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Young v. Anne Stone

Young v. Anne Stone

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Published by PatentBlast
Young v. Anne Stone
Young v. Anne Stone

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Published by: PatentBlast on Jul 11, 2013
Copyright:Attribution Non-commercial

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07/11/2013

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ROGER YOUNG
v.
IN THE UNITED STATES DISTRICT COURT
FOR
THE NORTHERN DISTRICT OF ILLINOIS
Plaintiff,No.
_____
ANNE STONE, INC.
JURY TRIAL DEMANDED
Defendant.
COMPLAINT
FOR
PATENT INFRINGEMENT
Plaintiff Roger Young files this complaint for patent infringement against DefendantAnne Stone, Inc. ("Anne Stone") and states as follows:
THE
PARTIES
I.
Roger Young is an individual domiciled
in
the State
of
California with his place
of
residence at 9460 Upper Valley Rd., Auburn, CA 95602.
2.
Upon information and belief, Defendant Anne Stone is a corporation organizedunder the laws
of
the State
of
California with its principal place
of
business at 468
N.
CamdenDr., 2nd Floor, Beverly Hills, California.
3.
Anne Stone is in the business, inter alia,
of
selling golf putting equipment,including putting practice targets, and has sold and provided golf putting practice targetsthroughout the United States and, on information and belief, in this District. Specifically, AnneStone sells the Putt-A-RoundTM practice target, which is a circular putting target that allows a
 
user
to
practice putting from any direction.
JURISDICTION
AND
VENUE
4.
This
is
an action for patent infringement arising under the patent laws
of
theUnited States, Title 35
of
the United States Code. Jurisdiction as to these claims is conferred onthis Court by 35 U.S.C.
§§
1331
and 1338(a).
5.
This Court has personal jurisdiction over Defendant because Defendant advertisesits products in this District. Specifically, Defendant advertises its Putt-A-RoundTM practicetarget through SkyMall® Magazine, which is made available on flights to and from this Districtoperated by, among others, United Airlines and American Airlines. Copies
of
excerpts fromSkyMall® Magazine for Late Spring 2013 for United Airlines and American Airlines areattached as Exhibits
Band
C, respectively.
6.
On information and belief, Defendant Anne Stone purchased advertising inSkyMall® Magazine with the knowledge and intent that the advetiising would reach consumersin this District and with the intent to sell its Putt-A-RoundTM product in this District.
7.
Venue is proper in this district under 28 U.S.C.
§§
1391(b) and 1400(b).
COUNT
I -
INFRINGEMENT OF
U.S.
PATENT
D442,661
8.
Roger Young incorporates by reference paragraphs 1-7 as fully set forth herein.
9.
On May 22, 2001, United States Patent No. D442,661 ("the '661 patent") entitled
"Golf
Putting Practice Hole Simulator" was duly and legally issued
by
the United States Patentand Trademark Office. Roger Young is the owner
of
all right, title, and interest in and to the '661patent, with full right to bring suit to enforce the patent, including the right to recover for pastinfringement damages. A copy
of
the '661 patent is attached hereto as Exhibit
A.
10.
Anne Stone has known
of
the '661 patent since at least as early as May 29, 2013,
 
when counsel for Roger Young mailed a letter notifying Anne Stone
of
the'
661
patent.
Ii.
Anne Stone has directly infringed and continues
to
infringe the '661 patent under
35
U.S.C.
§
271(a) by making, using, selling, or offering for sale in the United States
at
least itsPutt-A-Round™ product.
12.
The design
of
Defendant Anne Stone's Putt-A-Round™ product
is
substantiallyidentical
to
the design claimed by Roger Young in the '661 patent. At the very least, the design
of
the Putt-A-Round™ product
is no
more than a colorable imitation
of
the design
of
the '661patent. The following table illustrates this striking similarity in design:

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