 of 9

l.l :

l ~ ~ : - : : : : : ~ : : ~ : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : ll:o. ~ ~ ;>;>.;;>;-;-;-;-;-;-;-;-;-;>;>;>;-;-;-:-:0.";-;>.;":":":0.":0:0:-:-:-:-:-:-:-:-:-:-:-:-:-:-:-... ....... ...... .... ' ....................... .

:""""'""''n""""'""""""""""""""""""""""""""""""""""""""""""'""""""

f < / < : ~ :j

US D564,405 S

-



29/65

U.S. Patent Mar.18,2008

0 0

..............

0 } . .. . '... .

f" ~~

Sheet 4 of 9 US D564,405 S



30/65


-

f--1r-- ' l

~

Sheet 5 of 9 US D564,405 S



31/65


mr--f,

.,,~



32/65


-

u;. . ,: : -r - 4



33/65

U.S. Patent

~ . ......

Mar.18,2008 Sheet 8 of 9 US D564,405 S

- ~

r--1~ M



34/65


0N .

t.l

Sheet 9 of 9

, . . --I

N .. _ .

'

US D564,405 S



35/65

Exhibit B

USOOD546243S



36/65

c12) United States Design Patent c1o) Patent No.: US D546,243 S** Jul. 10, 2007Loughlin et al. (45) Date of Patent:

(54) FLAGSTICK REFLECTOR

(75) Inventors: Robert F. O Loughlin, Madison, WI(US); Michael Plitman, Minneapolis,MN (US); Daniel Steiner, Waunakee,WI (US); Wayne Timberman, Carmel,IN (US)

(73) Assignee: Golf Solutions 1, L.L.C., Madison, WI(US)

(**) Term: 14 Years

(21) Appl. No.: 29/212,569

(22) Filed: Sep. 2, 2004

(51) LOC (8) Cl. ................................................. 11-05

(52) U.S. Cl. ..................................................... Dll/181

(58) Field of Classification Search ....... Dll/165-168,Dll/181-183; 116/173-175; 248/519, 538;

362/190, 296; 356/4.01; 473/199, 409;Dl0/70

See application file for complete search history.

(56) References Cited

U.S. PATENT DOCUMENTS

D242,775 s * 12/1976 Williams, Jr . ..... ..... ..... D10/704,136,394 A * 111979 Jones eta . ................. 702/1596,062,985 A * 5/2000 Rege ..................... ..... 473/1996,346,055 B1* 212002 Rege .......................... 473/409D465,174 s * 1112002 Ursprung ..... ..... .... ..... D111165

2005/0272515 A1 * 12/2005 Hurley et al . . . . . . . . . . . . . . . . 473/173

OTHER PUBLICATIONS

Internet World Wide Web Page , http:/ www.laserlinkgolf.com,printed Oct. 22, 2004.

* cited by examiner

Primary Examiner Louis S. ZarfasAssistant Examiner Anhdao Doan(74) Attorney Agent or Firm Foley & Lardner, LLP

(57) CLAIM

We claim the ornamental design for a flagstick reflector, asshown and described.

DESCRIPTIONFIG. 1 is a perspective view of the claimed design;FIG. 2 is a top view of the embodiment of FIG. 1;

FIG. 3 is a bottom view of the embodiment of FIG. 1;

FIG. 4 is a first side view of the embodiment of FIG. 1;

FIG. 5 is a second side view of the embodiment of FIG. 1,with the flagstick reflector rotated approximately 72 degreesfrom the view of FIG. 4;

FIG. 6 is a third side view of he embodiment of FIG. 1 withthe flagstick reflector rotated approximately 72 degrees fromthe view of FIG. 5;

FIG. 7 is a fourth side view of the embodiment of FIG. 1with the flagstick reflector rotated approximately 72 degreesfrom the view of FIG. 6; and,FIG. 8 is a fifth side view of the embodiment of FIG. 1 with

the flagstick reflector rotated approximately 72 degrees fromthe view of FIG. 7.The broken lines in the drawings are for illustrative purposesonly and form no part of the claimed design.




37/65

U.S. Patent Jul. 10, 2007 Sheet 1 of 2 US D546,243 S

FIG. 2

FIG. 1

FIG. 3

FIG. 4

U S S 6 2 3 S



38/65

U.S. Patent Jul. 10, 2007 Sheet 2 of 2 US D546,243 S

FIG. 6 FIG. 7

FIG 8 Case 3:14-cv-02711-JAH-JMA Document 1-4 Filed 11/14/14 Page 1 of 10


39/65

Exhibit C

IUSOOD536637S



40/65

c12) United States Design Patent c1o) Patent No.: US D536,637 S** Feb. 13, 2007litman (45) Date of Patent:

(54) FLAG STICK REFLECTOR INSERT

(75) Inventor: Michael D. Plitman, Minneapolis, MN(US)

(73) Assignee: Golf Solutions 1, L.L.C., Madison, WI(US)

(**) Term: 14 Years

(21) Appl. No.: 29/207,516

(22) Filed: Jun. 15, 2004

(51) LOC (8) Cl. .................................................... 11-05

(52) U.S. Cl. ...................................................... Dll/182

(58) Field of Classification Search ........ Dll/165-168,Dll/181-183; 116/173-175; 248/519, 538;

362/190, 296; 356/4.01; 473/199, 409; D1 0/70

See application file for complete search history.

(56) References Cited

U.S. PATENT DOCUMENTS

D242,775 S * 12/1976 Williams, Jr . . . . . . . . . . . . . . . . D10/704,136,394 A * 111979 Jones eta . ................. 702/1596,062,985 A * 5/2000 Rege ..................... ..... 473/1996,346,055 B1 * 212002 Rege .......................... 473/409D465,174 S * 1112002 Ursprung ..... ..... .... ..... D111165

2005/0272515 A1 * 12/2005 Hurley et al . . . . . . . . . . . . . . . . 473/173

* cited by examiner

Primary Examiner Louis S. ZarfasAssistant Examiner Anhadao Doan(74) Attorney Agent or Firm Foley & Lardner LLP

(57) CLAIM

The ornamental design for a flag stick reflector insert,substantially as shown and described.

DESCRIPTION

FIG. 1 is a perspective view of the flag stick reflector insertshowing my design;FIG. 2 is a side plan view of the insert shown in FIG. 1;FIG. 3 is a side view of the insert shown in FIG. 1 with theinsert rotated approximately no from the view shown inFIG. 2;FIG. 4 is a side view of the insert shown in FIG. 1, with theinsert rotated approximately no from the view shown inFIG. 3;FIG. 5 is a side view of the insert shown in FIG. 1 with theinsert rotated approximately no from the view shown inFIG. 4;FIG. 6 is a side view of the insert shown in FIG. 1 with theinsert rotated approximately no from the view shown inFIG. 5;FIG. 7 is a top view of he insert shown in FIG.1, the bottomview being a mirror image of the top view; and,FIG. 8 is a perspective view of the insert of FIG. 1 in a usestate, with a flag stick shown using broken lines where thebroken lines are for illustrative purposes only and form nopart of the claimed design.



41/65

U S Patent Feb l3 2007 Sheet 2 of 8 US D536 637 S



42/65

U.S. Patent Feb.l3,2007 Sheet 2 of 8 US D536,637 S

I

II

~

~:

'J....

~r\

t?i'J

II I

U S Patent Feb l3 2007 Sheet 3 of 8 US D536,637 S



43/65


I

JI I

~ ~

\t1

k ~

~..,. J/1\J

I I

U S Patent Feb l3 2007 Sheet 4 of 8 US D536,637 S



44/65

U.S. Patent Feb.l3,2007 S eet o 8

I a

'

I C


45/65




46/65

U.S. Patent ,

I

II

~ 1

i/~y,...

~

\

v."

I I

U.S. Patent Feb.13,2007 Sheet 7 of 8 US D536,637 S



47/65

FIG. 7

U.S. Patent Feb.13,2007 Sheet 8 of 8 US D536,637 S



48/65

E,\I

..

..

........

........

..

........

..

......

..

..

..................

......

..

.....

.



49/65

Exhibit D

THE PAR AIDEFLAGSTICK

TRUST ONLY THE ORIGINAL

F b gl ss Fl gst ks

Case 3:14-cv-02711-JAH-JMA Document 1-5 Filed 11/14/14 Pa ge 2 of 7Get a quote
http://www.allturf.ca/get-a-quotehttp://www.allturf.ca/get-a-quote


50/65

29GREEN PRODUCTS

The p r a de Fl gst ck. Yes, the often- m t ted des gnth t roves p r a des nnov t on le ds the ck. Wh tsets t rt s the tented no-st ck ferrule. introduced13 ye rs go, t st ll out erforms ny other n the

ndustry. and heres why:

S v g v s z s f t t w th th l t 2/3 f th l f t

t by st ght f l.

G v s l t s s ttl t f th b tt thth th .

d - st z s g s s s st t.

W ll ly t t th s k t v t g thfl gst k f k g th w l g t gth h l .

1. S l r g l t F b gl ss Fl gst ks1/2 . (1.3 )7 ft. (2.14 ) T llB x s f 9 Best Value730-079 Bright White740-079 Bright Yellow$135.00 ( $15.00/each)

8 ft. (2.44 ) T ll730-089 Bright White740-089 Bright Yellow$144.00 ( $16.00/each)

2. St r g l t F b gl ss Fl gst ks1/2 . (1.3 )5 ft. (1.53 ) T llB x s f 9 Best Value720-059 Red & White$146.25 ( $16.25/each)

7 ft. (2.14 ) T ll725-079 2 Stripe Red & White752-079 2 Stripe Black & White747-079 2 Stripe Black & Yellow720-079 3 Stripe Red & White750-079 3 Stripe Black & White755-079 3 Stripe Green & White$168.75 ( $18.75/each)

745-079 Bright Yellow with 30 in. (76.2 cm)Black Bottom

754-079 Bright White with 30 in. (76.2 cm)Black Bot tom

$157.50 ( $17.50/each)

St r g l t F b gl ss Fl gst ks1/2 . (1.3 ) ( t.)

8 ft. (2.44 ) T ll725-089 2 Stripe Red & White752-089 2 Stripe Black & White747-089 2 Stripe Black & Yellow720-089 3 Stripe Red & White750-089 3 Stripe Black & White755-089 3 Stripe Green & White$177.75 ( $19.75/each)

745-089 Bright Yellow with 30 in. (76.2 cm)Black Bottom

754-089 Bright White with 30 in. (76.2 cm)Black Bottom

$168.75 ( $18.75/each)

Flagsticks are available in 10 ft. (3.05 m)and 12 ft. (3.66 m) tall. Special shippingrequired. Contact Par Aide for available models.

1 2

Individual flagsticks are available. Add $0.75 per flagstick for individual quantities other than box of 9. Call dealer for details.

30 in.(76.2 cm)

Green producTS28

PAR90020_2010Catalog_22-41 28-29 11/23/09 9:39:24 AM

Exhibit D - Page 44

Get a Quote

al T t Fl gst ksT T t Fl gst ks

They measure 7 f t. 6 in. (2.29 m) high and taper from a 3/4 in. (1.9 cm) diameter in the middle to 1/2 in. (1.3 cm) at the ends.More visible and offers a solid and sturdy look and feel.

1 IN. (2.5 CM) ALUMINUM/FIBERGLASS TOURNAMENT FLAGSTICKS

A full 8 ft. (2.44 m) tall, this lightweight exclusive Par Aide design meets USGA regulations.

Ultimate visibility.

Top and bottom shanks are 1/2 in (1 3 cm) diameter color-impregnated fiberglass in bright yellow bright white or black3

Case 3:14-cv-02711-JAH-JMA Document 1-5 Fil ed 11/14/14 Page 3 of 7Get a Quote
http://www.allturf.ca/get-a-quotehttp://www.allturf.ca/get-a-quotehttp://www.allturf.ca/get-a-quote


51/65

Green producTS30 Green producTS 31


Swivel forTie-Style Flags

Top Stud

Acorn Nut

15 in.(38.1 cm)

18 in.(45.7 cm)

30 in.(76.2 cm)

30 in.(76.2 cm)

5. al /F b gl ss T t Fl gst ks 1 . (2.5 )8 ft. ( 2.44 ) T llBoxes of 9 Best Value701-089 Bright Yellow702-089 Bright White$297.00 ( $33.00/each)

703-089 One Black Stripe (As shown)$346.50 ( $38.50/each)

704-089 Two Black Stripes (As shown)$360.00 ( $40.00/each)

705-089 Three Black Stripes (As shown)$373.50 ( $ 41.50/each)

al /F b gl ss T t Fl gst ks 1 . (2.5 ) ( t.)703-99 One Custom Stripe*

$38.50

704-99 Two Custom Stripes*$40.00

705-99 Three Custom Stripes*$

41.50*For all other colors/combinations please clearly indicate color(s) and patterns when ordering.


Top and bottom shanks are 1/2 in. (1.3 cm) diameter, color-impregnated fiberglass in bright yellow, bright white, or black.

Flagstick body is 1 in. (2.5 cm) diameter aluminum.

Powder-coated body allows for a completely custom look. Colors and patterns can be changed to accommodate your course needs.

48 in.(121.9 cm)

18 in.(45.7 cm)

15 in.(38.1 cm)

15 in.(38.1 cm)

18 in.(45.7 cm)

18 in.(45.7 cm)

15 in.(38.1 cm)

18 in.(45.7 cm)

11 in.(27.9 cm)

7 in.(17.8 cm)

15 in.(38.1 cm)

5

al /F b gl ssT t Fl gst ks

T F b gl ssT t Fl gst ks

3/4 . (1.9 )

3. T F b gl ss T t Fl gst ks 3/4 . (1.9 )7 ft. 6 . (2.29 ) T llBoxes of 9 Best Value706-079 Bright White707-079 Bright Yellow$288.00 ( $32.00/each)

708-079 British Stripe Black & White712-079 British Stripe Red & White713-079 British Stripe Green & White714-079 British Stripe Black & Yellow$315.00 ( $35.00/each)

709-079 Bright Yellow with 30 in. (76.2 cm) Black Bottom 711-079 Bright White with 30 in. (76.2 cm) Black Bottom

$306.00 ( $34.00/each)

Patented Ferrule 4

Fl gst k p ts

4. Fl gst k p ts1715 Swivel for Tie-Style Flags$3.75

1729-6 Patented FerrulePackage of 6$29.70

1732-6 Top StudPackage of 6

$12.00

1733-6 Acorn NutPackage of 6$3.00

PAR90020_2010Catalog_22-41 30-31 11/23/09 9:39:27 AM

Exhibit D - Page 45

Get a Quote
http://www.allturf.ca/get-a-quote


52/65

paraide.com 1-888-893-2433p tt g c s

Five distinctive styles, each with the hallmarks of Par Aide products: durability, great appearance and impeccable quality. Yourchoices include two styles of the brightest white plastic cups in the industry, our traditional machined aluminum cup, zinc cup, andour patented Ever-White Cup, with replaceable plastic sleeves.

Case 3:14-cv-02711-JAH-JM A Document 1-5 Filed 11/14/14 Page 5 of 7Get a Quote


53/65


The patented Ever-White Cup has revolutionized the category by teaming analuminum outside with a bright white plastic sleeve.

No paint to chip, eliminating the need for stripping, sanding and painting.

Easily replaceable sleeve stays tight in the cup during play.

Resonates with the classic aluminum sound when the ball drops in.

1. ev -Wh t cPatented aluminum cup complete with plastic sleeve. Meets allUSGA regulations.935$23.50/each

Ever-White Cup Replacement SleevesCase of 18. (Sleeves not sold individually)935-1

$29.50

2. pl st p tt g c sDurable bright white plastic cupsfeaturing minimum taper for a snugfit, both on the course and on thepractice green. Meets all USGAregulations.

920 6 in. (15.2 cm) RegulationCup$6.00/each

3. p t Gpl st p tt g c sDurable bright white plastic cupsfeaturing minimum taper for a snugfit. Meets all USGA regulations.

940 4 in. (10.2 cm) Practice Cup$5.00/each

4. al p tt g c s Our classic model, its die cast

oversize, then machined down toprecision dimensions to minimizewobble in the hole. Meets allUSGA regulations.

Surfaces anodized anddichromated for ultimatecorrosion protection.

The cups vertical surfaces arepowder coated bright white. Thebottom of the cup is not powdercoated, so theres no paintto chip.

930 6 in. (15.2 cm)Regulation Cup

$21.50/each

5. Z c sSame characteristics as thealuminum model but molded inZinc for improved overall strength.Zinc also increases weight of cupfor more stability. Inside of cuppowder coated white. Meets allUSGA Regulations.

937 6 in. (15.2 cm) RegulationCup$33.00/each

6. c StBy inserting this rigid plastic diskinto the bottom of the cup, thecup will not sink into the greenonce it is set. Also preventsflagsticks from bottoming out.Please choose the appropriate cupstop to fit your Par Aide modelputting cups.

c St ( t.) 932 Use with Par Aide cup

model #s 920, 930 and 935only. Set of 18.

$35.00

7. p t g d sks(Not shown)

For masking bottom of aluminumcups when repainting.

931 Painting Disks, set of 50

$17.00

2

pl st p tt g c s

3

p t G pl stp tt g c s

4

al p tt g c s

5

Z c s

6

c St

1

ev -Wh t c

PAR90020_2010Catalog_22-41 34-35 11/23/09 9:39:51 AM

Exhibit D - Page 47

Get a Quote


54/65

paraide.com 1-888-893-2433e b S -p t Fl gs

Case 3:14-cv-02711-JAH-JM A Document 1-5 Fi led 11/14/14 Page 7 of 7

Get a Quote


55/65


OUR DETAILS ADD UP TO A BETTER EMBROIDERED FLAG

Turn to Par Aide when high quality and exceptional service are what you demand for embroidered flags. Our premium line ofembroidered flags is constructed using 400 denier material with reinforced stitching. The 400 denier material is more durableand is less likely to pucker when embroidered upon. Par Aide continues to recommend a lighter 200 denier material forregular golf flags, but recognizes a heavier 400 denier material provides the highest quality and satisfaction whenembroidery is preferred.

1. Unique reverse bobbined stitching on all flags reverses embroidery detail on back side of flag. No additional charge.

2. Fastest turnaround time in the industry. 23 weeks from receipt of approved order.

3. Constructed with premium 400 denier flag material rather than 200 denier.

4. Thread is made of colorfast material, specifically designed for outdoor use.

5. Flags are made of protected nylon for maximum fade resistance.

6. Available in convenient tube-style or tie-style (with grommets).

CUSTOM SCREEN-PRINTED FLAGS

Tube-style and tie-style flags available with a custom look for your course. Jr. Flags also available in tube -style only.

LETS TALK ABOUT YOUR ARTWORK BEFORE WE GET STARTED

Good artwork is essential to get the process started. To accurately price your logo for embroidered or screen-printed custom flags,you need to provide us with an example of your logo. A high-resolution vector-based or 800 dpi artwork would be the best exampleof your logo. Low-resolution artwork, such as a scorecard or letterhead, can be used but may require an additional art charge.

ORDERING PROCESS: HIGH QUALITY IS ALWAYS IN STOCK

From start to finish, our step-by-step process makes it easy and convenient for you.1. Acquire artwork. You need the correct artwork of your logo before we can start.

2. Select flag. Determine flag style, colors and quantity. Twelve-flag minimum for embroidery. Nine-flag minimum for screen printing.

3. Contact Par Aide dealer. Work with your local Par Aide dealer to facilitate a price quotation.

4. Approve quote. Once a purchase order is received, a sample flag or JPEG file will be sent for logo approval when needed/requested. Contact your Par Aide dealer directly if any changes need to be made.

5. Experience the fastest turnaround. Once we have final logo approval, please allow 23 weeks for delivery.

SEE FINE DETAIL ON BOTH SIDES OF THE FLAG WITH OUR UNIQUE PROCESS

Unbelievable precision and quality. We took flag embroidery to the next level by utilizing the exclusive reverse bobbined stitchingtechnique. The reverse bobbined technique embroiders your logo in reverse on the back side of the flag. This gives you extraordinarydetail on both sides of the flag, eliminating the unattractive white thread that is commonly found. All of our embroidered flags featurethis technique. This is just another example of how Par Aide takes its passion to improve existing products for the game of golf.

Black Hunter Green

Navy Blue

Red White Royal Blue Gold

*All flags have border and header options available. Call for details.

Emerald GreenYellow Orange Burgundy Border / Header

Flag Colors

Unique Reverse Bobbined Stitching

Front Back Note: All embroidered and screen-printed flags are custom and require a quote f or exact pricing.

PAR90020_2010Catalog_22-41 38-39 11/23/09 9:41:11 AM

Exhibit D - Page 49

Get a Quote


56/65


57/65


58/65


59/65


60/65



61/65

Exhibit F - Page53



62/65

Exhibit G



63/65

Exhibit G - Page 54



64/65

Exhibit H



65/65

Exhibit H - Page 55

prestige flag v. par aide - complaint

Documents