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Rick N. Bryson/Bar No. 010568 Benjamin K. Erlick/Bar No. 027176 SANDERS & PARKS, P.C. 1300 SCF Tower 3030 North Third Street Phoenix, AZ 85012-3099 Rick N. Bryson Direct Phone: (602) 532-5710 Direct Fax: (602) 230-5014 E-Mail: Rick.Bryson@SandersParks.com
Attorneys for Plaintiff Arizona Manufacturing & Embroidery, Inc. UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA DIVISION ONE

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v. INCREDIBLE GOLF, LLC, a Texas limited Defendant. Plaintiff Arizona Manufacturing & Embroidery, Inc. (AM&E) brings this complaint for patent infringement against defendant Incredible Golf, LLC (I-Golf) and alleges as follows: PARTIES 1. Plaintiff AM&E is a corporation incorporated under the laws of the State of EMBROIDERY, INC., an Arizona corporation, COMPLAINT AND JURY DEMAND Plaintiff,

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85281. 2.

Arizona, having its principal place of business at 606 South Hacienda Drive, Tempe, Arizona,

AM&E creates golf accessories used by golf club members, and golf

professionals around the world.

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3.

Upon information and belief, Defendant I-Golf is a Texas limited liability

company, having its principal place of business at 12510 Cutten Road, Houston, Texas 77066. 4. Upon information and belief, Defendant I-Golf designs and manufactures golf

accessories, is a direct competitor to AM&E, and does business in Maricopa County, Arizona. 5. Upon information and belief, Defendant I-Golf does business as Back 9 USA

and B9 LTD. JURISDICTION AND VENUE 6. This action is for patent infringement under 35 U.S.C. 100 et seq. This Court

has subject matter jurisdiction under 28 U.S.C. 1331 (Federal Question) and 1338(a) (Patent Infringement). 7. Venue in this district is proper under 28 U.S. C. 1391(b). FACTS 8. U.S. Patent No. 6,095,214 (the 214 patent), entitled Golf Club Head Cover,

was duly and legally issued on August 1, 2000. A true and correct copy of the 214 patent is attached hereto as Exhibit A. 9. AM&E is the owner of the 214 patent with the right to collect damages for all

relevant times, and has the right to prevent others from making, having made, using, offering for sale or selling products or services covered by such patent, as well as the right to enforce the 214 patent with respect to defendant I-Golf. COUNT I. (Patent Infringement) 10. herein. 11. Defendant I-Golf has infringed and is continuing to infringe, directly AM&E incorporates by reference paragraphs 1-9 above, as if fully set forth

contributorily and/or by inducement, one or more claims of the 214 patent in violation of 35 U.S.C. 271, and is still doing so by making, selling, and/or offering for sale, one or more golf-

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club-head-cover products manufactured, designed and/or sold by I-Golf, including I-Golfs

Legend Headcover series golf-club-head-cover products, and will continue to do so unless


enjoined by this Court. 12. Upon information and belief, I-Golf had actual knowledge of the 214 patent prior

to engaging in its infringing activity. I-Golfs infringement of the 214 patent is willful and deliberate. 13. 14. AM&E has been and continues to be damaged by the infringement. AM&E has and continues to incur irreparable harm that can only be fully

redressed by injunctive relief pursuant to 35 U.S.C. 283. 15. AM&E is entitled to treble damages, attorneys fees and costs pursuant to 35

U.S.C. 284 and 285. PRAYER FOR RELIEF WHEREFORE, AM&E prays for: a. b. A finding by this Court that I-Golf has infringed the 214 patent. An injunction under 35 U.S.C. 283 preliminarily and permanently enjoining and

restraining I-Golf, its officers, managers, members, agents, parents, subsidiaries, principals, successors in interest, and those acting in concert with it from directly or indirectly infringing, inducing, or contributing to the infringement of the 214 patent. c. An order requiring I-Golf to account to AM&E for all the gains, profits and

advantages realized from its infringement of the 214 patent. d. An award to AM&E of damages adequate to compensate for the infringement by

I-Golf of the 214 patent, including lost profits of AM&E, but in no event less than a reasonable royalty under 35 U.S.C. 284. e. An award of treble damages for the willful infringement of the 214 patent

pursuant to 35 U.S.C. 284. f. An award of attorney fees, costs, and expenses incurred in connection with this

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action pursuant to 35 U.S.C. 285. g. h. An award of prejudgment and post-judgment interest. Such other and further relief as the Court deems equitable and appropriate. JURY DEMAND Plaintiff hereby requests a jury trial. RESPECTFULLY SUBMITTED this 24th day of October, 2012. SANDERS & PARKS, P.C.

By

/s/ Rick N. Bryson Rick N. Bryson

Benjamin K. Erlick
1300 SCF Tower 3030 North Third Street Phoenix, Arizona 85012-3099 Attorneys for Plaintiff Arizona Manufacturing & Embroidery, Inc.

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