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I VERIFICATION
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Plaintiff PRO-TROLL, a California corporation ("Plaintiff') is aparty to this action. I,
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Richard B. Pool, veriff that I am an Officer in Plaintiff herein, that I am authorized to make this
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verification on behalf of Plaintiff, and that I have read the foregoing Complaint and know the
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contents thereof. I verify that the factual matters stated in the foregoing Complaint are true based
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on my own knowledge except as to those matters which are stated on information and belief; and
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as to those matters I believe them to be true.
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I declare under penalty of perjury under the laws of the United States of America that the
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foregoing is true and correct.
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Executed February 1 ,2018, ut Q lzaSant llt^l | , ce.
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COMPLAINT FOR PATENT INFRINGEMENT CASENO.
 Case 3:18-cv-00731 Document 1-1 Filed 02/02/18 Page 1 of 3
USO0D516663S

(12) United States Design Patent (10) Patent N0.: US D516,663 S

P001 et al. (45) Date of Patent: ** Mar. 7, 2006

(54) FISHING LURE D451,574 S * 12/2001 Hobson et al. .......... .. D22/129

D453,811 S * 2/2002 Hobson et al. D22/129

Inventors: Cecil
Richard
R Spurgeon,
B P00], Lafayette,
Richmond, CA (US) * Cited by examiner
S * Yamaguchi . . . . . . . . . . . . . . ..

(73) Assignee: PRO- Troll, Inc., Concord, CA (US) Primary Examiner—Catherine R. Oliver
(H) Term: 14 Years 74 Artorney, A gen,t 0r F'lrm—E rnes tH.MC
(VIJCOY c oy,'B ruce &

(21) Appl. No.: 29/215,090 (57) CLAIM

(22) Filed: Oct 12’ 2004 The ornamental design for a ?shing lure, as shoWn and
described.
(51) LOC (8) Cl. .................................................. .. 22-05
(52) US. Cl. .................................................... .. D22/129 DESCRIPTION
(58) Field of Classi?cation Search ...... .. D22/126—133; FIG. 1 is a front perspective vieW showing my new design;
43/4205, 42.06, 425, 42.31, 45.51, 42.32, FIG. 2 is a top plan vieW thereof;
43/4233, 42.34, 43.1, 43.13 FIG. 3 is a bottom plan vieW thereof;
See application ?le for complete search history. FIG. 4 is a side elevation thereof;
_ FIG. 5 is an opposite side vieW thereof;
(56) References Clted FIG. 6 is an end elevation thereof; and,
U S PATENT DOCUMENTS FIG. 7 is an opposite end elevation thereof.

D399,293 S * 10/1998 Cordingley .............. .. D22/129 1 Claim, 2 Drawing Sheets

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U.S. Patent Mar. 7, 2006 Sheet 2 of2 US D516,663 S

FIG.—4

FIG.-5
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Antero.Tormey&Petrin
101 Gregory Lane Suite 46 - Pleasant Hill, CA94523
(4i5) 355-4529 - www.Antlegal.com

August 28,24L6

Thomas L. Doss, Sr.

Proking Spoon LLC
1179 N. Apple Ct.
Plainwell, MI 49080

Dear Mr. Doss:

We represent Pro-Troll, Inc, a leader in fishing and marine products. One of their leading
products is the ProChip 8" flasher.

This letter is to inform you of Pro-Troll's family of published patents covering Pro-Troll's
flasher product line. These patents include published U.S. patents 6,457,275; D516663; D678460;
6,457,275; and others.

We have become aware that you are involved in the sale and/or manufacture of a product
that is fully covered by Pro-Troll's patents. To wit, you offer identical flashers - the Pro King
Double Rudder Salmon Flasher for sale on www.allseasonssports.com. As a leader in the fishing
industry and in particular flashers, Pro-Troll intends to fully enforce its rights to its inventions and
all other intellectual property it owns.

Patent litigation is a very expensive endeavor. Moreover, our client is entitled to triple
damages for willful patent infringement. This firm has recently successfully litigated to enforce

the design patent that protects these same flashers.

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We demand that you immediately stop manufacturing, producing, marketing, selling

and/or reselling flashers that infringe Pro-Troll's patents. Continuing these activities will result in
damages for willful infringement.

Antero, Tormey & Petrin (92513ss-452e

101 Gregory Lane, Suite 46
Pleasant Hill, CA 94523
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Antero.Tormey&Petrin
101 Gregory Lane Suite 46 - Pleasant Hill, CA94523
(415) 355-4529 - www.Antlegal.com

October 5,2017

Derek Vekich
KMDA, Inc.
P.O. Box 509
Bovey, MN 55709

Dear Mr. Vekich:

We represent Pro-Troll, Inc, a leader in fishing and marine products. One of their leading
products is the ProChip 8" flasher.

This letter is to inform you of Pro-Troll's family of published patents covering Pro-Troll's
flasher product line. These patents include published U.S. patents 6,457,275;D516663;D678460;
6,457,275; and others.

We have become aware that you are involved in the sale and/or manufacture of a product
that is fully covered by Pro-Troll's patents. To wit, you offer identical flashers - the Pro King
Double Rudder Salmon Flasher, which we have reason to believe is manufactured by KMDA, Inc.
under its subsidiary name Opti Tackle, for sale on www.allseasonssports.com. As a leader in the
fishing industry and in particular flashers, Pro-Troll intends to fully enforce its rights to its
inventions and all other intellectual property it owns.

Patent litigation is a very expensive endeavor. Moreover, our client is entitled to triple
damages for willful patent infringement. This firm has recently successfully litigated to enforce
the design patent that protects these same flashers. You can avoid legal action by immediately
ceasing and desisting from any and all infringing activity including ceasing the manufacture,
production, marketing and sale of the infringing flashers, and all other flashers that infringe Pro-
Troll's patent(s). Additionally, you must execute a copy of the below agreement to cease and
desist, and send it to this firm within seven (7) days of the receipt of this letter. I recommend you
consult with an attomey before taking any action.
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If you oI youf attorney have any questions, please feel free to contact me.
Regards,

Pete Torrney
Antero, Tormey & Petrin (925) ssS-452e
101 Gregory Lane, Suite 46
Pleasant Hill, CA 94523
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I, Derek Vekich, personally and on behalf of KMDA, Inc., agree to immediately cease and
desist from any and all further manufacture, production, marketing and sale of the Pro King

Double Rudder Salmon Flasher and all other products that infringe Pro-Troll's patents,
including published U.S. patents 6,457,275;D516663;D678460; and6,457,275.lnthe event
this agreement is breached by me or KMDA, Inc., Pro-Troll shall be entitled to costs,
attorney's fees, and collection costs related to any claims and/or action brought to enforce
this agrcement and shall be free to pursue all rights it had as of the date of this letter as if this
letter had never been signed. I certify that I have the authority to enter into this agreement on
behalf of KMDA,Inc.

Dated: By:
Derek Vekich, individually and on behalf of
KMDA,Inc.
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