Case: 1:17-cv-06672 Document #: 2 Filed: 09/15/17 Page 1 of 28 PageID #:4

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

Parsons Xtreme , LLC, a Delaware limited liability company, Case No. 1:17-cv-6672

Plaintiff, JURY TRIAL DEMANDED v.

Golf & Pro Shop, Inc., d/b/a PGA TOUR Superstore, a Georgia corporation; DICK’S Sporting Goods, Inc., a Delaware corporation; and Golf Galaxy, Inc., a Minnesota corporation,

Defendants.

COMPLAINT

For its Complaint against Defendants, Plaintiff Parsons Xtreme Golf, LLC

(hereinafter referred to as “PXG”) alleges as follows:

PARTIES, JURISDICTION AND VENUE

PARTIES

1. Plaintiff PXG is now, and has been at all relevant times, a Delaware

limited liability company, having its principal place of business in Scottsdale,

Arizona. PXG is properly registered in as a foreign limited liability

company authorized to do business in Arizona.

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2. Defendant Golf & Tennis Pro Shop, Inc., d/b/a PGA TOUR

Superstore (“PGA Tour Superstore”) is now, and has been at all relevant times, a

Georgia corporation having its principal place of business in Roswell, Georgia.

3. Defendant DICK’S Sporting Goods, Inc. (“Dick’s Sporting Goods”) is now, and has been at all relevant times, a Delaware corporation having its principal place of business in Coraopolis, Pennsylvania.

4. Defendant Golf Galaxy, Inc. (“Golf Galaxy”) is now, and has been at all relevant times, a Minnesota corporation having its principal place of business in

Coraopolis, Pennsylvania.

JURISDICTION AND VENUE

5. This civil action includes claims for patent infringement arising under the Patent Act of the United States, 35 U.S.C. §§ 1-376.

6. This Court has subject-matter jurisdiction over this action under 28

U.S.C. §§ 1331 and 1338.

7. This Court has personal jurisdiction over PGA Tour Superstore and venue is proper in this District under 28 U.S.C. § 1400(b), because PGA Tour

Superstore sells or offers to sell infringing products in this District via its website, and maintains regular and established places of business located within the

District, specifically stores that are, upon information and belief, owned and operated by PGA Tour Superstore located at 1319 E. Golf Rd., Schaumburg, IL

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60173; and 1017 Butterfield Road, Downers Grove, IL 60515. These stores not

only sell or offer to sell infringing products, but upon information and belief they

offer seminars, lessons, custom fittings for equipment, and indoor golf tournaments

for weekly cash prizes.

8. This Court has personal jurisdiction over Dick’s Sporting Goods and

venue is proper in this District under 28 U.S.C. § 1400(b), because Dick’s Sporting

Goods sells or offers to sell infringing products in this District via its website, and

maintains regular and established places of business located within the District,

specifically stores that are, upon information and belief, owned and operated by

Dick’s Sporting Goods located at, inter alia , 1538 N. Clybourn Ave., Chicago, IL

60610; 1100 S. Canal Street, Chicago, IL 60607; 5601 Touhy Ave., Niles, IL

60714; 1900 Tower Drive, Glenview, IL 60026; 810 E. Butterfield Road,

Lombard, IL 60148; 275 Skokie Blvd., Northbrook, IL 60062; 1 Orland Park

Place, Suite 1, Orland Park, IL 60462; 601 N. Martingale, Suite 195, Schaumburg,

IL 60173; 401 E. Palpatine Road, Arlington Heights, IL 60004; 328 West Army

Trail Road, Bloomingdale, IL 60108.

9. This Court has personal jurisdiction over Golf Galaxy and venue is

proper in this District under 28 U.S.C. § 1400(b), because Golf Galaxy sells or

offers to sell infringing products in this District via its website, and maintains

regular and established places of business located within the District, specifically

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stores that are, upon information and belief, owned and operated by Golf Galaxy located at 15756 Lagrange Road, Orland Park, IL 60462; and 555 East Townline

Road #9, Vernon Hills, IL 60061.

ALLEGATIONS COMMON TO ALL COUNTS

PXG INNOVATES THE 0311 IRONS

10. PXG, founded in September of 2014 by well-known business man, philanthropist, and avid golfer Bob Parsons (“Parsons”), was born out of Parsons’ desire to make the world’s best . Sparing no expense and with no cost or time constraints, PXG engaged in the long process of researching various alloys, exploring new technologies, and identifying unique properties that would make PXG clubs unlike anything else. That effort innovated a new technology that

PXG implemented to create a revolutionary —one with an expanded sweet spot, having an ultra-thin club face, and an elastic polymer material injected in the hollow-bodied club . That iron is not only better-performing, but it sounds and feels great. The incorporating PXG’s technology is called the 0311 iron, and it immediately achieved meteoric success among nonprofessional golfers and PGA and LPGA Tour professionals. As PXG’s advertisements suggest:

“Nobody makes golf clubs the way we do. Period.”

11. As a result of Parsons’ passion and PXG’s innovation, PXG has developed a global patent portfolio of 128 patents. PXG has also introduced a full

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line of golf clubs that have and continue to force golfers to change the way they think about the game, and PXG has quickly become a premium international brand, with retailers and distributors around the world.

12. A depiction of PXG’s flagship product, the 0311 iron, is here:

THE PXG PATENTS

13. Parsons, along with Michael Nicolette (“Nicolette”), and Bradley

Schweigert (“Schweigert”) (collectively, the “Inventors”), are the inventors of a variety of golf club heads and methods of manufacture of golf club heads, many of which have resulted in issued patents.

14. One common depiction of a golf club embodiment taught in the

Inventors’ patents is a club at the address position with weight portions below the midplane, for example in Figure 10:

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15. Another depiction of a golf club embodiment taught in the Inventors’ patents is a cross-sectional view, which reveals the thin face, elastic polymer materials filling the interior cavity, and weight portion below the midplane:

16. February 24, 2015, the United States Patent and Trademark Office

(“PTO”) issued U.S. Patent No. 8,961,336 (the “’336 patent”), entitled “GOLF

CLUB HEADS AND METHODS TO MANUFACTURE GOLF CLUB HEADS” to PXG. A true and correct copy of the ’336 patent is attached to this Complaint as

Exhibit A.

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17. The ’336 patent teaches, without limitation, an iron-type golf club head comprising a hollow body portion with an interior cavity filled with an elastic polymer material, a first weight portion coupled to the hollow body at or proximate to a top-and-toe transition region, and a second weight portion coupled to the hollow body at or proximate to a sole-and-toe transition region, wherein the second weight portion is located below a horizontal midplane of the golf club head.

18. On December 1, 2015, the PTO issued U.S. Patent No. 9,199,143 (the

“’143 patent”), entitled “GOLF CLUB HEADS AND METHODS TO

MANUFACTURE GOLF CLUB HEADS” to PXG. A true and correct copy of the ’143 patent is attached to this Complaint as Exhibit B.

19. The ’143 patent teaches, without limitation, an iron-type golf club head comprising a hollow body portion with an interior cavity filled with an elastic polymer material, a first weight portion coupled to the hollow body at or proximate to a top-and-toe transition region, and a second weight portion coupled to the hollow body at or proximate to a sole-and-toe transition region, wherein the second weight portion is located below a horizontal midplane of the golf club head, and the first weight portion has a mass less than the mass of the second weight portion.

20. On May 24, 2016, the PTO issued U.S. Patent No. 9,345,938 (the

“’938 patent”), entitled “GOLF CLUB HEADS AND METHODS TO

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MANUFACTURE GOLF CLUB HEADS” to PXG. A true and correct copy of the ’938 patent is attached to this Complaint as Exhibit C.

21. The ’938 patent teaches, without limitation, a golf club head comprising a hollow body portion having a face portion with a thickness of less than or equal to 1.5 millimeters, an elastic polymer material in the interior cavity configured to fill the interior cavity by injection molding, the elastic polymer being attached to the face and configured to structurally support the face portion during impact with a golf ball, and weight portions coupled to the hollow body portion located above and below the horizontal midplane of the golf club head, wherein the weight portion below the horizontal midplane is greater than the weight portion above the horizontal midplane.

22. On May 24, 2016, the PTO issued U.S. Patent No. 9,346,203 (the

“’203 patent”), entitled “GOLF CLUB HEADS AND METHODS TO

MANUFACTURE GOLF CLUB HEADS” to PXG. A true and correct copy of the ’203 patent is attached to this Complaint as Exhibit D.

23. The ’203 patent teaches, without limitation, a method for forming a hollow body portion having a toe portion, top portion, sole portion, back portion, and front portion having a face, a first weight portion coupled to the hollow body at or proximate to a top-and-toe transition region, and a second weight portion coupled to the hollow body at or proximate to a sole-and-toe transition region,

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wherein the second weight portion is located below a horizontal midplane of the golf club head, and forming an interior cavity comprising an elastic polymer material configured to at least partially absorb impact on the face portion.

24. On June 14, 2016, the PTO issued U.S. Patent No. 9,364,727 (the

“’727 Patent”), entitled “GOLF CLUB HEADS AND METHODS TO

MANUFACTURE GOLF CLUB HEADS” to PXG. A true and correct copy of the ’727 patent is attached to this Complaint as Exhibit E.

25. The ’727 patent teaches, without limitation, an iron-type golf club head comprising a hollow body portion with an interior cavity filled with an elastic polymer material injection molded in the interior cavity, a bonding portion, a first weight portion coupled to the hollow body at or proximate to a top-and-toe transition region, and a second weight portion coupled to the hollow body at or proximate to a sole-and-toe transition region, wherein the second weight portion is located below a horizontal midplane of the golf club head, and the second weight portion includes a greater number of weight portions than the first weight portion.

26. On January 3, 2016, the PTO issued U.S. Patent No. 9,533,201 (the

“’201 patent”), entitled “GOLF CLUB HEADS AND METHODS TO

MANUFACTURE GOLF CLUB HEADS” to PXG. A true and correct copy of the ’201 patent is attached to this Complaint as Exhibit F.

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27. The ’201 patent teaches, without limitation, a golf club head

comprising a body portion having a toe portion, a heel portion, a top portion, a sole

portion, a back portion with weight portions, and a front portion having a face

portion with a thickness being less than or equal to 1.5 millimeters, an interior

cavity, a bonding portion, an elastic polymer injection molded in the cavity,

wherein the elastic polymer material is bonded to the bonding portion, and a

greater number of weight portions are located on the back portion below a

horizontal midplane than above the horizontal midplane.

28. On April 4, 2017, the PTO issued U.S. Patent No. 9,610,481 (the

“’481 patent”), entitled “GOLF CLUB HEADS AND METHODS TO

MANUFACTURE GOLF CLUB HEADS” to PXG. A true and correct copy of

the ’481 patent is attached to this Complaint as Exhibit G.

29. The ’481 patent teaches, without limitation, a golf club head

comprising body portion having an interior cavity filled with an elastic polymer

material, wherein an elastic polymer material volume is related to a body portion

volume by the equation 0.2 ≤ V e / V b ≤ 0.5, where V e is the elastic polymer

3 3 material volume in units of in , and V b is the body portion volume in units of in , wherein a greater number of weight portions are located on the rear portion below a horizontal midplane than above the horizontal midplane.

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30. On June 13, 2017, the PTO issued U.S. Patent No. 9,675,853 (the

“’853 patent”), entitled “GOLF CLUB HEADS AND METHODS TO

MANUFACTURE GOLF CLUB HEADS” to PXG. A true and correct copy of the ’853 patent is attached to this Complaint as Exhibit H.

31. The ’853 patent teaches, without limitation, a golf club head comprising a body portion with a front portion having a face portion with a thickness less than or equal to 1.5 millimeters, an interior cavity, an elastic polymer material injection molded in the interior cavity to structurally support the face portion during the impact with a golf ball, and a bonding portion, wherein a greater number of weight portions are located on the back portion of the body below a horizontal midplane than above the horizontal midplane, wherein at least one weight portion of the plurality of weight portions is constructed from different material than the body portion.

32. For each patent referenced above, on or about the time of the filing of the patent application, the Inventors assigned the entire right, title, and interest to

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the patent application to PXG.

THE ACCUSED TAYLORMADE P790 IRONS

33. Among other products, Defendants offer for sale, sell, import into the

United States, and/or distribute golf clubs under the name TaylorMade P790 (the

“P790 Products”).

34. An example of the P790 Products is depicted here:

35. The P790 Products exhibit a thin face, polymer material within the interior cavity and weight portions below the midline of the club:

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36. TaylorMade’s website and advertising materials confirm that each and every element of at least claim 16 of the ’336 patent and claim 15 of the ’203 patent reads on TaylorMade’s P790 Products.

37. Upon information and belief, each and every element of at least claim

15 of the ’143 patent, claim 15 of the ’938 patent, claim 16 of the ’727 patent, claim 1 of the ’201 patent, claim 1 of the ’481 patent, and claim 1 of the ’853 patent reads on TaylorMade’s P790 Products.

38. Upon information and belief, PGA Tour Superstore has offered to sell the infringing P790 Products in Illinois via its website and at retail stores, such as the stores located in Schaumburg and Downers Grove, Illinois. Specifically, PGA

Tour Superstore advertises via its website that consumers within Illinois may pre- order the P790 Products through September 14, 2017, and upon information and belief, PGA Tour Superstore will offer to sell and sell the P790 Products at all locations thereafter.

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39. Upon information and belief, Dick’s Sporting Goods has offered to sell the infringing P790 Products in Illinois via its website and at retail stores, such as the stores located in Chicago, Niles, Glenview, Lombard, Northbrook, Orland

Park, Schaumburg, Arlington Heights, and Bloomingdale. Specifically, Dick’s

Sporting Goods advertises via its website that consumers within Illinois may purchase the P790 Products, and upon information and belief, offers to sell and sells the P790 Products at all of its retail stores.

40. Upon information and belief, Golf Galaxy has offered to sell the infringing P790 Products in Illinois via its website and at retail stores, such as the stores located in Orland Park and Venon Hills. Specifically, Golf Galaxy advertises via its website that consumers within Illinois may pre-order the P790

Products, and upon information and belief, offers to sell and sells the P790

Products at all of its retail stores.

CAUSES OF ACTION

COUNT I (U.S. Patent No. 8,961,336)

41. PXG realleges and incorporates by reference the preceding paragraphs of this Complaint as though fully set forth herein.

42. Defendants have infringed and continue to infringe directly, by inducement, and/contributorily by making, using, selling, or offering to sell golf

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clubs embodying one or more claims of the ’336 patent, specifically, TaylorMade’s

P790 Products, in violation of 35 U.S.C. §§ 271(a)-(c).

43. Defendants’ infringement of the ’336 patent have been and continue to be willful.

44. Defendants have and have had actual notice and/or constructive notice of the ’336 patent under 35 U.S.C. § 287(a).

45. Defendants’ acts of infringement of the ’336 patent will continue as alleged in this Complaint unless enjoined by the Court.

46. As a direct and proximate result of Defendants’ infringement of the

’336 patent, PXG has suffered and will continue to suffer monetary damages.

47. PXG is entitled to recover from Defendants the damages sustained by

PXG as a result of Defendants’ wrongful acts in an amount to be determined at trial.

48. PXG has suffered irreparable harm as a result of Defendants’ infringement of the ’336 patent.

49. Unless Defendants are enjoined by this Court from continuing their infringement of the ’336 patent, PXG will continue to suffer irreparable harm and impairment of the value of its patent rights. Thus, PXG is entitled to a preliminary and permanent injunction against further infringement.

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COUNT II (U.S. Patent No. 9,199,143)

50. PXG realleges and incorporates by reference the preceding paragraphs of this Complaint as though fully set forth herein.

51. Defendants have infringed and continue to infringe directly, by inducement, and/contributorily by making, using, selling, or offering to sell golf clubs embodying one or more claims of the ’143 patent, specifically, TaylorMade’s

P790 Products, in violation of 35 U.S.C. §§ 271(a)-(c).

52. Defendants’ infringement of the ’143 patent have been and continue to be willful.

53. Defendants have and have had actual notice and/or constructive notice of the ’143 patent under 35 U.S.C. § 287(a).

54. Defendants’ acts of infringement of the ’143 patent will continue as alleged in this Complaint unless enjoined by the Court.

55. As a direct and proximate result of Defendants’ infringement of the

’143 patent, PXG has suffered and will continue to suffer monetary damages.

56. PXG is entitled to recover from Defendants the damages sustained by

PXG as a result of Defendants’ wrongful acts in an amount to be determined at trial.

57. PXG has suffered irreparable harm as a result of Defendants’ infringement of the ’143 patent.

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58. Unless Defendants are enjoined by this Court from continuing their infringement of the ’143 patent, PXG will continue to suffer irreparable harm and impairment of the value of its patent rights. Thus, PXG is entitled to a preliminary and permanent injunction against further infringement.

COUNT III (U.S. Patent No. 9,345,938)

59. PXG realleges and incorporates by reference the preceding paragraphs of this Complaint as though fully set forth herein.

60. Defendants have infringed and continue to infringe directly, by inducement, and/contributorily by making, using, selling, or offering to sell golf clubs embodying one or more claims of the ’938 patent, specifically, TaylorMade’s

P790 Products, in violation of 35 U.S.C. §§ 271(a)-(c).

61. Defendants’ infringement of the ’938 patent have been and continue to be willful.

62. Defendants have and have had actual notice and/or constructive notice of the ’938 patent under 35 U.S.C. § 287(a).

63. Defendants’ acts of infringement of the ’938 patent will continue as alleged in this Complaint unless enjoined by the Court.

64. As a direct and proximate result of Defendants’ infringement of the

’938 patent, PXG has suffered and will continue to suffer monetary damages.

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65. PXG is entitled to recover from Defendants the damages sustained by

PXG as a result of Defendants’ wrongful acts in an amount to be determined at trial.

66. PXG has suffered irreparable harm as a result of Defendants’ infringement of the ’938 patent.

67. Unless Defendants are enjoined by this Court from continuing their infringement of the ’938 patent, PXG will continue to suffer irreparable harm and impairment of the value of its patent rights. Thus, PXG is entitled to a preliminary and permanent injunction against further infringement.

COUNT IV (U.S. Patent No. 9,346,203)

68. PXG realleges and incorporates by reference the preceding paragraphs of this Complaint as though fully set forth herein.

69. Defendants have infringed and continue to infringe directly, by inducement, and/contributorily by making, using, selling, or offering to sell golf clubs embodying one or more claims of the ’203 patent, specifically, TaylorMade’s

P790 Products, in violation of 35 U.S.C. §§ 271(a)-(c), (g).

70. Defendants’ infringement of the ’203 patent have been and continue to be willful.

71. Defendant have and have had actual notice and/or constructive notice of the ’203 patent under 35 U.S.C. § 287(a).

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72. Defendants’ acts of infringement of the ’203 patent will continue as alleged in this Complaint unless enjoined by the Court.

73. As a direct and proximate result of Defendants’ infringement of the

’203 patent, PXG has suffered and will continue to suffer monetary damages.

74. PXG is entitled to recover from Defendants the damages sustained by

PXG as a result of Defendants’ wrongful acts in an amount to be determined at trial.

75. PXG has suffered irreparable harm as a result of Defendants’ infringement of the ’203 patent.

76. Unless Defendants are enjoined by this Court from continuing their infringement of the ’203 patent, PXG will continue to suffer irreparable harm and impairment of the value of its patent rights. Thus, PXG is entitled to a preliminary and permanent injunction against further infringement.

COUNT V (U.S. Patent No. 9,364,727)

77. PXG realleges and incorporates by reference the preceding paragraphs of this Complaint as though fully set forth herein.

78. Defendant has infringed and continues to infringe directly, by inducement, and/contributorily by making, using, selling, or offering to sell golf clubs embodying one or more claims of the ’727 patent, specifically, TaylorMade’s

P790 Products, in violation of 35 U.S.C. §§ 271(a)-(c).

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79. Defendant’s infringement of the ’727 patent has been and continues to be willful.

80. Defendant has and has had actual notice and/or constructive notice of the ’727 patent under 35 U.S.C. § 287(a).

81. Defendant’s acts of infringement of the ’727 patent will continue as alleged in this Complaint unless enjoined by the Court.

82. As a direct and proximate result of Defendant’s infringement of the

’727 patent, PXG has suffered and will continue to suffer monetary damages.

83. PXG is entitled to recover from Defendant the damages sustained by

PXG as a result of Defendant’s wrongful acts in an amount to be determined at trial.

84. PXG has suffered irreparable harm as a result of Defendant’s infringement of the ’727 patent.

85. Unless Defendant is enjoined by this Court from continuing its infringement of the ’727 patent, PXG will continue to suffer irreparable harm and impairment of the value of its patent rights. Thus, PXG is entitled to a preliminary and permanent injunction against further infringement.

COUNT VI (U.S. Patent No. 9,533,201)

86. PXG realleges and incorporates by reference the preceding paragraphs of this Complaint as though fully set forth herein.

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87. Defendants have infringed and continue to infringe directly, by inducement, and/contributorily by making, using, selling, or offering to sell golf clubs embodying one or more claims of the ’201 patent, specifically, TaylorMade’s

P790 Products, in violation of 35 U.S.C. §§ 271(a)-(c).

88. Defendants’ infringement of the ’201 patent have been and continue to be willful.

89. Defendants have and have had actual notice and/or constructive notice of the ’201 patent under 35 U.S.C. § 287(a).

90. Defendants’ acts of infringement of the ’201 patent will continue as alleged in this Complaint unless enjoined by the Court.

91. As a direct and proximate result of Defendants’ infringement of the

’201 patent, PXG has suffered and will continue to suffer monetary damages.

92. PXG is entitled to recover from Defendants the damages sustained by

PXG as a result of Defendants’ wrongful acts in an amount to be determined at trial.

93. PXG has suffered irreparable harm as a result of Defendants’ infringement of the ’201 patent.

94. Unless Defendants are enjoined by this Court from continuing their infringement of the ’201 patent, PXG will continue to suffer irreparable harm and

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impairment of the value of its patent rights. Thus, PXG is entitled to a preliminary and permanent injunction against further infringement.

COUNT VII (U.S. Patent No. 9,610,481)

95. PXG realleges and incorporates by reference the preceding paragraphs of this Complaint as though fully set forth herein.

96. Defendants have infringed and continue to infringe directly, by inducement, and/contributorily by making, using, selling, or offering to sell golf clubs embodying one or more claims of the ’481 patent, specifically, TaylorMade’s

P790 Products, in violation of 35 U.S.C. §§ 271(a)-(c).

97. Defendants’ infringement of the ’481 patent have been and continue to be willful.

98. Defendant have and have had actual notice and/or constructive notice of the ’481 patent under 35 U.S.C. § 287(a).

99. Defendants’ acts of infringement of the ’481 patent will continue as alleged in this Complaint unless enjoined by the Court.

100. As a direct and proximate result of Defendants’ infringement of the

’481 patent, PXG has suffered and will continue to suffer monetary damages.

101. PXG is entitled to recover from Defendants the damages sustained by

PXG as a result of Defendants’ wrongful acts in an amount to be determined at trial.

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102. PXG has suffered irreparable harm as a result of Defendants’ infringement of the ’481 patent.

103. Unless Defendants are enjoined by this Court from continuing their infringement of the ’481 patent, PXG will continue to suffer irreparable harm and impairment of the value of its patent rights. Thus, PXG is entitled to a preliminary and permanent injunction against further infringement.

COUNT VIII (U.S. Patent No. 9,675,853)

104. PXG realleges and incorporates by reference the preceding paragraphs of this Complaint as though fully set forth herein.

105. Defendants have infringed and continue to infringe directly, by inducement, and/contributorily by making, using, selling, or offering to sell golf clubs embodying one or more claims of the ’853 patent, specifically, TaylorMade’s

P790 Products, in violation of 35 U.S.C. §§ 271(a)-(c).

106. Defendants’ infringement of the ’853 patent have been and continue to be willful.

107. Defendants have and have had actual notice and/or constructive notice of the ’853 patent under 35 U.S.C. § 287(a).

108. Defendants’ acts of infringement of the ’853 patent will continue as alleged in this Complaint unless enjoined by the Court.

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109. As a direct and proximate result of Defendants’ infringement of the

’853 patent, PXG has suffered and will continue to suffer monetary damages.

110. PXG is entitled to recover from Defendants the damages sustained by

PXG as a result of Defendants’ wrongful acts in an amount to be determined at trial.

111. PXG has suffered irreparable harm as a result of Defendants’ infringement of the ’853 patent.

112. Unless Defendants are enjoined by this Court from continuing their infringement of the ’853 Patent, PXG will continue to suffer irreparable harm and impairment of the value of its patent rights. Thus, PXG is entitled to a preliminary and permanent injunction against further infringement.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for judgment against Defendants as follows:

1. For judgment that the ’336 patent is valid, enforceable, and infringed by Defendants;

2. For profits and damages resulting from Defendants’ past and present infringement of the’336 patent;

3. For judgment that the ’143 patent is valid, enforceable, and infringed by Defendants;

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4. For profits and damages resulting from Defendants’ past and present infringement of the’143 patent;

5. For judgment that the ’938 patent is valid, enforceable, and infringed by Defendants;

6. For profits and damages resulting from Defendants’ past and present infringement of the’938 patent;

7. For judgment that the ’203 patent is valid, enforceable, and infringed by Defendants;

8. For profits and damages resulting from Defendants’ past and present infringement of the ’203 patent;

9. For judgment that the ’727 patent is valid, enforceable, and infringed by Defendants;

10. For profits and damages resulting from Defendants’ past and present infringement of the ’727 patent;

11. For judgment that the ’201 patent is valid, enforceable, and infringed by Defendants;

12. For profits and damages resulting from Defendants’ past and present infringement of the ’201 patent;

13. For judgment that the ’481 patent is valid, enforceable, and infringed by Defendants;

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14. For profits and damages resulting from Defendants’ past and present infringement of the ’481 patent;

15. For judgment that the ’853 patent is valid, enforceable, and infringed by Defendants;

16. For profits and damages resulting from Defendants’ past and present infringement of the ’853 patent;

17. For injunctive relief, preliminarily and permanently enjoining against the continuing infringement of the ’336 patent by Defendants, their officers, agents, servants, employees, and those persons acting in active concert or in participation with it, under 35 U.S.C. § 283;

18. For injunctive relief, preliminarily and permanently enjoining against the continuing infringement of the ’143 patent by Defendants, their officers, agents, servants, employees, and those persons acting in active concert or in participation with it, under 35 U.S.C. § 283;

19. For injunctive relief, preliminarily and permanently enjoining against the continuing infringement of the ’938 patent by Defendants, their officers, agents, servants, employees, and those persons acting in active concert or in participation with it, under 35 U.S.C. § 283;

20. For injunctive relief, preliminarily and permanently enjoining against the continuing infringement of the ’203 patent by Defendants, their officers,

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agents, servants, employees, and those persons acting in active concert or in participation with it, under 35 U.S.C. § 283;

21. For injunctive relief, preliminarily and permanently enjoining against the continuing infringement of the ’727 patent by Defendants, their officers, agents, servants, employees, and those persons acting in active concert or in participation with it, under 35 U.S.C. § 283;

22. For injunctive relief, preliminarily and permanently enjoining against the continuing infringement of the ’201 patent by Defendants, their officers, agents, servants, employees, and those persons acting in active concert or in participation with it, under 35 U.S.C. § 283;

23. For injunctive relief, preliminarily and permanently enjoining against the continuing infringement of the ’481 patent by Defendants, their officers, agents, servants, employees, and those persons acting in active concert or in participation with it, under 35 U.S.C. § 283;

24. For injunctive relief, preliminarily and permanently enjoining against the continuing infringement of the ’853 patent by Defendants, their officers, agents, servants, employees, and those persons acting in active concert or in participation with it, under 35 U.S.C. § 283;

25. For increased damages, interest, and costs under 35 U.S.C. § 284;

26. For judgment that this is an exceptional case under 35 U.S.C. § 285;

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27. For an award of reasonable attorneys’ fees under 35 U.S.C. § 285;

28. For costs and disbursements incurred by PXG;

29. For an assessment of prejudgment interest; and

30. For any other and further relief as the Court deems just and proper.

JURY TRIAL DEMAND

Plaintiff demands a jury trial on all issues that are triable by a jury.

Dated: September 15, 2017 Loeb & Loeb LLP

By: /s/ Adam G. Kelly Adam G. Kelly (IL 6277772) William J. Voller III (IL 6287608) John A. Cotiguala (IL 6311056) 321 North Clark Street, Suite 2300 Chicago, IL 60654 Telephone: 312.464.3100 Facsimile: 312.464.3111 [email protected] [email protected] [email protected]

Counsel for Plaintiff Parsons Xtreme Golf, LLC

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