IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CHEMICAL LIGHT, INC.

, Plaintiff, vs. PREMIER GLOW, Defendant. ) ) ) ) ) ) ) ) )

Case No.

Jury Trial Demanded

COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Chemical Light, Inc. (Chemical Light), through its attorneys, complains of defendant Premier Glow (Premier Glow) as follows: 1. This action arises under the patent laws of the United States, Title 35 of the

United States Code. PARTIES 2. Plaintiff Chemical Light is an Illinois corporation with its principal place of

business in Vernon Hills, Illinois. 3. On information and belief Defendant Premier Glow is a general partnership

organized and existing under the laws of Tennessee, with its principal place of business in Collierville, Tennessee. JUSRISDICTION AND VENUE 4. This Court has jurisdiction over the subject matter of this action under 28 U.S.C.

1331 and 1338(a) because this action arises under the patent laws of the United States.

LP 3456425.1 \ 00000-00793

5.

This Court has personal jurisdiction over Premier Glow because Premier Glow

has purposefully availed itself of the privilege of conducting business in this District and has committed acts of infringement in this District. 6. Venue is proper in this District under 28 U.S.C. 1391(c) and 1400(b). INFRINGEMENT OF U.S. PATENT NO. 6,042,487 7. On March 28, 2000, the United States Patent and Trademark Office issued United

States Patent No. 6,042,487 (the 487 patent), entitled Illuminated Golf Ball. A copy of the 487 patent is attached as Exhibit A. Chemical Light is the sole owner of the entire right, title and interest in the 487 patent, including the right to sue for infringement. 8. U.S.C. 287. 9. Premier Glow has infringed and continues to infringe the 487 patent by making, Chemical Light has given notice of its rights under the 487 patent pursuant to 35

using, offering to sell, selling and/or importing into the United States products that infringe one or more of the claims of the 487 patent, including, without limitation, the products advertised and sold as LED Golf Ball Twilight Supernova (Model No. NGS02). Upon information and belief, Premier Glows infringement will continue unless and until enjoined by this Court. 10. On information and belief, Premier Glow has acted and continues to act despite an

objectively high likelihood that its actions constitute infringement of a valid patent and, on information and belief, Premier Glow knew or should have known of that objectively high risk. Accordingly, Premier Glow has infringed willfully or with reckless disregard for Chemical Lights rights. 11. Chemical Light has suffered and will continue to suffer damages as a result of

Premier Glows unlawful infringement of the 487 patent, and Chemical Light is entitled to

recover damages adequate to compensate it for such infringement, but in no event less than a reasonable royalty. 12. Premier Glows acts of infringement have caused and will continue to cause

irreparable harm to Chemical Light unless and until enjoined by this Court. PRAYER FOR RELIEF WHEREFORE, Chemical Light respectfully requests that this Court enter judgment in its favor and against Premier Glow, granting the following relief: A. A judgment declaring that Premier Glow has infringed the 487 patent pursuant to

35 U.S.C. 271; B. An order enjoining Premier Glow and its officers, directors, agents, employees,

parents, subsidiaries, affiliates, and all those acting in concert with any of them from infringing, inducing infringement, or contributing to the infringement of the 487 patent; C. An award of damages as permitted under 35 U.S.C 284 sufficient to compensate

Chemical Light for defendants past infringement and any future infringement, including both compensatory and treble damages for willful infringement, together with prejudgment interest from the date the infringement began; D. A finding that this case is exceptional within the meaning of 35 U.S.C. 285 and

an award to Chemical Light of reasonable attorneys fees, expenses, and costs; E. Such other and further relief as this Court may deem just or proper. JURY DEMAND Chemical Light hereby demands a trial by jury on all issues so triable.

Dated: May 18, 2012

Respectfully submitted, CHEMICAL LIGHT, INC.

By:

/s/ Michael P. Padden One of Its Attorneys

Michael P. Padden (mpadden@lplegal.com) Mitchell J. Weinstein (mweinstein@lplegal.com) Levenfeld Pearlstein, LLC 2 North LaSalle, Ste. 1300 Chicago, IL 60602 T: (312) 346-8380 F: (312) 346-8434