IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS

ROGER YOUNG Plaintiff,

v.

No. _ _ _ _ __

ANNE STONE, INC. Defendant.

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Roger Young files this complaint for patent infringement against Defendant Anne Stone, Inc. ("Anne Stone") and states as follows: THE PARTIES
I.

Roger Young is an individual domiciled in the State of California with his place

of residence at 9460 Upper Valley Rd., Auburn, CA 95602. 2. Upon information and belief, Defendant Anne Stone is a corporation organized

under the laws of the State of California with its principal place of business at 468 N. Camden Dr., 2nd Floor, Beverly Hills, California. 3. Anne Stone is in the business, inter alia, of selling golf putting equipment,

including putting practice targets, and has sold and provided golf putting practice targets throughout the United States and, on information and belief, in this District. Specifically, Anne Stone sells the Putt-A-RoundTM practice target, which is a circular putting target that allows a

user to practice putting from any direction. JURISDICTION AND VENUE 4. This is an action for patent infringement arising under the patent laws of the

United States, Title 35 of the United States Code. Jurisdiction as to these claims is conferred on this Court by 35 U.S.C. 1331 and 1338(a). 5. This Court has personal jurisdiction over Defendant because Defendant advertises

its products in this District. Specifically, Defendant advertises its Putt-A- RoundTM practice target through SkyMall Magazine, which is made available on flights to and from this District operated by, among others, United Airlines and American Airlines. Copies of excerpts from SkyMall Magazine for Late Spring 2013 for United Airlines and American Airlines are attached as Exhibits Band C, respectively. 6. On information and belief, Defendant Anne Stone purchased advertising in

SkyMall Magazine with the knowledge and intent that the advetiising would reach consumers in this District and with the intent to sell its Putt-A-RoundTM product in this District. 7. Venue is proper in this district under 28 U.S.C. 1391(b) and 1400(b). COUNT I - INFRINGEMENT OF U.S. PATENT D442,661 8. 9. Roger Young incorporates by reference paragraphs 1-7 as fully set forth herein. On May 22, 2001, United States Patent No. D442,661 ("the '661 patent") entitled

"Golf Putting Practice Hole Simulator" was duly and legally issued by the United States Patent and Trademark Office. Roger Young is the owner of all right, title, and interest in and to the '661 patent, with full right to bring suit to enforce the patent, including the right to recover for past infringement damages. A copy of the '661 patent is attached hereto as Exhibit A. 10. Anne Stone has known of the '661 patent since at least as early as May 29, 2013,

when counsel for Roger Young mailed a letter notifying Anne Stone of the' 661 patent. Ii. Anne Stone has directly infringed and continues to infringe the '661 patent under

35 U.S.C. 271(a) by making, using, selling, or offering for sale in the United States at least its Putt-A-Round product. 12. The design of Defendant Anne Stone's Putt-A-Round product is substantially

identical to the design claimed by Roger Young in the '661 patent. At the very least, the design of the Putt-A-Round product is no more than a colorable imitation of the design of the '661 patent. The following table illustrates this striking similarity in design:

661 Patent Design

Putt-A-RoundTM Design

13.

Anne Stone has at no time been either expressly or impliedly licensed under the

661 patent. 14. to be willful. PRAYER FOR RELIEF Rogel' Young requests judgment that: A. B. Defendant Anne Stone has inti'inged Rogel' Young's '661 patent; Rogel' Young be awarded a disgorgement of Defendant's total profits under 35 On information and belief, AIUle Stone's infi'ingement has been and will continue

U.S.C. 289 or, at a minimum, a reasonable royalty under 35 U.S.C. 284; C. Rogel' Young be awarded enhanced damages and counsel fees for willful

infringement as permitted under the law; D. Defendant Anne Stone, its agents, employees, representatives, successors, and
01'

assigns, and those acting in privity

in concert with any or all of them, be enjoined from further

infringement of Roger Young's '661 patent.

E.

Roger Young be awarded such further and additional relief as the Court deems

just and proper. Dated: July 9, 2013 Respectfully submitted,

By:

~i?:,

GOLDMAN ISMAIL TOMASELLI BRENNAN

& BAUM LLP - .

564 West Randolph Street, Suite 400 Chicago, IL 60661 Tel: (312) 681-6000 Fax: (312) 881-5191 Alan Littmann IL Bar No. 6283389 a lit tmann@goldmanismail.com

Counsel/or Rogel' Young