Prestige Flag Mfg. v. Golf Solutions I - Complaint

Case 3:17-cv-02543-LAB-KSC Document 1 Filed 12/19/17 PageID.
1 Page 1 of 16
1 SHEPPARD MULLIN RICHTER & HAMPTON LLP

A Limited Liability Partnership
2 Including Professional Corporations
3 DANIEL N. YANNUZZI (Cal Bar No. 196612)
dyannuzzi@sheppardmullin.com
4 Sheppard Mullin Richter & Hampton LLP
12275 El Camino Real, Suite 200
5 San Diego, California 92130
Telephone: (858) 720-8900
6 Facsimile: (858) 509-3691
7 Attorney for Plaintiff
PRESTIGE FLAG MFG. CO., INC.
8
9
10 IN THE UNITED STATES DISTRICT COURT
11 FOR THE SOUTHERN DISTRICT OF CALIFORNIA
12
13 PRESTIGE FLAG MFG. CO., INC., Case No. '17CV2543 LAB KSC
a California corporation,
14 COMPLAINT FOR:
Plaintiff,
15 (1) PATENT INFRINGEMENT;
v.
16 (2) UNFAIR COMPETITION UNDER
GOLF SOLUTIONS I, L.L.C., 15 U.S.C. § 1125(a); AND
17 a Wisconsin limited liability company
d/b/a Laser Link Golf, and (3) COMMON LAW UNFAIR
18 COMPETITION;
DOES 1–10, inclusive,
19 DEMAND FOR JURY TRIAL
Defendants.
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Case 3:17-cv-02543-LAB-KSC Document 1 Filed 12/19/17 PageID.2 Page 2 of 16
1 Plaintiff Prestige Flag Mfg. Co., Inc. (“Prestige”) complains and alleges as
2 follows against Defendant Golf Solutions I, L.L.C. (“Golf Solutions”).
3 THE PARTIES
4 1. Plaintiff is a California corporation, having a principal place of
5 business at 591 Camino De La Reina # 917, San Diego, California 92108.
6 2. On information and belief, Defendant Golf Solutions is a Wisconsin
7 limited liability company, having a principal place of business at 4027 Owl Creek
8 Drive, Madison, Wisconsin, 53718.
9 3. The true names, identities and capacities, whether individual, associate,
10 corporate or otherwise, of Defendants DOES 1 to 10, inclusive, and each of them
11 (“the DOE Defendants”), are unknown to Prestige at this time, who therefore sues
12 the DOE Defendants by such fictitious names. When the true names and capacities
13 or participation of the DOE Defendants are ascertained, Prestige will amend this
14 complaint to assert the true names, identities and capacities. Prestige is informed
15 and believes and thereon alleges that each of the DOE Defendants sued herein is
16 responsible for the wrongful acts alleged herein, and is therefore liable to Prestige in
17 some manner for the events and happenings alleged in this complaint. Prestige is
18 informed and believes and thereon alleges that at all times herein mentioned, the
19 DOE Defendants were and are doing business and/or residing in this District.
20 NATURE OF THE ACTION
21 4. This is a civil action against Defendants for infringement of United
22 States Patent Number 7,215,412 (“the ’412 Patent”), and United States Design
23 Patent Numbers D564,405 (“the ’D405 Patent”), and D546,243 (“the ’D243 Patent)
24 (collectively, “the Asserted Patents”) arising under the patent laws of the United
25 States, Title 35 of the United States Code; for unfair competition in violation of the
26 Lanham Act arising under 15 U.S.C. §§ 1125 et. seq.; and for unfair competition
27 arising under the common law of the State of California.
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SMRH:485023211.1
1 JURISDICTION AND VENUE

2 5. This Court has original subject matter jurisdiction of this action under
3 15 U.S.C. § 1121(a) (federal question), 28 U.S.C. § 1331 (federal question), and 28
4 U.S.C. § 1338(a) and (b) (any Act of Congress relating to patents and trademarks
5 and related unfair competition), and under the supplemental jurisdiction of this
6 Court, as embodied in 28 U.S.C. § 1367(a).
7 6. This Court has specific and general personal jurisdiction over
8 Defendants pursuant to due process and/or the California Long Arm Statute because
9 Defendants have committed and continue to commit acts of infringement in
10 violation of 35 U.S.C. §§ 271(a), (b), and (c), and place infringing products into the
11 stream of commerce, with the knowledge or understanding that such products are
12 sold in the State of California, including in this judicial district. Moreover,
13 Defendants’ acts, including both unfair competition and other violations of
14 California law, caused and are causing injury to Prestige within this judicial district.
15 On information and belief, Defendants have begun and will continue to derive
16 substantial revenue from the sale of infringing products within this judicial district,
17 expect their actions to have consequences within this judicial district, and derive
18 substantial revenue from interstate and international commerce, including within
19 this judicial district.
20 7. Venue is proper within this judicial district under 28 U.S.C. § 1391(b)
21 because a substantial portion of the events giving rise to the claims for relief stated
22 in this Complaint arose in this judicial district. Specifically, Defendants have sold
23 or offered for sale infringing products in this district, and have committed other acts
24 complained of infra within this district. In addition, venue is proper because
25 Prestige’s principal place of business is in this district and Prestige suffered and is
26 suffering harm in this district.
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1 BACKGROUND FACTS
2 8. Plaintiff Prestige is a San Diego-based company that designs and
3 manufactures flags, banners, golf course flags, flagsticks, and golf course
4 accessories, including a line of reflection rangefinder products for gauging distance.
5 Customers use Prestige’s high quality products in many places throughout the
6 world, including the United States, Canada, Mexico, Europe, and Asia.
7 9. On October 25, 2013, Prestige duly acquired a golf stick and reflector
8 business from Golf Solutions I, L.L.C. d/b/a Laser Link Golf (“the Laser Link
9 Business”) pursuant to an asset purchase agreement between the two companies and
10 in exchange for substantial consideration. Further, pursuant to this asset purchase
11 agreement, Prestige acquired the intellectual property, goodwill, and physical assets
12 related to the Laser Link Business.
13 10. The acquired Laser Link Business includes reflection products such as
14 flagstick reflectors, sold under the name Smarty (flagstick screw-on reflectors). The
15 Smarty 5 Reflector screws into the top of a golf flagstick, and contains five prisms
16 that reflect laser light. Coupled with a rangefinder, a device that sends laser light
17 toward the flagstick and receives laser light reflected back from reflectors in the
18 Smarty 5 Reflector atop the flagstick, the Smarty 5 Reflector enables a golfer to
19 accurately determine the distance between the golfer and the flagstick.
20 11. In connection with its acquisition of the Laser Link Business and the
21 associated intellectual property and goodwill, Prestige acquired and owns all right,
22 title, and interest in the asserted design patents: (1) the ’412 Patent, titled “Flagpole
23 Reflectors for Laser Range Finders,” a copy of which is attached as Exhibit A (2)
24 the ’D405 Patent, titled “Flagpole Reflector,” a copy of which is attached as Exhibit
25 B; and (3) the ’D243 Patent, titled “Flag Stick Reflector,” a copy of which is
26 attached as Exhibit C. The functionality and designs claimed in the Asserted
27 Patents are embodied in Prestige’s Smarty 5 Reflector and/or in Prestige’s products.
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1 12. Since acquiring the Laser Link Business, Prestige has continuously
2 offered for sale its Smarty products in interstate commerce, and has vigorously
3 protected its intellectual property, including the innovative functionality and
4 distinctive designs of Prestige’s Smarty that are protected through the above-
5 mentioned patents issued by the United States Patent and Trademark Office and
6 duly assigned to Prestige. Prestige’s patents cover the functional and distinctive
7 ornamental features of the Smarty 5 Reflector products, including, for example, their
8 overall utility, appearance, shape, and the location and distribution of prisms
9 throughout the device. Prestige is informed and believes that customers in the
10 marketplace have come to associate these distinctive features and overall appearance
11 with Prestige’s high quality products, including its Smarty products.
12 13. On November 20, 2014, Prestige filed a complaint against Defendants
13 Golf Solutions and Robert F. O’Loughlin alleging Breach of Contract in connection
14 with Prestige’s acquisition of the Laser Link Business. On December 12, 2014,
15 Prestige filed an amended complaint further alleging Negligent Misrepresentation
16 and Fraudulent Misrepresentation in addition to Breach of Contract on the part of
17 Defendants Golf Solutions and Robert F. O’Loughlin. On May 6, 2015, Prestige
18 and Defendants Golf Solutions and Robert F. O’Loughlin came to a settlement
19 agreement in which Prestige agreed to release Defendants Golf Solutions and Robert
20 F. O’Loughlin from the noncompetition agreement set forth in the asset purchase
21 agreement as of October 26, 2017. However, the settlement agreement also set forth
22 that the assignment of patents (including the Asserted Patents) and trademarks
23 (Smarty) remain intact.
24 14. On information and belief, Defendant Golf Solutions is a worldwide
25 provider of a number of golf course accessories. On information and belief, Golf
26 Solutions’ products are on sale and in use throughout the United States, including in
27 the State of California. As of at least November 2017, Golf Solutions has begun
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1 offering for sale, a flagstick reflector product named the “BEACON” on its website.
2 A copy of the relevant portions of Golf Solutions website is attached as Exhibit D.
3 15. On information and belief, Golf Solutions’ BEACON reflector is
4 described in its advertising as a prism flagstick reflector that uses a five-prism
5 design that is used with laser rangefinders to measure distance. Specifically, Golf
6 Solutions’ BEACON reflector embodies the functionality of the flagpole reflectors
7 disclosed and claimed in the ’412 Patent. Indeed, Golf Solutions is the original
8 assignee of the ’412 Patent.
9 16. Claim 14 of the ’412 Patent is exemplary and reads as follows:
10 A device for reflecting laser light back to a laser range
11
finder, the device comprising:
a first lateral surface having a first exterior peripheral edge;
12
a second lateral surface having a second exterior
13 peripheral edge;
14 a rod surface extending from the first exterior peripheral
15 edge to the second exterior peripheral edge;
16 a plurality of sockets, the plurality of sockets formed in the

rod surface and arranged in a plurality of rows, wherein
17 two or more sockets are arranged in at least one row of the
18 plurality of rows; and
a light reflector mounted in each of the plurality of
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sockets, whereby a portion of laser light directed at the
20 device from a laser is reflected back to the laser by at least
one light reflector.
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22 17. On information and belief, the resemblance between Golf Solutions’
23 BEACON reflector and the Smarty 5 Reflector (and the designs claimed in the
24 Asserted Patents) is such as to deceive an ordinary observer, giving such attention as
25 a purchaser usually gives, including inducing the purchaser to purchase one
26 supposing it to be the other. Golf Solutions’ BEACON reflector has an overall
27 appearance that is substantially the same, in view of the prior art and in the eyes of
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1 an ordinary observer, as the Smarty 5 Reflector (and the designs claimed in the
2 Asserted Patents), as demonstrated by the side-by-side comparison below (Table 1).
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4 Table 1
5 Figure 8 Figure 4 BEACON
6 ’D243 ’D405
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20 18. However, since assigning the Asserted Patents to Prestige, Prestige has
21 not authorized Golf Solutions to practice the product claimed in the Asserted
22 Patents. Nor has Prestige authorized Golf Solutions to offer products confusingly
23 similar to Prestige’s Smarty products. Similarly, Prestige has never authorized Golf
24 Solutions to use Prestige’s duly held goodwill and intellectual property associated
25 with the Laser Link Business, including the distinctive trade dress customers have
26 come to recognize when seeking the Smarty Reflector.
27 19. On information and belief, Golf Solutions has used, imported into, sold,
28 or offered for sale in the United States its BEACON reflector, which infringes the
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1 Asserted Patents. Golf Solutions has not obtained permission from Prestige to use,
2 sell, offer, or import Prestige’s product or designs claimed in the Asserted Patents.
3 Golf Solutions had many options in developing its BEACON reflector.
4 Nevertheless, Golf Solutions chose to willingly infringe Prestige’s product and
5 designs claimed in the Asserted Patents by making, using, selling or offering for
6 sale, and/or importing its BEACON reflector during the terms of Prestige’s Asserted
7 Patents, knowing full well that its BEACON product is covered by the Asserted
8 Patents.
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10 FIRST CAUSE OF ACTION
11 Infringement of Design Patent ’D405
12 20. Prestige incorporates and realleges Paragraphs 1 through 19 of this
13 Complaint.
14 21. Under 35 U.S.C. § 271(a), Defendants have infringed and continue to
15 infringe, literally or under the doctrine of equivalents, the ’D405 Patent by making,
16 using, selling, and/or offering to sell in the United States, and/or importing into the
17 United States the BEACON product identified in this Complaint, which BEACON
18 embodies the design covered by the ’D405 Patent.
19 22. Moreover, Defendants have infringed and continue to infringe the
20 ’D405 Patent indirectly, under 35 U.S.C. §§ 271(b) and (c), by inducing others to
21 infringe the ’D405 Patent, and by committing acts that constitute contributory
22 infringement of the ’D405 Patent.
23 23. On information and belief, Defendants have gained profits and will
24 continue to gain profits following their release from the noncompetition clause by
25 virtue of their infringement of the ’D405 Patent.
26 24. On information and belief, Prestige has sustained damages and will
27 continue to sustain damages as a direct and proximate result of Defendants’
28 infringement of the ’D405 Patent following Defendants’ release from the
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1 noncompetition clause, and, as such, Prestige is entitled to damages pursuant to 35

2 U.S.C. §§ 284 and/or 289.
3 25. Moreover, Prestige is informed and believes that Defendants’
4 infringement of the ’D405 Patent is and has been willful. On information and belief,
5 Defendants have acted and continue to act with objective recklessness by
6 proceeding despite an objectively high likelihood that their actions constitute
7 infringement of Prestige’s valid patents, and Defendants are aware of Prestige’s
8 patents, including the ’D405 Patent, and know of the high likelihood that they cover
9 Defendants’ products. Indeed, Defendant assigned the Asserted Patents to Prestige
10 as part of the aforementioned asset purchase agreement.
11 26. This is an exceptional case warranting an award of treble damages to
12 Prestige under 35 U.S.C. § 284, and an award of attorneys’ fees under 35 U.S.C. §
13 285.
14 27. On information and belief, Prestige will suffer and is suffering
15 irreparable harm from Defendants’ infringement of the ’D405 Patent. Prestige has
16 no adequate remedy at law and is, under 35 U.S.C. § 283, entitled to an injunction
17 against Defendants’ continuing infringement of the ’D405 Patent. Unless enjoined,
18 Defendants will continue their infringing conduct.
19 SECOND CAUSE OF ACTION
20 Infringement of Design Patent ’D243
22 Complaint.
23 29. Under 35 U.S.C. § 271(a), Defendants have infringed and continue to
24 infringe, literally or under the doctrine of equivalents, the ’D243 Patent by making,
25 using, selling, and/or offering to sell in the United States, and/or importing into the
26 United States the BEACON product identified in this Complaint, which BEACON
27 product embodies the design covered by the ’D243 Patent.
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1 30. Moreover, Defendants have infringed and continue to infringe the

2 ’D243 Patent indirectly, under 35 U.S.C. §§ 271(b) and (c), by inducing others to
3 infringe the ’D243 Patent, and by committing acts that constitute contributory
4 infringement of the ’D243 Patent.
5 31. On information and belief, Defendants have gained profits and will
6 continue to gain profits following their release from the noncompetition clause by
7 virtue of their infringement of the ’D243 Patent.
8 32. On information and belief, Prestige has sustained damages and will
9 continue to sustain damages as a direct and proximate result of Defendants’
10 infringement of the ’D243 Patent following Defendants’ release from the
11 noncompetition clause, and, as such, Prestige is entitled to damages pursuant to 35
12 U.S.C. §§ 284 and/or 289.
13 33. Moreover, Prestige is informed and believes that Defendants’
14 infringement of the ’D243 Patent is and has been willful. On information and belief,
15 Defendants have acted and continue to act with objective recklessness by
16 proceeding despite an objectively high likelihood that their actions constitute
17 infringement of Prestige’s valid patents, and Defendants are aware of these patents,
18 including the ’D243 Patent, and know of the high likelihood that they cover
19 Defendants’ products. Again, Defendant assigned the Asserted Patents to Prestige
20 as part of the aforementioned asset purchase agreement.
21 34. This is an exceptional case warranting an award of treble damages to
22 Prestige under 35 U.S.C. § 284, and an award of attorneys’ fees under 35 U.S.C. §
23 285.
24 35. On information and belief, Prestige will suffer and is suffering
25 irreparable harm from Defendants’ infringement of the ’D243 Patent. Prestige has
26 no adequate remedy at law and is, under 35 U.S.C. § 283, entitled to an injunction
27 against Defendants’ continuing infringement of the ’D243 Patent. Unless enjoined,
28 Defendants will continue their infringing conduct.
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SMRH:485023211.1
1 THIRD CAUSE OF ACTION

2 Infringement of the ’412 Patent
4 Complaint.
5 37. Under 35 U.S.C. § 271(a), Golf Solutions has infringed and continues
6 to infringe, literally or under the doctrine of equivalents, the ’412 Patent by without
7 authority making, using, offering to sell or selling within the United States, or
8 importing into the United States, during the term of the ’412 Patent the flagpole
9 reflector products identified in this Complaint, which are covered by the claims of
10 the ’412 Patent.
11 38. Under 35 U.S.C. § 271(b), Golf Solutions has actively induced, and is
12 actively inducing, infringement of the ’412 Patent by promoting, offering and
13 selling the BEACON reflector that Golf Solutions knows, when used, will infringe
14 the ’412 Patent.
15 39. Under 35 U.S.C. § 271(c), Golf Solutions has contributed to, and is
16 contributing to, infringement of the ’412 Patent by offering to sell or selling within
17 the United States, or importing into the United States, the BEACON products
18 constituting a material part of the invention, knowing the same to be especially
19 made or especially adapted for use in an infringement of the ’412 patent, and not a
20 staple article or commodity of commerce suitable for substantial noninfringing use.
21 FOURTH CAUSE OF ACTION
22 Unfair Competition Under 15 U.S.C. § 1125(a)
24 Complaint.
25 41. The acts of Golf Solutions complained of above are likely to cause
26 confusion, or to cause mistake, or to deceive as to the affiliation, connection, or
27 association as to the origin, sponsorship, or approval of Golf Solutions’ and
28 Prestige’s goods. Moreover, the acts of Golf Solutions complained of above
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1 misrepresent the nature, characteristics, or qualities of Golf Solutions’ and Prestige’s

2 goods. These acts thus constitute false designation of origin and/or affiliation, false
3 or misleading description of fact, or false or misleading representation of fact, in
4 violation of 15 U.S.C. §1125(a).
5 42. Prestige is informed and believes that Golf Solutions’ acts include, for
6 example, offering Golf Solutions’ BEACON reflector for sale and piggybacking off
7 Prestige’s goodwill, by copying the distinctive features, designs and appearances of
8 Prestige’s Smarty products, all of which were assigned to and purchased by Prestige
9 via the asset purchase agreement which remains intact.
10 43. Prestige has suffered and will continue to damages from Golf
11 Solutions’ conduct in an amount to be proven at trial.
12 44. Golf Solutions has received and will continue to receive wrongful gains
13 from its conduct in an amount to be proven at trial.
14 45. Prestige is informed and believes, and thereon alleges that, unless
15 restrained by the Court, Golf Solutions will continue to designate falsely the origin
16 of its goods, causing irreparable damage to Prestige and engendering a multiplicity
17 of lawsuits. Pecuniary compensation will not afford Prestige adequate relief for its
18 resulting damages. Further, Prestige is informed and believes, and thereon alleges,
19 that in the absence of injunctive relief, customers are likely to continue being
20 mistaken or deceived as to the true source, origin, sponsorship, and affiliation of
21 Golf Solutions’ goods.
22 46. Prestige is informed and believes, and thereon alleges, that Golf
23 Solutions’ acts were committed, and continue to be committed, with actual notice of
24 Prestige’s exclusive rights and with intent to cause confusion, to cause mistake,
25 and/or to deceive, and to cause injury to the reputation and goodwill associated with
26 Prestige and its Smarty product. Pursuant to 15 U.S.C. §1117, Prestige is therefore
27 entitled to recover three times its actual damages or three times Golf Solutions’
28 profits, whichever is greater, together with Prestige’s attorneys' fees. In addition,
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1 pursuant to 15 U.S.C. §1118, Prestige is entitled to an order requiring destruction of

2 all infringing products and promotional materials in Golf Solutions’ possession.
3 FIFTH CAUSE OF ACTION
4 Common Law Unfair Competition
6 Complaint.
7 48. The acts of Golf Solutions complained of above constitute unfair
8 competition under the common law of the State of California. Prestige expended
9 significant amounts of money ($2,500,000.00), time, and resources in the goodwill
10 associated with its Smarty products. On information and belief, Golf Solutions
11 copied those products, including their distinctive designs, and is trading off that
12 goodwill at relatively little to no engineering or design expense and without
13 Prestige’s authorization. Prestige has suffered harm as a result—including, for
14 example, lost sales and customer confusion.
15 49. Prestige is informed and believes that further examples of Golf
16 Solutions’ acts of unfair competition include sales of confusingly similar Golf
17 Solutions products.
18 50. Prestige has suffered actual damages from Golf Solutions’ conduct in
19 an amount to be proven at trial.
20 51. Golf Solutions has received and will continue to receive wrongful gains
21 from its conduct in an amount to be proven at trial.
22 52. Golf Solutions’ acts complained of above were committed with fraud,
23 malice, and oppression as those terms are defined in Cal. Civ. Code § 3294. Golf
24 Solutions’ actions were intended to cause harm to Prestige, and Golf Solutions
25 carried on its conduct with a willful and conscious disregard for Prestige’s rights.
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1 PRAYER
2 WHEREFORE, Prestige prays:
3 (a) For a judgment that Defendants have infringed one or more
4 claims of Prestige’s Asserted Patents;
5 (b) For an order and judgment preliminarily and permanently
6 enjoining Defendants and their officers, directors, agents, servants, employees,
7 affiliates, attorneys, and all others acting in privity, active concert, or participation
8 with any of them, and their parents, subsidiaries, divisions, successors and assigns,
9 who receive actual notice of the judgment by personal service or otherwise, from
10 further acts of infringement of Prestige’s Asserted Patents;
11 (c) That Defendants be directed to file with this court, within thirty
12 days after entry of any injunction in this case, a written statement, under oath,
13 setting forth in detail the manner in which Defendants have complied with the
14 injunction;
15 (d) For a judgment awarding Prestige all damages, in an as yet
16 undetermined amount, adequate to compensate for Defendants’ infringement of
17 Prestige’s Asserted Patents, and in no event less than a reasonable royalty for
18 Defendants’ acts of infringement, including all pre-judgment and post-judgment
19 interest at the maximum rate permitted by law;
20 (e) For a judgment awarding Prestige all damages, including treble
21 damages, based on any infringement found to be willful, pursuant to 35 U.S.C. §
22 284, together with prejudgment interest;
23 (f) For a judgment that Defendants and their officers, agents,
24 distributors, employees, attorneys, subsidiaries, assigns, or related companies, and
25 those in active concert or participation with any of them, who receive actual notice
26 of the judgment by personal service or otherwise, be permanently enjoined from
27 using, offering for sale, or employing, directly or indirectly, any device, product, or
28 the like, that is confusingly similar to, or is likely to confuse or deceive as to the
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1 affiliation, connection, sponsorship, or association of, the Reflection Products or

2 commercial activities of Defendants with Plaintiff or the Reflection Products, or
3 with Plaintiff’s commercial activities;
4 (g) That an accounting be directed to determine Defendants’ profits
5 resulting from their false designation of origin and affiliation and unfair
6 competition, which are the subject of this suit, and that such profits be increased
7 under 15 U.S.C. §1117;
8 (h) That Prestige recover its damages, in an as yet undetermined
9 amount, resulting from the above-alleged false designation of origin and unfair
10 competition of Defendants;
11 (i) That Prestige be awarded punitive damages in an amount to be
12 determined;
13 (j) For costs of suit and reasonable attorneys’ fees; and
14 (k) For any other remedy to which Prestige may be entitled under
15 the law, and any other further relief as the Court may deem appropriate.
16 Respectfully submitted,
17 Dated: December 19, 2017
18 SHEPPARD, MULLIN, RICHTER
19 & HAMPTON LLP
20 By s/Daniel N. Yannuzzi
21 DANIEL N. YANNUZZI
Attorney for Plaintiff
22 PRESTIGE FLAG MFG. CO., INC.
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SMRH:485023211.1
1 DEMAND FOR JURY TRIAL

2 Prestige requests a trial by jury on all issues so triable in this action.
3 Respectfully submitted,
4
5 Dated: December 19, 2017
6 SHEPPARD, MULLIN, RICHTER
7
& HAMPTON LLP
8 By s/Daniel N. Yannuzzi
9 DANIEL N. YANNUZZI
Attorney for Plaintiff
10 PRESTIGE FLAG MFG. CO., INC.
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Case 3:17-cv-02543-LAB-KSC Document 1-1 Filed 12/19/17 PageID.17 Page 1 of 1
JS 44 (Rev. 06/ l 7) CIVIL COVER SHEET
The JS 44 c ivil cover sheet and the infom1ation contaiued herein neither replace nor supple m ent the filing a nd service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, app roved by the Judicial Confereuce of the United States in Septemb er 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket s heet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FOR,W.j
~~fts~bIBI~~G. CO., INC. a California corporation c£{fl§~t#)1J~s I, L.L.C., a Wisconsin limited liability company
d/b/a Laser Link Golf, and DOES 1-10, inclusive
(b) County of Residence of Firs t Lis ted Plainti ff San Diego, California County of Res idence of F irst l isted Defendant Dane County, Wisconsin
(EXCEPT lN U.S PLAINTTFF CASES) {TN U.S. PLAJNTIFF CASES ONLY)
NOTE: TN LAND CONDEMNATION CASES. USE THE LOCATION OF
TiiE TRACT OF LAND INVOLVED.
(C) Attorneys (Firm Name, Address, and Telephone N111nbe1) A llo meys (//Known)
Daniel Yannuzzi, SBN 196612
SHEPPARD MULLIN RICHTER & HAMPTON LLP
12275 El Camino Real, Suite 200, San Diego, CA 92130 '17CV2543 LAB KSC
II. BASIS OF JURISDICTION (Placean "X " inOneBoxOnfy) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box/or Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
0 l U.S. Government ~3 Federn I Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State IX l 0 Incorporated or Principal Place 0 4 0 4
of Business In This State
0 2 U.S. Government 0 4 Diversity Citizen of Another State 0 2 0 2 Incorporated and Principal Place o 5 IX 5
Defendant {Indicate Citizenship ofParties in Item Ill) of Business In Another State
Citizen or Subjec1of a 0 3 0 3 Foreign Naiion 06 06

Forei~1 Country
JV NATURE OF SUIT (Place an "X" in 0 ne Box 0 11)1

I~ c1·IC klie re o r: N arure o rstllt c o de D escnnllon s.
I CONTRACT TORTS .F ORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES l
0 110 Insurance PERSONAL lNJURY PERSONAL lNJURY 0 625 Drug Related Seizure 0 422 Appeal 28 USC 158 0 375 False Claims Act
0 120Marine 0 3 l 0 Airplane 0 365 Personal Injury - of Property 2 1 USC 881 0 423 Withdrnwal 0 376 Qui Tam (31 USC
0 130 Miller Act 0 315 Airplane Producl Product Liability 0 690 Other 28 USC 157 3729(a))
0 l 40 Negotiable Instrument Liability 0 367 Health Carel 0 400 State Reapportiolllllent
0 ISO Recovery of Overpa}o11ent 0 320 Assauh, Libel & l>h~1rma.ceutic.al PDQPl<;RTV RlGH I s 0 410 Antiirust
& Enforcement of Jud.gment Slander Personal Injury D 820 Copyrights D 430 Banks and Banking
0 l S I Medicare Act 0 330 Federal Employers' Product Liability ~ 830 Patent 0 450 Commerce
0 I 52 Recovery of Oefauhed Liability 0 368 Asbesios Personal 0 835 Patent - Abbreviated 0 460 Deportation
Studeut Loans D 340Marine lnjury Product New Drug Application D 470 Racketeer Intluenced and
(Excludes Veterans) 0 345 Marine Prnduct Liability 0 840 Trademark Com1pl Organizations
0 l 53 Recovery of Overpavmenr Liability PERSO NAL PROPERTY l ,A BOR SOC IAL SEC! ;" y 0 480 Consumer Credit
of Veteran's Benefits 0 350 Motor Vehicle 0 370 0 1her Fraud 0 710 Fair Labor Standards 0 861 HIA (l395fl) 0 490 Cable/Sat TV
0 160 Stockholders' Suits 0 355 Motor Vehicle D 371 Truth in Lending Act 0 862 Black Lung (923) 0 850 Securities/ Commodities/
0 190 Other Contract Producl Liability 0 380 Other Personal 0 720 Labor/Managemem 0 863 DlWC/DIWW (405(g)) Exchange
0 I 95 Contract Product Liability 0 360 Other PetrSOnal Propeny Damage Relations 0 864 SSID Title XVI 0 890 Other Statutory Actions
0 196 Franchise Injury 0 385 Property Damage 0 740 Railway Labor Act 0 865 RSI (405(g)) 0 89 1 Agricultural Acts
D 362 Personal Injury - Product Liability D 751 Family and Medical 0 893 Environmental Matters
Medical Malpractice Leave Acl 0 895 Freedom oflnformaiion
I REAL PROPERTY CIVIL RJG DTS PRISONER PETITIONS 0 790 Other Labor Litigation :FEDERAL TAX SlITTS Act
0 2 10 Land Condemnation 0 440 Other Civil Rights Habeas Corpus: 0 791 Employee Retirement 0 870 Taxes (U.S. Plaintiff 0 896 Arbitration
0 220 Foreclosure 0 441 Voting 0 463 Alien Detainee Income Security Act or Defendant) 0 899 Administrative Procedure
0 230 Rent Le-.1sc & Ejectment 0 442 Employmeul 0 510 Motions lo Vacate 0 871 LRS-Third Party Act/Review or Appeal of
0 240 Torts to Land 0 443 Housing/ Semenec 26 USC 7609 Agency Decision
0 245 Ton Product Liability Accommodations 0 530 Geneml 0 950 Constitutionality of
0 290 All Other Real Property 0 445 Amer. wfDisabilities - 0 535 Oc.ath Penally lMMIGRATION State Staiutes
Emplo)1nent Other: 0 462 Naturnlization Application
0 446 Amer. w!Disobilities - 0 540 Mandamus & Other 0 465 Other lmJlligration
Other 0 550 Civil Rights Actions
D 448 Education D 555 Prison Condition
D 560 Civil Detainee -
Condi1ions of
Confinement
V, ORIGIN (Place an "X"'in011eBox011/y)
J8: .1 O rig inal 0 2 Removed from 0 3 Rema nded from 0 4 Reinstated o~ 0 5 Transferred from 0 6 Multidistrict 0 8 M u ltidis trict
Proceeding State Court Appellate Court Reopened A n other D istrict Litigation - Litigation -
(specifo) Tnmsfer Direct File
C ite the U.S . Civil Statute under which you are filing (Do 1101 cirej11risdictio11al s1a111res "nless dfrersiry) :
15 U.S.C. Section 1125 a
VI. CAUSE OF ACTION t-8-'-n"'"
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VII. REQUESTED IN 0 CHECK IF THIS IS A C LASS ACTION DEMAND $ CHECK Y ES only if demanded in complaint:
C OMPLAINT: UNDER RULE 23 , F .R.Cv.P. .rDRY DEMAND: ~ Yes ONo
Vlll. RELATED CASE(S)

(See instructions):
IF ANY JUDGE
DATE SIGNATURE OF ATIORNEY OF RECORD
12/21/2017 Isl Daniel Yannuzzi
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Exhibit A
Illlll llllllll Ill lllll lllll lllll lllll lllll 111111111111111111111111111111111
US007215412B2
c12) United States Patent (10) Patent No.: US 7,215,412 B2

O'Loughlin et al. (45) Date of Patent: May 8, 2007
(54) FLAGPOLE REFLECTORS FOR LASER 6,062,985 A 512000 Rege

RANGE FINDERS 6,185,055 Bl* 2/2001 Feist .......................... 359/831
6,266,628 Bl * 7/2001 Huep et al. ................. 702/150
(75) Inventors: Robert F. O'Loughlin, Madison, WI 6,346,055 Bl 212002 Rege
D465,174 S 1112002 Ursprung
(US); Michael D. Plitman,
2004/0223139 Al* 11/2004 Vogel ...................... 356/141.1
Minneapolis, MN (US); Daniel Steiner,
2005/0272515 Al 12/2005 Hurley et al.
Waunakee, WI (US); Wayne
Timberman, Carmel, IN (US)
OTHER PUBLICATIONS
(73) Assignee: Golf Solutions 1, L.L.C., Madison, WI Internet World Wide Web Page, http://www.laserlinkgolf.com/main.
(US) htm, printed Nov. 23, 2004.
Internet World Wide Web Page, http://www.
( *) Notice: Subject to any disclaimer, the term of this mosquitocreekoutdoors. corn/c gi -bin/So ftCart. exe/golf_gps.
patent is extended or adjusted under 35 htm?E+scstore, printed Aug. 4, 2004.
U.S.C. 154(b) by 258 days.
* cited by examiner
(21) Appl. No.: 10/931,947 Primary Examiner-Thomas H. Tarcza
Assistant Examiner-Luke D. Ratcliffe
(22) Filed: Sep. 1, 2004 (74) Attorney, Agent, or Firm-Foley & Lardner, LLP
(65) Prior Publication Data (57) ABSTRACT
US 2006/0044544 Al Mar. 2, 2006
A system and method are provided for determining a dis-
(51) Int. Cl. tance to a target. The method includes sending light, at a first
GOJC 3108 (2006.01) time, to a light reflector mounted in a reflector device,
(52) U.S. Cl. ................... 356/4.01; 356/4.02; 356/4.03; receiving light reflected from the light reflector at a second
356/5.01 time, and determining the distance to the reflector device
(58) Field of Classification Search ................ 356/4.01 using the difference between the first time and the second
See application file for complete search history. time. The reflector device has a first lateral surface, a second
lateral surface parallel to the first lateral surface, and a rod
(56) References Cited surface extending from the first lateral surface to the second
U.S. PATENT DOCUMENTS lateral surface. The reflector device includes sockets
arranged in the rod surface with a light reflector mounted in
2,362,131 A * 11/1944 Haggart, Jr................. 340/321 each socket. The sockets may be arranged in a plurality of
D242,775 s 12/1976 Williams, Jr. rows with possibly a plurality of sockets in each row. The
4,136,394 A 111979 Jones et al. reflector device may be mounted as an insert to or at the top
4,813,494 A * 3/1989 Beard et al ................... 173/91
of a target to determine the distance to the target.
5,723,840 A * 3/1998 Bojic et al. ................... 218/60
5,760,909 A * 6/1998 Nichols ..................... 356/4.08
5,841,392 A * 11/1998 Kishimoto .................. 342/125 24 Claims, 10 Drawing Sheets
72
56 76
52
60
94 82
102 62
80
98 66
~50
106
174
70
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US 7,215,412 B2
1 2
FLAGPOLE REFLECTORS FOR LASER Another exemplary embodiment of the invention relates
RANGE FINDERS to a device for reflecting laser light back to a laser range
finder. The device includes, but is not limited to, a pole and
FIELD OF THE INVENTION a reflector device. The reflector device mounts to the pole.
The reflector device includes, but is not limited to, a first
The present invention is related to systems for determin- lateral surface having a first exterior peripheral edge, a
ing a distance to an object. More specifically, the present second lateral surface having a second exterior peripheral
invention relates to a reflector placed at a desired location, edge, a rod surface extending from the first exterior periph-
and the use of laser light to calculate a distance from a laser eral edge to the second exterior peripheral edge, two to four
light source to the reflector location. 10
sockets, and a light reflector mounted in each of the two to
four sockets. The two to four sockets are formed in the rod
BACKGROUND OF THE INVENTION
surface and arranged in a plurality of rows. A portion of light
directed at the device from a laser is reflected back to the
Laser light can be used to measure the distance from the
laser by at least one light reflector.
laser light source to a target object. Powerful lasers can 15
measure distances of hundreds of millions of miles. Much Still another exemplary embodiment of the invention
less powerful lasers, however, are useful in measuring much relates to a system for determining a distance to a target. The
shorter distances. Short range lasers can measure distances system includes, but is not limited to, a laser range finder, a
up to 300 yards and are much smaller in size, relatively pole, and a reflector device. The laser range finder is
inexpensive, and less hazardous. To measure distance, a 20
configured to send light at a first time to the reflector device,
laser transmits several pulses of light toward an intended to receive a portion of the light reflected from the reflector
target. The light is reflected from the target and is received device at a second time, and to determine the distance from
by a receptor. A calculation is made to determine the the laser range finder to the reflector device using the first
distance to the target based on the elapsed travel time time and the second time. The reflector device mounts to the
between the transmission of the pulse of light and the 25
pole. The reflector device includes, but is not limited to, a
reception of the reflected pulse oflight. When the target does first lateral surface having a first exterior peripheral edge, a
not reflect sufficient laser light back to the receptor, errors in second lateral surface having a second exterior peripheral
the distance measurement may result or a complete failure to edge, a rod surface extending from the first exterior periph-
measure any distance to the target may result. Thus, there is eral edge to the second exterior peripheral edge, two to four
a need for an improved method and a system for accurately 30
sockets, and a light reflector mounted in each of the two to
and for reliably measuring the distance to a known target. four sockets. The two to four sockets are formed in the rod
Further, there is a need for an improved method and system surface and arranged in a plurality of rows. A portion of the
for measuring the distance to a known target that is simple light directed at the reflector device from the laser range
to use. finder is reflected back to the laser range finder by at least
35
one light reflector.
SUMMARY OF THE INVENTION An exemplary embodiment of the invention relates to a
method for determining a distance to a target. The method
An exemplary embodiment of the invention relates to a includes, but is not limited to, sending light at a first time
method for determining a distance to a target. The method from a device to a reflector device, receiving light reflected
includes, but is not limited to, sending light at a first time 40 from a light reflector at the device at a second time, and
from a device to a reflector device, receiving light reflected determining the distance from the device to the reflector
from a light reflector at the device at a second time, and device using the first time and the second time. The reflector
determining the distance from the device to the reflector device mounts to a pole. The reflector device includes, but
device using the first time and the second time. The reflector is not limited to, a first lateral surface having a first exterior
device mounts to a pole. The reflector device includes, but 45 peripheral edge, a second lateral surface having a second
is not limited to, a first lateral surface having a first exterior exterior peripheral edge, a rod surface extending from the
peripheral edge, a second lateral surface having a second first exterior peripheral edge to the second exterior periph-
exterior peripheral edge, a rod surface extending from the eral edge, a plurality of sockets, and the light reflector
first exterior peripheral edge to the second exterior periph- mounted in one of the plurality of sockets. The plurality of
eral edge, two to four sockets, and the light reflector 50 sockets are formed in the rod surface and arranged in a
mounted in one of the two to four sockets. The two to four plurality of rows. Two or more sockets are arranged in at
sockets are formed in the rod surface and arranged in a least one row of the plurality of rows. The light reflector
plurality of rows. The light reflector receives a portion of the receives a portion of the light and reflects the received
light and reflects the received portion of the light back to the portion of the light back to the device.
device. 55 An exemplary embodiment of the invention relates to a
An exemplary embodiment of the invention relates to a device for reflecting laser light back to a laser range finder.
device for reflecting laser light back to a laser range finder. The device includes, but is not limited to, a first lateral
The device includes, but is not limited to, a first lateral surface having a first exterior peripheral edge, a second
surface having a first exterior peripheral edge, a second lateral surface having a second exterior peripheral edge, a
lateral surface having a second exterior peripheral edge, a 60 rod surface extending from the first exterior peripheral edge
rod surface extending from the first exterior peripheral edge to the second exterior peripheral edge, a plurality of sockets,
to the second exterior peripheral edge, two to four sockets, and a light reflector mounted in each of the plurality of
and a light reflector mounted in each of the two to four sockets. The plurality of sockets are formed in the rod
sockets. The two to four sockets are formed in the rod surface and arranged in a plurality of rows. Two or more
surface and arranged in a plurality of rows. A portion of light 65 sockets are arranged in at least one row of the plurality of
directed at the device from a laser is reflected back to the rows. A portion of light directed at the device from a laser
laser by at least one light reflector. is reflected back to the laser by at least one light reflector.
Exhibit A - Page 12
US 7,215,412 B2
3 4
Another exemplary embodiment of the invention relates FIG. 9 is a side view of an example pole for mounting the
to a device for reflecting laser light back to a laser range first example reflector device of FIG. 5.
finder. The device includes, but is not limited to, a pole and FIG. 10 is a side view of a second example reflector
a reflector device. The reflector device mounts to the pole. device mounted to the example pole of FIG. 9.
The reflector device includes, but is not limited to, a first FIG. 11 is a first side view of the first example reflector
lateral surface having a first exterior peripheral edge, a device of FIG. 5.
second lateral surface having a second exterior peripheral FIG. 12 is a second side view of the first example reflector
edge, a rod surface extending from the first exterior periph- device of FIG. 11 with the first example device rotated
eral edge to the second exterior peripheral edge, a plurality approximately 90 degrees in a counter clockwise direction
of sockets, and a light reflector mounted in each of the 10 as viewed from the top of the first example reflector device
plurality of sockets. The plurality of sockets are formed in of FIG. 11.
the rod surface and arranged in a plurality of rows. Two or FIG. 13 is a third side view of the first example reflector
more sockets are arranged in at least one row of the plurality device of FIG. 11 with the first example device rotated
of rows. A portion oflight directed at the device from a laser approximately 180 degrees in a counter clockwise direction
is reflected back to the laser by at least one light reflector. 15 as viewed from the top of the first example reflector device
Still another exemplary embodiment of the invention of FIG. 11.
relates to a system for determining a distance to a target. The FIG. 14 is a fourth side view of the first example reflector
system includes, but is not limited to, a laser range finder, a device of FIG. 11 with the first example device rotated
pole, and a reflector device. The laser range finder is approximately 270 degrees in a counter clockwise direction
configured to send light at a first time to the reflector device, 20 as viewed from the top of the first example reflector device
to receive a portion of the light reflected from the reflector of FIG. 11.
device at a second time, and to determine the distance from FIG. 15 is a perspective view of the second example
the laser range finder to the reflector device using the first reflector device of FIG. 10 for mounting as an insert in a pole
time and the second time. The reflector device mounts to the as depicted in FIG. 1.
pole. The reflector device includes, but is not limited to, a 25 FIG. 16 is a bottom view of the insert of FIG. 15.
first lateral surface having a first exterior peripheral edge, a FIG. 17 is a top view of the insert of FIG. 15.
second lateral surface having a second exterior peripheral FIG. 18 is a perspective view of a third example reflector
edge, a rod surface extending from the first exterior periph- device.
eral edge to the second exterior peripheral edge, a plurality
FIG.19 is a side view of the third example reflector device
of sockets, and a light reflector mounted in each of the 30
of FIG. 18.
plurality of sockets. The plurality of sockets are formed in
FIG. 20 is a side view of the third example reflector device
the rod surface and arranged in a plurality of rows. Two or
of FIG. 19 with the third example reflector device rotated
more sockets are arranged in at least one row of the plurality
approximately 72 degrees in a clockwise direction as viewed
of rows. A portion of the light directed at the reflector device
from the top of the third example reflector device of FIG. 19.
from the laser range finder is reflected back to the laser range 35
finder by at least one light reflector.
Other principal features and advantages of the invention
approximately 144 degrees in a clockwise direction as
will become apparent to those skilled in the art upon review
viewed from the top of the third example reflector device of
of the following drawings, the detailed description, and the
FIG. 19 and mounted as an insert.
appended claims. 40
BRIEF DESCRIPTION OF THE DRAWINGS
viewed from the top of the third example reflector device of
The exemplary embodiments will hereafter be described
45
FIG. 19 and mounted as an insert.
with reference to the accompanying drawings, wherein like
numerals will denote like elements. The objects shown in the
figures may not be drawn to the same scale.
FIG. 1 is an overview diagram of a distance measuring viewed from the top of the third example reflector device of
system in accordance with an exemplary embodiment FIG. 19 and mounted as an insert.
including a first example reflector device. 50
FIG. 24 is a side view of a fourth example reflector device
FIG. 2 is a functional flow diagram of operations per- mounted as an insert.
formed in the distance measuring system of FIG. 1 in FIG. 25 is a side view of the fourth example reflector
accordance with an exemplary embodiment. device of FIG. 24 with the fourth example reflector device
FIG. 3 is a diagram illustrating the structure of an example rotated approximately 72 degrees in a clockwise direction as
55
reflector of the distance measuring system of FIG. 1. viewed from the top of the fourth example reflector device
FIG. 4 is a diagram illustrating a laser light reception and of FIG. 24 and mounted as an insert.
reflection path for the example reflector of the distance FIG. 26 is a side view of the fourth example reflector
measuring system of FIG. 3. device of FIG. 24 with the fourth example reflector device
FIG. 5 is a perspective view of a first example reflector 60 rotated approximately 144 degrees in a clockwise direction
device of the distance measuring system of FIG. 1. as viewed from the top of the fourth example reflector device
FIG. 6 is a top view of the first example reflector device of FIG. 24 and mounted as an insert.
of FIG. 5. FIG. 27 is a side view of the fourth example reflector
FIG. 7 is a bottom view of the first example reflector device of FIG. 24 with the fourth example reflector device
device of FIG. 5. 65 rotated approximately 216 degrees in a clockwise direction
FIG. 8 is a side view of the first example reflector device as viewed from the top of the fourth example reflector device
of FIG. 5. of FIG. 24 and mounted as an insert.
Exhibit A - Page 13
US 7,215,412 B2
5 6
FIG. 28 is a side view of the fourth example reflector The reflector device 56 may include, but is not limited to,
device of FIG. 24 with the fourth example reflector device a first socket 94, a second socket 96, a third socket 98, a
rotated approximately 288 degrees in a clockwise direction fourth socket 100 (not shown in FIG. 1), a first light reflector
as viewed from the top of the fourth example reflector device 102, a second light reflector 104, a third light reflector 106,
of FIG. 24 and mounted as an insert. and a fourth light reflector 108 (not shown in FIG. 1). The
first socket 94, the second socket 96, the third socket 98, and
DETAILED DESCRIPTION OF EXEMPLARY the fourth socket 100 have a size and shape sufficient to hold
EMBODIMENTS the first light reflector 102, the second light reflector 104, the
third light reflector 106, and the fourth light reflector 108,
10 respectively. The first light reflector 102 is mounted in the
With reference to FIG. 1, a distance measuring system 50 first socket 94. The second light reflector 104 is mounted in
that includes, but is not limited to, a handheld laser range the second socket 96. The third light reflector 106 is
finder 52, a pole 54, and a reflector device 56 is shown in an mounted in the third socket 98. The fourth light reflector 108
exemplary embodiment. The laser range finder 52 includes, is mounted in the fourth socket 100.
but is not limited to, an aiming light source 58, a laser light 15 With reference to the functional flow diagram of FIG. 2,
source 60, a laser light receptor 62, a measurement button the operations of the distance measuring system 50 are
64, and a handle 66. The aiming light source 58 transmits a described. Additional, fewer, or different operations may be
light, for example a red light, toward a current aiming point performed depending on the embodiment. A user aims the
so that the user can visually identify where the laser range laser range finder 52 at the reflector device 56 mounted in
finder 52 is currently aimed. The laser light source 60 20 the reflector pole 54 using the aiming light source 58. The
transmits laser light toward the current aiming point when user depresses the measurement button 64 to determine the
the measurement button 64 is depressed by the user. The distance from the laser range finder 52 to the reflector device
laser light may be transmitted in a series oflaser light pulses. 56. In response and at operation 110, the laser light source
The laser light source 60 may be a Class 1 laser as known 60 transmits pulses of laser light toward the reflector device
to those skilled in the art. A Class 1 laser is considered safe 25 56 at a first time. At least one of the light reflectors 102, 104,
based upon current medical knowledge. The laser light 106, 108 of the reflector device 56 receives the transmitted
receptor 62 receives laser light reflected back toward the laser light pulses. The light reflector receiving the transmit-
laser range finder 52 from the current aiming point. The ted laser light pulses reflects the laser light back toward the
handle 66 provides the user with a grasping point for the laser light receptor 62. The laser light receptor 62 receives
laser range finder 52 and provides access to the measure- 30 the reflected laser light from the light reflector at operation
ment button 64 while keeping the hands of the user away 112 at a second time. At operation 114, the laser range finder
from the laser light source 60 and the laser light receptor 62. 52 determines the distance from the laser range finder 52 to
The handle 66 may be held in the palm of the user's hand. the reflector device 56 based on the time difference between
In the exemplary embodiment of FIG. 1, the reflector pole the first time and the second time. The distance equals the
54 includes, but is not limited to, a first end 70, a second end 35 time difference between the first time and the second time
72, a first pole 74, a second pole 76, and an upright nut 78. divided by two and further multiplied by the speed of light.
The first end 70 provides a surface to support the reflector With reference to FIG. 3, a corner cube reflector 130 is
pole 54 upright, for example, in a flagpole stand placed at the shown. The comer cube reflector 130 is cut from a comer
bottom of a golf hole. The upright nut 78 may be placed near 132 of a cube of glass 134. The comer cube reflector 130 has
the first end 70 to provide additional support for the reflector 40 three mutually orthogonal reflecting faces 136, 138, 140 and
pole 54, for example, when the first end 70 of the reflector an entrance/exit face 142. With reference to FIG. 4, a ray of
pole 54 is placed in the golf hole. The second end 72 is light 144 entering the entrance/exit face 142 undergoes three
opposite the first end 70. The first pole 74 extends from the internal reflections, one reflection from each of the three
first end 70 to a first mounting end 80. The second pole 76 mutually orthogonal reflecting faces 136, 138, 140. After the
extends from a second mounting end 82 to the second end 45 third reflection, a ray oflight 146 exits the entrance/exit face
72. 142 in the opposite direction of the original incoming ray of
In the exemplary embodiment of FIG. 1, the reflector light 144.
device 56 is mounted to the reflector pole 54 between the The retro-reflective behavior of the corner cube reflector
first mounting end 80 of the first pole 74 and the second 130 is independent of the orientation angle between the
mounting end 82 of the second pole 76. As used in this 50 corner cube reflector and the ray of light incident on the
disclosure, the term "mount" includes join, unite, connect, entrance/exit face 142. The retro-reflective behavior
associate, insert, hang, hold, affix, attach, fasten, bind, paste, depends only on the accuracy of the squareness of the comer
secure, bolt, screw, rivet, solder, weld, and other like terms. 132. As known to those skilled in the art, comer cube
The reflector device 56 may be mounted in the reflector pole reflectors may also be known as a corner cube, a trihedral
54 as shown in FIG. 1 or may be mounted to the second end 55 retro-reflector, a trihedral prism, a corner cube prism, and/or
72 of the reflector pole 54 as described with reference to a comer cube retro-reflector. The light reflectors 102, 104,
FIG. 10. The reflector device 56 generally should be 106, 108 may be corner cube reflectors formed from glass or
mounted a sufficient distance above the first end 70 to allow other similarly reflective material. Use of the comer cube
a laser range finder 52 to aim at the reflector device 56 from reflector 130 for the light reflectors 102, 104, 106, 108
the desired distance without obstruction from the ground. 60 increases the amount of laser light that is reflected back
Additionally, the reflector device 56 should be mounted a toward the laser light receptor 62 by reducing the amount of
sufficient distance above or below any other obstructions laser light that would otherwise be scattered in directions
that may be attached to the reflector pole 54. For example, other than back toward the laser range finder 52. As a result,
the reflector pole 54 may have a flag attached near the the laser range finder provides a more accurate and reliable
second end 72. If so, the reflector device 56 should be 65 measurement of the distance.
mounted such that the flag will not cover the reflector device With reference to FIG. 5, a perspective view of the
56. reflector device 56 is shown. The reflector device 56 may
Exhibit A - Page 14
US 7,215,412 B2
7 8
further include, a first lateral surface 90, a rod surface 91, on the size of the light reflectors 102, 104, 106, 108. In an
and a second lateral surface 92 (not shown in FIG. 5). The exemplary embodiment, the diameter of the first lateral
first lateral surface 90 has a first exterior peripheral edge 93. surface 90 is approximately 0.625 inches, and the length of
The first exterior peripheral edge 93 defines a shape having the rod surface 91 is approximately 3.375 inches. The
a first center 108 shown in FIG. 6. The shape may be any 5 entrance/exit face 142 of the light reflectors 102, 104, 106,
shape including, but not limited to, circular, square, trian- 108, in an exemplary embodiment, may be 12 millimeters in
gular, rectangular, hexagonal, etc. The second lateral surface diameter.
92 has a second exterior peripheral edge 95. The second With reference to FIG. 8, a side view of the reflector
exterior peripheral edge 95 defines a shape having a second device 56 is shown. FIG. 9 depicts a side view of a reflector
center 109 shown in FIG. 7. The shape may be any shape 10 pole 160 in an alternative embodiment to the reflector pole
including, but not limited to, circular, square, triangular, 54. The reflector pole 160 includes, but is not limited to, a
rectangular, hexagonal, etc. The rod surface 91 extends from first pole 162, a first end 164, a second end 166, and a stem
the first exterior peripheral edge 93 to the second exterior 168. The first end 164 provides a surface to support the
peripheral edge 95. The first socket 94, the second socket 96, reflector pole 160 upright, for example, in a flagpole stand
the third socket 98, and the fourth socket 100 are formed in 15 placed at the bottom of a golf hole. The second end 166 is
the rod surface 91 and arranged in a plurality of rows. In the opposite the first end 164. The first pole 162 extends from
exemplary embodiment, sockets in a row have a common the first end 164 to the second end 166.
distance from the first center 108 to a center of the socket 94, The stem 168 extends from the second end 166 in a
96, 98, 100. Sockets in a row may also have a common generally perpendicular direction. The socket 150 of the
vertical distance from the first exterior peripheral edge 93 20 reflector device 56 may be mounted to the stem 168 of the
and/or from the second exterior peripheral edge 95. As a reflector pole 160. For example, FIG. 10 depicts a reflector
result, the reflectors 102, 104, 106, 108 are mounted in the device 182 mounted to the stem 168 of the reflector pole
reflector device 56 in a vertical stack and arranged to point 160. In an alternative embodiment, the stem 168 may have
in a direction rotated 90 degrees from an adjacent reflector a diameter that is greater than or equal to a diameter of the
thereby providing 360 degrees of coverage relative to a 25 second end 166. The surface of the stem 168 may be
center axis extending from the first center 108 to the second threaded. If the interior surface 151 of the socket 150 is
center 109. Thus, the laser light transmitted from the laser threaded, the surface of the stem 168 generally also is
range finder 52 reflects from at least one reflector 102, 104, threaded, and the thread of the stem 168 cooperates with the
106, 108 regardless of the pointing direction from the laser thread of the interior surface 151 of the socket 150. The stem
range finder 52 to the pole 54. Where a different number of 30 168 at the first end 166 of the reflector pole 160 may screw
light reflectors is used, the light reflectors may be separated into the socket 150 of the reflector device 56. If the interior
by a different number of degrees to provide the 360 degrees surface 151 of the socket 150 is not threaded, the reflector
of coverage. device 56 may slide onto the stem 168 at the first end 166
FIG. 6 shows a top view of the reflector device 56. FIG. of the reflector pole 160. In an alternative embodiment, the
7 shows a bottom view of the reflector device 56. In the 35 second lateral surface 92 may include a stem that extends
exemplary embodiment of FIG. 7, the second lateral surface from the second lateral surface 92. The second end 166 of
92 includes, but is not limited to, a mounting socket 150. The the reflector pole 160 may include a socket that accommo-
mounting socket 150 includes, but is not limited to, an dates the stem. The reflector device 56 may slide into the
interior surface 151 and a third lateral surface 152. The socket at the first end 166 of the reflector pole 160. The stem
interior surface 151 extends in a generally perpendicular 40 and the socket may be threaded. If the interior surface of the
direction from an interior peripheral edge 154 of the second socket is threaded, the reflector device may screw into the
lateral surface 92 to a peripheral edge 156 of the third lateral socket at the first end 166 of the reflector pole 160.
surface 152. The mounting socket 150 may vary in depth. In With reference to FIG. 10, the reflector device 182 may
an exemplary embodiment, the depth of the mounting socket include, but is not limited to, a first exterior peripheral edge
150 is approximately 0.875 inches. The interior surface 151 45 188, a second exterior peripheral edge 190, a rod surface
of the socket 150 may be threaded. The number of threads 191, a first socket 192, a second socket 194, a third socket
of the interior surface 151 may vary. In an exemplary 196, a fourth socket 198 (not shown in FIG. 10), a first light
embodiment, the number of threads is 24. In an alternative reflector 200, a second light reflector 202, a third light
embodiment, the number of threads is 16. reflector 204, and a fourth light reflector 206 (not shown in
The third lateral surface 152 extends from the interior 50 FIG. 10). The first socket 192, the second socket 194, the
surface 151 toward the second center 109. The third lateral third socket 196, and the fourth socket 198 have a size and
surface 152 may vary in size and shape. In an exemplary shape sufficient to hold the first light reflector 200, the
embodiment the third lateral surface 152 may be circular in second light reflector 202, the third light reflector 204, and
shape and have a diameter of approximately 0.375 inches. In the fourth light reflector 206, respectively. The first light
an alternative embodiment, the third lateral surface 152 may 55 reflector 200 is mounted in the first socket 192. The second
be conical to accommodate the second end 72 of the reflector light reflector 202 is mounted in the second socket 194. The
pole 54 as shown in FIG. 1. The interior surface 151 may third light reflector 204 is mounted in the third socket 196.
slope from the interior peripheral edge 154 of the second The fourth light reflector 206 is mounted in the fourth socket
lateral surface 92 to the peripheral edge 156 at an angle less 198. The reflector device 182 shows an alternative arrange-
than 90 degrees as measured relative to the second lateral 60 ment of the light reflectors.
surface 92 pointed toward the second center 109. FIGS. 11-14 show side views of the reflector device 56
The reflector device 56 may be formed of aluminum or successively rotated in 90 degree increments to show the
any other material capable of holding the light reflectors arrangement of the first socket 94, the second socket 96, the
102, 104, 106, 108. The reflector device 56 may be painted third socket 98, and the fourth socket 100 and the first light
various colors, for example, white, yellow, black, etc. The 65 reflector 102, the second light reflector 104, the third light
reflector device 56 may be coated in reflective material. The reflector 106, and the fourth light reflector 108 mounted in
dimensions of the reflector device 56 may be adjusted based the corresponding socket 94, 96, 98, 100 in an exemplary
Exhibit A - Page 15
US 7,215,412 B2
9 10
embodiment. FIG. 12 shows the reflector device 56 of FIG. 228, a rod surface 223, a second lateral surface 230, a first
11 rotated 90 degrees relative to a center axis extending from socket 232 (not shown in FIG. 18), a second socket 234, a
the first center 108 to the second center 109 in a counter third socket 236, a fourth socket 238 (not shown in FIG. 18),
clockwise direction as viewed from the first lateral surface a fifth socket 239 (not shown in FIG. 15), a first light
90. FIG. 13 shows the reflector device 56 of FIG. 12 rotated 5 reflector 240 (not shown in FIG. 18), a second light reflector
an additional 90 degrees in the same direction. FIG. 14 242, a third light reflector 244, a fourth light reflector 246
shows the reflector device 56 of FIG. 13 rotated an addi- (not shown in FIG. 18), and a fifth light reflector 247 (not
tional 90 degrees in the same direction. shown in FIG. 18).
In an alternative embodiment, a reflector insert 180 may The first lateral surface 228 has a first exterior peripheral
be used as an insert in a reflector pole 54 in the manner 10 edge 229. The first exterior peripheral edge 229 defines a
depicted in FIG. 1. With reference to FIG. 15, a perspective shape having a first center. The shape may be any shape
view of the reflector insert 180 is shown. The reflector insert including, but not limited to, circular, square, triangular,
180 may include, but is not limited to, the reflector device rectangular, hexagonal, etc. The second lateral surface 230
182, a first stem 184, and a second stem 186. The reflector has a second exterior peripheral edge 231. The second
device 182 may further include a first lateral surface 187 and 15 exterior peripheral edge 231 defines a shape having a second
a second lateral surface 189. center. The shape may be any shape including, but not
FIG. 16 shows a bottom view of the reflector insert 180. limited to, circular, square, triangular, rectangular, hexago-
The first stem 184 may include, but is not limited to, a first nal, etc. The rod surface 223 extends from the first exterior
lateral surface 210 and a first rod surface 212. The first rod peripheral edge 229 to the second exterior peripheral edge
surface 212 extends from the first lateral surface 187 of the 20 231.
reflector device 182 in a generally perpendicular direction. The first socket 232, the second socket 234, the third
The first lateral surface 210 extends from the first rod surface socket 236, the fourth socket 238, and the fifth socket 239
212 forming a closed stem that may be solid. In an alterna- have a size and shape sufficient to hold the first light reflector
tive embodiment, the first stem 184 may further include a 240, the second light reflector 242, the third light reflector
socket extending into the first lateral surface 210 thereby 25 244, the fourth light reflector 246, and the fifth light reflector
forming an open stem. 247, respectively. The first light reflector 240 is mounted in
FIG. 17 shows a top view of the reflector insert 180. The the first socket 232. The second light reflector 242 is
second stem 186 may include, but is not limited to, a second mounted in the second socket 234. The third light reflector
lateral surface 214 and a second rod surface 216. The second 244 is mounted in the third socket 236. The fourth light
rod surface 216 extends from the second lateral surface 189 30 reflector 246 is mounted in the fourth socket 238. The fifth
of the reflector device 182 in a generally perpendicular light reflector 247 is mounted in the fifth socket 239.
direction. The second lateral surface 214 extends from the The first socket 232, the second socket 234, the third
second rod surface 216 forming a closed stem that may be socket 236, the fourth socket 238, and the fifth socket 239
solid. In an alternative embodiment, the second stem 186 are formed in the rod surface 223 and arranged in a plurality
may further include a socket extending into the second 35 of rows. Sockets in a row have a common distance from the
lateral surface 214 thereby forming an open stem. first center to a center of the socket 232, 234, 236, 238, 239.
The reflector device 182 may be formed of aluminum or Sockets in a row may also have a common vertical distance
any other sufficiently rigid material. The reflector device 182 from the first exterior peripheral edge 229 and/or from the
may be painted various colors, for example, white, yellow, second exterior peripheral edge 231. A plurality of sockets
black, etc. The reflector device 182 may be coated in 40 may be arranged in a single row. For example, sockets 232
reflective material. The dimensions of the reflector device and 238 are shown mounted in a single row and sockets 234
182 may be adjusted based on the size of the light reflectors and 239 are shown mounted in a single row. The number of
200, 202, 204, 206. The light reflectors 200, 202, 204, 206 sockets mountable in a single row generally is constrained
may be comer cube reflectors. In an exemplary embodiment, by the width of the reflector device in a radial direction
the diameter of the first lateral surface 187 may be the same 45 parallel to the first lateral surface 230. The light reflectors
as the diameter of the second lateral surface 189 and may be 232, 234, 236, 238, 239 are arranged to point in a direction
approximately 0.625 inches. The diameter of the first lateral rotated 72 degrees from an adjacent reflector thereby pro-
surface 187 may be different from the diameter of the second viding 360 degrees of coverage relative to a center axis
lateral surface 189. In an exemplary embodiment, the length extending from the first center to the second center. Thus, the
of the reflector device 182 along the rod surface 191 is 50 laser light transmitted from the laser range finder 52 reflects
approximately 3.375 inches. The entrance/exit face 142 of from at least one reflector 232, 234, 236, 238, 239 regardless
the light reflectors 200, 202, 204, 206, in an exemplary of the pointing direction from the laser range finder 52 to the
embodiment, may be 12 millimeters in diameter. In an pole 54. Where a different number of light reflectors is used,
alternative embodiment, the diameter of the first lateral the light reflectors may be separated by a different number
surface 210 of the first stem 184 may be greater than or equal 55 of degrees to provide the 360 degrees of coverage.
to the diameter of the first lateral surface 187 of the reflector FIGS. 19-23 show side views of the reflector insert 220
device 182. In an alternative embodiment, the diameter of successively rotated in 72 degree increments to show the
the second lateral surface 214 of the second stem 186 may arrangement of the first socket 232, the second socket 234,
be greater than or equal to the diameter of the second lateral the third socket 236, the fourth socket 238, the fifth socket
surface 189 of the reflector device 182. 60 239, and thus, the arrangement of the first light reflector 240,
In another alternative embodiment, a reflector insert 220 the second light reflector 242, the third light reflector 244,
may be used as an insert in a reflector pole 54 in the manner the fourth light reflector 246, and the fifth light reflector 247
depicted in FIG. 1. With reference to FIG. 18, a perspective mounted in the corresponding sockets 232, 234, 236, 238,
view of the reflector insert 220 is shown. The reflector insert 239. Thus, FIG. 20 shows the reflector insert 220 of FIG. 19
220 may include, but is not limited to, a reflector device 222, 65 rotated 72 degrees about a center axis 248 in a clockwise
a first stem 224, and a second stem 226. The reflector device direction as viewed from the second lateral surface 230.
222 may include, but is not limited to, a first lateral surface FIG. 21 shows the reflector insert 220 of FIG. 20 rotated 72
Exhibit A - Page 16
US 7,215,412 B2
11 12
degrees in the same direction. FIG. 22 shows the reflector The reflector device 262 may be formed of aluminum or
insert 220 of FIG. 21 rotated 72 degrees in the same any other sufficiently rigid material. The reflector device 262
direction. FIG. 23 shows the reflector insert 220 of FIG. 22 may be painted various colors, for example, white, yellow,
rotated 72 degrees in the same direction. FIGS. 21, 22, and black, etc. The reflector device 262 may be coated in
23 depict the reflector insert 220 mounted in the reflector reflective material. The dimensions of the reflector device
pole 54. 262 may be adjusted based on the size of the light reflectors
The reflector device 222 may be formed of aluminum or 280, 282, 284, 286, 287. The light reflectors 280, 282, 284,
any other sufficiently rigid material. The reflector device 222 286, 287 may be comer cube reflectors. In an exemplary
may be painted various colors, for example, white, yellow, embodiment, the diameter of the first lateral surface 268 may
black, etc. The reflector device 222 may be coated in 10 be the same as the diameter of the second lateral surface 270
reflective material. The dimensions of the reflector device and may be approximately one inch. In an alternative
222 may be adjusted based on the size of the light reflectors embodiment, the diameter of the first lateral surface 268 may
240, 242, 244, 246, 247. The light reflectors 240, 242, 244, be different from the diameter of the second lateral surface
246, 247 may be comer cube reflectors. In an exemplary 270. In an exemplary embodiment, the length of the reflector
embodiment, the diameter of the first lateral surface 228 may 15 device 262 along the center axis is approximately two
be the same as the diameter of the second lateral surface 230 inches. The entrance/exit face 142 of the light reflectors 280,
and may be approximately one inch. In an alternative 282, 284, 286, 287 in an exemplary embodiment, may be 9
embodiment, the diameter of the first lateral surface 228 may millimeters in diameter.
be different from the diameter of the second lateral surface The components of the example reflector devices are
230. In an exemplary embodiment, the length of the reflector 20 described above with reference to a generally circular or
device 222 along the center axis 248 is approximately two cylindrical geometry. It is understood, however, that the
inches. The entrance/exit face 142 of the reflectors 240, 242, invention may take the form of various other geometrical
244, 246, 247 in an exemplary embodiment, may be 9 shapes, e.g., square, polygon, rectangle, triangle, etc. Addi-
millimeters in diameter. In an exemplary embodiment, the tionally, the reflector device may include a stem and/or a
length of the first stem 224 is equal to the length of the 25 socket for mounting to the reflector pole either at the top or
second stem 226 and is 1.25 inches. In an exemplary within the pole as an insert. Thus, for example, the first
embodiment, the diameter of the first lateral surface 250 of lateral surface of the reflector device may include a stem
the first stem 224 is equal to the diameter of the first lateral while the second lateral surface may include a socket and
surface 254 of the second stem 226 and is 0.875 inches. In vice versa.
an alternative embodiment, the diameter of the first lateral 30 The invention just described provides for the simple,
surface 250 of the first stem 224 may be greater than or equal accurate, and reliable determination of the distance from a
to the diameter of the first lateral surface 228 of the reflector laser range finder to a reflector device mounted at a desired
device 222. In an alternative embodiment, the diameter of target location. In an example use case, the reflector device
the second lateral surface 254 of the second stem 226 may may be mounted in a flagstick standing upright in a golf
be greater than or equal to the diameter of the second lateral 35 hole. Placement of the reflector device in the flagstick
surface 230 of the reflector device 222. improves the accuracy and reliability of distance measure-
In an alternative embodiment, a reflector device 262 may ments determined in the laser range finder carried by the
be used as an insert mounted in the reflector pole 54. With golfer by increasing the amount of laser light reflected back
reference to FIGS. 24-28, the reflector device 262 may toward the laser range finder. It is understood that the
include, but is not limited to, a first lateral surface 268, a rod 40 invention is not confined to the particular embodiments set
surface 263, a second lateral surface 270, a first socket 272, forth herein as illustrative, but embraces all such modifica-
a second socket 274, a third socket 276, a fourth socket 278, tions, combinations, and permutations as come within the
a fifth socket 279, a first light reflector 280, a second light scope of the following claims. Thus, the description of the
reflector 282, a third light reflector 284, a fourth light exemplary embodiments is for purposes of illustration and
reflector 286, and a fifth light reflector 287. The first socket 45 not limitation.
272, the second socket 274, the third socket 276, the fourth What is claimed is:
socket 278, and the fifth socket 279 have a size and shape 1. A method for determining a distance to a target, the
sufficient to hold the first light reflector 280, the second light method comprising:
reflector 282, the third light reflector 284, the fourth light sending laser light at a first time from a device to a
reflector 286, and the fifth light reflector 287, respectively. 50 reflector device, the reflector device mounted to a pole,
The first light reflector 280 is mounted in the first socket 272. wherein the reflector device comprises:
The second light reflector 282 is mounted in the second a first lateral surface having a first exterior peripheral
socket 274. The third light reflector 284 is mounted in the edge;
third socket 276. The fourth light reflector 286 is mounted in a second lateral surface having a second exterior periph-
the fourth socket 278. The fifth light reflector 287 is mounted 55 eral edge;
in the fifth socket 279. a rod surface extending from the first exterior peripheral
FIGS. 24-28 show the reflector device 262 mounted in the edge to the second exterior peripheral edge;
reflector pole 54 and successively rotated in 72 degree two to four sockets, the two to four sockets formed in the
increments to show the arrangement of sockets 272, 274, rod surface and arranged in a plurality of rows; and
276, 278, 279. Thus, FIG. 25 shows the reflector device 262 60 a light reflector mounted in one of the two to four sockets,
of FIG. 24 rotated 72 degrees about a center axis in a the light reflector receiving a portion of the laser light
clockwise direction as viewed from the second lateral sur- and reflecting the received portion of the laser light
face 270. FIG. 21 shows the reflector device 262 of FIG. 20 back to the device;
rotated 72 degrees in the same direction. FIG. 22 shows the receiving laser light reflected from the light reflector at the
reflector device 262 of FIG. 21 rotated 72 degrees in the 65 device at a second time; and
same direction. FIG. 23 shows the reflector device 262 of determining the distance from the device to the reflector
FIG. 22 rotated 72 degrees in the same direction. device using the first time and the second time.
Exhibit A - Page 17
US 7,215,412 B2
13 14
2. A device for reflecting laser light back to a laser range a first lateral surface having a first exterior peripheral
finder, the device comprising: edge;
a first lateral surface having a first exterior peripheral a second lateral surface having a second exterior periph-
edge; eral edge;
a second lateral surface having a second exterior periph- a rod surface extending from the first exterior peripheral
eral edge; edge to the second exterior peripheral edge;
a rod surface extending from the first exterior peripheral two to four sockets, the two to four sockets formed in the
edge to the second exterior peripheral edge; rod surface and arranged in a plurality of rows; and
two to four sockets, the two to four sockets formed in the a light reflector mounted in each of the two to four
rod surface and arranged in a plurality of rows; and 10 sockets, whereby a portion of the laser light directed ~t
a light reflector mounted in each of the two to four the reflector device from the laser range finder 1s
sockets, whereby a portion of laser light directed at the reflected back to the laser range finder by at least one
device from a laser is reflected back to the laser by at light reflector.
least one light reflector. 13. A method for determining a distance to a target, the
3. The device of claim 2, further comprising a first
15 method comprising:
mounting socket, the first mounting socket extending from
sending laser light at a first time from a device to a
the first lateral surface, wherein a first stem at an end of a
reflector device, the reflector device mounted to a pole,
first pole is capable of insertion in the first mounting socket.
wherein the reflector device comprises:
4. The device of claim 3, wherein an interior surface of the
a first lateral surface having a first exterior peripheral
first mounting socket is threaded.
20 edge;
5. The device of claim 3, further comprising a second
a second lateral surface having a second exterior periph-
mounting socket, the second mounting socket extending
eral edge;
from the second lateral surface, wherein a first stem at an end
a rod surface extending from the first exterior peripheral
of a second pole is capable of insertion in the second
edge to the second exterior peripheral edge;
mounting socket.
25 a plurality of sockets, the plurality of sockets formed in
6. The device of claim 5, wherein an interior surface of the
the rod surface and arranged in a plurality of rows,
second mounting socket is threaded. wherein two or more sockets are arranged in at least
7. The device of claim 2, further comprising a first stem, one row of the plurality of rows; and
the first stem extending from the first lateral surface in a a light reflector mounted in one of the plurality of soc~ets,
direction opposite the first lateral surface, wherein the first the light reflector receiving a portion of the laser hght
30
stem is capable of insertion in a first socket at an end of a and reflecting the received portion of the laser light
first pole. back to the device;
8. The device of claim 7, wherein an exterior surface of receiving laser light reflected from the light reflector at the
the first stem is threaded. device at a second time; and
9. The device of claim 7, further comprising a second determining the distance from the device to the reflector
35
stem, the second stem extending from the second lateral device using the first time and the second time.
surface in a direction opposite the second lateral surface, 14. A device for reflecting laser light back to a laser range
wherein the second stem is capable of insertion in a first finder, the device comprising:
socket at an end of a second pole. a first lateral surface having a first exterior peripheral
10. The device of claim 9, wherein an exterior surface of edge;
40
the second stem is threaded. a second lateral surface having a second exterior periph-
11. A device for reflecting laser light back to a laser range eral edge;
finder, the device comprising: a rod surface extending from the first exterior peripheral
a pole; and edge to the second exterior peripheral edge;
a reflector device, the reflector device mounted to the pole a plurality of sockets, the plurality of sockets formed in
45
and comprising: the rod surface and arranged in a plurality of rows,
a first lateral surface having a first exterior peripheral wherein two or more sockets are arranged in at least
edge; one row of the plurality of rows; and
a second lateral surface having a second exterior periph- a light reflector mounted in each of the plurality of
eral edge; sockets, whereby a portion of laser light directed at the
a rod surface extending from the first exterior peripheral 50
device from a laser is reflected back to the laser by at
edge to the second exterior peripheral edge; least one light reflector.
two to four sockets, the two to four sockets formed in the 15. The device of claim 14, further comprising a first
rod surface and arranged in a plurality of rows; and mounting socket, the first mounting socket extending from
a light reflector mounted in each of the two to four the first lateral surface, wherein a first stem at an end of a
sockets, whereby a portion of laser light directed at the 55
first pole is capable of insertion in the first mounting soc k et.
least one light reflector. 16. The device of claim 15, wherein an interior surface of
12. A system for determining a distance to a target, the the first mounting socket is threaded.
system comprising: 17. The device of claim 15, further comprising a second
a laser range finder, the laser range finder configured to: 60 mounting socket, the second mounting socket extending
send laser light at a first time to a reflector device; from the second lateral surface, wherein a first stem at an end
receive a portion of the laser light reflected from the of a second pole is capable of insertion in the second
reflector device at a second time; and mounting socket.
determine the distance from the laser range finder to the 18. The device of claim 17, wherein an interior surface of
reflector device using the first time and the second time; 65 the second mounting socket is threaded.
a pole; and 19. The device of claim 14, further comprising a first
the reflector device mounted to the pole and comprising: stem, the first stem extending from the first lateral surface in
Exhibit A - Page 18
US 7,215,412 B2
15 16
a direction opposite the first lateral surface, wherein the first 24. A system for determining a distance to a device, the
stem is capable of insertion in a first socket at an end of a system comprising:
first pole. a laser range finder, the laser range finder configured to:
20. The device of claim 19, wherein an exterior surface of
the first stem is threaded. send laser light at a first time to a reflector device;
21. The device of claim 19, further comprising a second receive a portion of the laser light reflected from the
stem, the second stem extending from the second lateral reflector device at a second time; and
surface in a direction opposite the second lateral surface, determine the distance from the laser range finder to the
wherein the second stem is capable of insertion in a first reflector device using the first time and the second time;
socket at an end of a second pole. 10
a pole; and
22. The device of claim 21, wherein an exterior surface of
the second stem is threaded. the reflector device mounted to the pole and comprising:
23. A device for reflecting laser light back to a laser range a first lateral surface having a first exterior peripheral
finder, the device comprising: edge;
a pole; and 15 a second lateral surface having a second exterior periph-
a reflector device, the reflector device mounted to the pole eral edge;
and comprising:
a first lateral surface having a first exterior peripheral a rod surface extending from the first exterior peripheral
edge; edge to the second exterior peripheral edge;
a second lateral surface having a second exterior periph- 20 a plurality of sockets, the plurality of sockets formed in
era! edge; the rod surface and arranged in a plurality of rows,
a rod surface extending from the first exterior peripheral wherein two or more sockets are arranged in at least
edge to the second exterior peripheral edge; one row of the plurality of rows; and
a plurality of sockets, the plurality of sockets formed in
a light reflector mounted in one of the plurality of sockets,
the rod surface and arranged in a plurality of rows,
25 whereby a portion of the laser light directed at the
wherein two or more sockets are arranged in at least
one row of the plurality of rows; and reflector device from the laser range finder is reflected
a light reflector mounted in each of the plurality of back to the laser range finder by at least one light
sockets, whereby a portion of laser light directed at the reflector.
least one light reflector. * * * * *
Exhibit A - Page 19
Exhibit B
Exhibit B - Page 1
Exhibit B - Page 2
Exhibit B - Page 3
Exhibit B - Page 4
Exhibit B - Page 5
Exhibit B - Page 6
Exhibit B - Page 7
Exhibit B - Page 8
Exhibit B - Page 9
Exhibit B - Page 10
Exhibit B - Page 11
Exhibit C
Exhibit C - Page 1
Exhibit C - Page 2
Exhibit C - Page 3
Exhibit D
Laser Link Golf Products :: Beacon

HOME PRODUCTS LASER LINK COURSES COMPANY CONTACT CUSTOMER CARE STORE
RANGEFINDERS: XL1000 RH2 QUICKSHOT 2.0 SWITCH TOUR SLOPE REFLECTORS: BEACON
SMART STICK
The BEACON
The best flagstick reflector in golf!
Over 17 years ago, Laser Link Golf invented the prism flagstick reflector as a way to
make laser rangefinders the fastest, simplest, and most accurate way to measure
distance. The prism reflector is superior to all other reflector products in the golf market,
and we are proud to offer the best version in the business. For warranty information,
click here.
• Specially treated prisms that help repel water,

dirt, and chemicals - All of our prisms are
treated with a nanostructured glass treatment
to provide not only water, dirt, and chemical
repellant, but also abrasion/scratch resistance
and UV resistance. Your reflectors will work
better, and require less maintenance, than
other prism products.
• Five-prism design for 360-degree coverage
• LIFETIME WARRANTY - The best warranty

available. Buy the BEACON with confidence
that it will last.
• Strip-resistant metal threading
REGISTER YOUR RANGEFINDER REBATES REPAIRS CONTACT US MANUALS TRADE FOR THE UPGRADE
©2017, All rights reserved.
Exhibit D - Page 1
http://www.laserlinkgolf.com/products_beacon.php[12/5/2017 6:08:47 PM]
BEACON Flagstick Reflector
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Product List
BEACON Flagstick Reflector
Over 17 years ago, Laser Link Golf invented the prism flagstick reflector as a
way to make laser rangefinders the fastest, simplest, and most accurate
way to measure distance. The prism reflector is superior to all other
reflector products in the golf market, and we are the proud to offer the
best version in the business.

The BEACON features include:
Specially treated prisms that repel water, dirt, and chemicals -

All of our prisms are treated with a nanostructured glass treatment to
provide not only water, dirt, and chemical repellent, but also
abrasion/scratch resistance and UV resistance. Your reflectors will
work better, and require less maintenance, than other reflector
products.
Five-prism design for 360-degree coverage
No warranty for the accuracy of product image or description.
LIFETIME WARRANTY
Publisher 0315
Strip-resistant metal threading
Same day shipping - Order before 12pm and your order ships that
Price $29.00 day!
Saturday delivery with the US Postal Service.

Select Options THE BEST PRICE!
Measurements: 1.75" height x .875" wide
Coupon
Quantity
1
Privacy Policy
Exhibit D - Page 2
https://store.laserlinkgolf.com/Store/tabid/71/CategoryID/2/List/0/Level/a/productid/144/Default.aspx?SortField=Free2%2cProductName[12/5/2017 6:30:12 PM]
THE BEST FLAGSTICK

REFLECTOR IN GOLF!
Over 17 years ago, Laser Link Golf invented the prism flagstick reflector as a way to
make laser rangefinders the fastest, simplest, and most accurate way to measure distance.
The prism reflector is superior to all other reflector products in the golf market, and we are
proud to offer the best version in the business.
The BEACON features include:
• S
pecially treated prisms that help repel
water, dirt, and chemicals - All of our prisms are
treated with a nanostructured glass treatment to provide
not only water, dirt, and chemical repellent, but also
abrasion/scratch resistance and UV resistance. Your
reflectors will work better, and require less maintenance,
than other prism products.

• Five-prism design for 360-degree coverage

• LIFETIME WARRANTY - The best warranty available.
Buy the BEACON with confidence that it will last.

• Strip-resistant metal threading

• Same day shipping - Order before
12pm, and your order ships that day!

• Saturday delivery

• THE BEST PRICE
GET YOUR FLAGSTICK TOP REFLECTORS FROM

THE COMPANY THAT INVENTED THEM!
Visit www.laserlinkgolf.com for more information. (866) 909-4653
Exhibit D - Page 3

Prestige Flag Mfg. v. Golf Solutions I - Complaint

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Prestige Flag Mfg. v. Golf Solutions I - Complaint

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Case 3:17-cv-02543-LAB-KSC Document 1 Filed 12/19/17 PageID.

1 SHEPPARD MULLIN RICHTER & HAMPTON LLP

1 JURISDICTION AND VENUE

16 a plurality of sockets, the plurality of sockets formed in the

1 noncompetition clause, and, as such, Prestige is entitled to damages pursuant to 35

1 30. Moreover, Defendants have infringed and continue to infringe the

1 THIRD CAUSE OF ACTION

1 misrepresent the nature, characteristics, or qualities of Golf Solutions’ and Prestige’s

1 pursuant to 15 U.S.C. §1118, Prestige is entitled to an order requiring destruction of

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

1 DEMAND FOR JURY TRIAL

Citizen or Subjec1of a 0 3 0 3 Foreign Naiion 06 06

JV NATURE OF SUIT (Place an "X" in 0 ne Box 0 11)1

Vlll. RELATED CASE(S)

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

c12) United States Patent (10) Patent No.: US 7,215,412 B2

(54) FLAGPOLE REFLECTORS FOR LASER 6,062,985 A 512000 Rege

U.S. Patent May 8, 2007 Sheet 1 of 10 US 7,215,412 B2

reflector device at a first time 110 .....

U.S. Patent May 8, 2007 Sheet 3 of 10 US 7,215,412 B2

CX) O> ..-

U.S. Patent May 8, 2007 Sheet 4of10 US 7,215,412 B2

U.S. Patent May 8, 2007 Sheet 5 of 10 US 7,215,412 B2

U.S. Patent May 8, 2007 Sheet 6 of 10 US 7,215,412 B2

222 222 ....

250 ------r__; rJl

.... ,~ ....... _,,,,,,,..... -·· 247

239 '- 'fl I lfil 1J1

244~ NI I 1111 11 222_ rnl223 ....0.....

284 Ill I --'- I II L...-,.....- 284

262 262~ 263 ....0.....

U.S. Patent May 8, 2007 Sheet 10 of 10 US 7,215,412 B2

• Specially treated prisms that help repel water,

• LIFETIME WARRANTY - The best warranty

• Strip-resistant metal threading

©2017, All rights reserved.

BEACON Flagstick Reflector

Specially treated prisms that repel water, dirt, and chemicals -

THE BEST FLAGSTICK

The BEACON features include:

GET YOUR FLAGSTICK TOP REFLECTORS FROM

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