Case KG Doc 257 Filed 11/17/15 Page 1 of 11

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1 Case KG Doc 257 Filed 11/17/15 Page 1 of 11 IN THE UNITED STATES BANKRUPTCY COURT FQR THE DISTRICT OF DELAWARE In re: ) Chapter 11 MALIBU LIGHTING CORPORATION, et al.,l) Case No (KG) Debtors. ) (Jointly Administered) Abjection Deadline: December 1, 4:00 p.m. EST Hearing Date: December 8, 3:00 p.m. MOTION OF DEBTQRS FOR AN QRAER (1) FIXING BAR DATE FOR THE FILING OF FR~QFS 4F CLAIM, INCLUDING CLAIMS ARISING UNDER SECTION SQ3(b)(9) pf THE BANKRUPTCY CODE, (2) FIXING BAR DATE FOR THE FILING OF PROOFS OF CLAIM BY GOVERNMENTAL UNITS, (3) DESIGNATING FORM AND MANNER OF NOTICE THEREOF, AND (4) GRANTING RELATED RELIEF The above-captioned debtors and debtors in possession (the "Debtors") hereby move this Court (the "Motion") for entry of an order, pursuant to sections 501, 502(b)(9), and 503 of title 11 of the United States bode (the "Bankruptcy Code"), Rules 2002(a)(7) and 3003 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rule (e) of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the "Local Rules"): (1) establishing (a) the general bar date by which all entities, except as otherwise provided herein, must file proofs of claim in these chapter 11 cases, and (b) the date by which governmental units must file proofs of claim in these cases; (2) authorizing and approving the form and content of the proposed notice of the proposed Claims Bar Dates (defined below), by mail in substantially the form annexed hereto as Exhibit A I The Debtors, together with the last four digits of each Debtor's tax identification number, are: Malibu Lighting Corporation (0556); Outdoor Direct Corparation f/k/a The Brinkmann Corporation (9246); National Consumer Outdoors Corporation f/k/a Dallas Manufacturing Company, Inc. (1153); Q-Beam Corporation (1560); Smoke `N Pit Corporation (9951); Treasure Sensor Corporation (9938); and Stubbs Collections, Inc. (6615). The location of the Debtors' headquarters and service address is 4215 McEwen Road, Dallas, TX DOCS D6: /005

2 Case KG Doc 257 Filed 11/17/15 Page 2 of 11 and incorporated herein (the "Bar Date Notice") and by publication in substantially the form annexed hereto as Exhibit B (the "Publication Notice"); and (3) granting related relief. In support of the Motion, the Debtors respectfully represent as follows: Jurisdiction 1. The Court has jurisdiction over this Motion pursuant to 28 U.S.C This proceeding is a core proceeding within the meaning of 28 U.S.C. 157(b)(2)(A) and (0). 2. Venue of these proceedings and this Motion is proper in this District pursuant to 28 U.S.C and The statutory predicates for the relief sought herein are sections 501, 502(b)(9) and 503 of the $ankruptcy Code, Bankruptcy Rules 2002(a)(7) and 3003, and Local Rule (e). Background A. General Case Background On October 8, 2015 (the "Petition Date"), the Debtors each filed with this Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code. The Debtors are operating their businesses and managing their properties as debtors and debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 2. No request has been made for the appointment of a trustee or an examiner. On October 20, 2015, the office of the United States Trustee appointed an Official committee of unsecured creditors (the"committee") and initially appointed 5 members thereto. DOCS DE /p05

3 Case KG Doc 257 Filed 11/17/15 Page 3 of 11 The factual background regarding the Debtors, including their current and historical business operations and the events precipitating the chapter 11 filing, is set forth in detail in the Declaration of David M. Baker in Support of First Day Motions [Docket No. 3] (the "First Dav Declaration") and fully incorporated herein by reference.2 4. On November 9, 2015, each Debtor filed its respective schedules of assets and liabilities and its respective statement of financial affairs [Docket Nos ] (collectively, the "Schedules"). B. The Sale and Liquidation of each of the Debtors' Assets 5. There are three distinct creditor bodies for the Debtors: (1) creditors of Debtor Malibu Lighting Corporation ("MLC");(2) creditors of Debtor Outdoor Direct Corporation f/k/a The Brinkmann Corporation ("ODC"); and (3) creditors of Debtor National Consumer Outdoors Corporation f/k/a Dallas Manufacturing Corporation ("NCOC"), along with its Debtor subsidiaries, Q-Beam Corporation, Smoke `N Pit Corporation, Treasure Sensor Corporation, and Stubbs Collections, Inc. Each Debtor is in the process of selling their specific assets, as summarized below. 6. MLC was a manufacturer and supplier of outdoor and landscape lighting products, such as solar and low voltage lights and home security lights, including the parts and accessories associated with these products. On November 4, 2015, the Court entered its Order Pursuant to I1 U.S. G'. ~~ 327 and 328(a), Fed. R. Bcankr. P and 5002 and Local Rule 2 Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the First ]aay Declaration. ROCS DE: /005 Kj

4 Case KG Doc 257 Filed 11/17/15 Page 4 of , Authorizing the Retention and Employment of PipeN.Iaffray and Co. as Investor Banker, Nunc Pro Tunc, to the Petition Date [Docket No. 197] (the"pjc Retention Order") and its Order Pursuant to 11 U.S.C. ~~ 327 and 328(a), Fed.. R. Bankr. P and 5002 and Local Rule , Authorizing Retention and Employment of Hilco IP Service, LLC d/b/a Hilco Streambank as Intellectual Propet~ty Agent far the Debtors, Nunc Pro Tunc to the Petition Date [Docket No. 199] (the "Hilco Retention Order"). The services provided under the PJC Retention Order and Hilco Retention Order include, inter alia,3 the proposed sale of intellectual property and the disposition of the valuable trademarks, patents, copyrights domain names, customer lists and related data and related assets, including tooling, equipment, inventory, accounts receivable and other assets (the "Intellectual Property and Related Assets") owned by ODC and MLC, respectively. In addition the sale of MLC's Intellectual Property and Related Assets, the Debtors expect to shortly file their Motion Pursuant to Sections 1 Q5, 327, 328, 363, 365, and 554 of the Bankruptcy Code for an Order Authorizing: (1) the Employment of Great American Global Partners, LLC as Consultants and Auctioneers; (2) the Assumption of the Consulting/Auction Agreement; (3) the ~'ontinued Liquidation of Obsolete Inventory Outside the Ordinary Course of Business, Including an Auction of Such Inventory; and (4) the Abandonment of any Unsold Inventory (the "Great American Retention"). The Great American Retention seeks, inter alia, to continue to employ Great American Global Partners LLC to sell each of 3 As set forth in the PJC Retention Order, Piper Jaffray & Co. is also the Debtors' investment banker with respect to the sale of NCOC's assets, discussed below. DOCS DE /005

5 Case KG Doc 257 Filed 11/17/15 Page 5 of 11 MLC's and ODC's respective remaining excess and obsolete inventory, which sales began prepetition. 7. ODC was a manufacturer and supplier of a variety of consumer goods, including (a) outdoor cooking products, such as outdoor gas grills, charcoal grills, smokers and fryers, (b) handheld lighting products, such as flashlights and spotlights, (c) landscape lighting products, and (d) parts and accessories associated with the foregoing products. ODC is currently winding down operations through the sales contemplated_ with respect to ODC's Intellectual Property and Related Assets and the sale of ODC's excess and obsolete inventory contemplated under the Great American Retention. 8. NCOC is a leading manufacturer and supplier of both branded and private label pet bedding and pet accessory products. NCOC manufactures beds, accessories, and deodorizers for dogs as well as beds, scratching posts, and toys for cats. In addition, NCOC markets and sells boat covers manufactured primarily from Chinese suppliers. NCOC maintains fulfillment and warehouse facilities totaling approximately 440,000 square feet of warehouse space in Athens, Texas. NCOC also has product development, design, manufacturing, and quality control operations in China. NGOC designs, manufactures, and markets its products through national big box retailers, national and regional discount stores, wholesale clubs, sporting goods stores, drug stores, grocery stores, catalog showrooms, marine outlets, pet distributors, mail-order catalogues, and online retailers. A hearing to consider the sale of substantially all of NCOC's assets is scheduled tq take place on November 19, 2015, pursuant to the Motion of Debtor National Consumer Outdoors Corporation f/k/a Dallas Manufacturing DOCS DE: /005 5

6 Case KG Doc 257 Filed 11/17/15 Page 6 of 11 Company, Inc., for Order (A) Approving Asset Purchase Agreement and Authorizing the Sale of Substantially All of the Debtors' Qperating Assets; (B) Authorizing the Sale of Assets Free and Clear of All Liens, Claims, Rights, Encumbrances, and Other Interests Pursuant to Bankruptcy Code Sections 105, 363(b), 3630 and 343(m); (C) Assuming and Assigning Certain Executory Contracts and Unexpired Leases; and (D) granting Related Relief [Docket No. 18]. Request for Relief 9. By this Motion, the Debtors seek the issuance and entry of an order of this Court, pursuant to Bankruptcy Rule 3003(c) and Local Rule (e), (a) establishing February 8, 2016, at 4:00 p.in. (prevailing Pacific time) as the deadline for filing proofs of claim (the"claims Bar Date") with Kurtzman Carson Consulting, LLC (the"claims A~") for all claims arising prior to the Petition Date, including claims arising under 503(b)(9) of the Bankruptcy Code;4 (b) establishing April 5, 2016, at 4:0~ p.m. (prevailing Pacific time) as the deadline for all governmental units, as defined in section 1 p 1(27) of the Bankruptcy Code, to file claims against the Debtors arising before the Petition Date with the Claims Agent (the "Governmental Unit Bar Date" and, together with the Claims Bar Date, the "Bar Dates") which date is at least 180 days after the Petitipn Date in accordance with Bankruptcy Code 502(b)(9); (c) authorizing and approving the form and content of the proposed notice pf the proposed Claims Bar Dates, by mail in substantially the form annexed hereto as Exhibit A and incorporated herein (the"bar Date Notice") and by publication in substantially the form annexed Pursuant to Local Rule (e), the pebtors are requesting a Claims Bar Date that will allow creditors to receive at least sixty (6Q) days' notice of the bar date. Such notice period is in excess of the twenty one (21) days contemplated in Bankruptcy Rule 2Q02(a)(7). DOCS DE /005

7 Case KG Doc 257 Filed 11/17/15 Page 7 of 11 hereto as Exhibit B (the "Publication Notice"); (d) approving the manner and method of the Debtors' dissemination of the Bar Date Notice to creditors, equity holders, and other interested parties, as set forth in the attached order; (e) requiring that any party filing a proof of claim identify the particular Debtor against which the proof of claim is asserted; and (~ granting the Debtors such other and further relief as is just and proper. 10. The following claims are excepted from the provisions of the Bar Date Order (the "Excepted Claims") and are not required to be filed on or before the Bar Dates: a. claims already duly filed in these Cases with the Claims Agent, or with the Clerk of the Bankruptcy Court for the District of Delaware, 824 North Market Street, 3rd Floor, Wilmington, DE 19801; b. claims listed in the Debtors' Schedules, if the claimant does not dispute the amount or manner in which its claim is listed in the Schedules or the nature of the claim as listed and if such claim is not designated therein as "contingent,""unliquidated," "subject to adjustment," "disputed," or "unknown"(or assigned a zero amount); and c. claims arising on or after the Petition Date. Basis for Relief 11. Bankruptcy Rule 3003(c)(3) provides that the Court "shall fix...the time within which proofs of claim or interest may be filed." Local Rule (e) provides that a request for such bar date may be granted by the Court, without notice or a hearing, on 14 days' notice to the United States Trustee and the Committee, provided that the Schedules have been filed, the Bankruptcy Code 341 meetings have been held, and that the bar date shall be not less DOCS DE /005 7

8 Case KG Doc 257 Filed 11/17/15 Page 8 of 11 than sixty (60) days from the date that the bar date notice is served (and not less than 180 days from the Petition Date for governmental units), all of which are contemplated by this Motion. The Office of the United States Trustee has already conducted and concluded its section 341(a) meeting of creditors on November 10, Furthermore, Bankruptcy Rule 3002(a) provides that an unsecured creditor or an equity security holder must file a proof of claim, except as provided in Bankruptcy Rule Bankruptcy Rule 3003(b), which applies in chapter 11 cases, provides that the schedules filed by a debtor shall constitute prima facie evidence of the validity and the amount of the claims of creditors, unless the claims are scheduled as disputed, contingent, unliquidated or unknown. In other words, no filing of a claim is necessary by a creditor for a claim that appears on the schedules and that is not scheduled as disputed, contingent, unliquidated or unknown by the debtor and to which the debtor is in agreement. 13. Bankruptcy Rule 3003(c)(2), in turn, provides that any creditor or equity security holder whose claim or interest is not listed in the schedules, or is listed as disputed, contingent, unliquidated, or unkngwn, shall file a proof of claim within the time prescribed by subsection (c)(3) of that Bankruptcy Rule, and any such creditor who fails to ale such a proof of claim shall not be treated as a creditor with respect to such claim or interest for the purpose of receiving any distribution from the estate. 14. Prior to the date hereof, creditors and equity security holders may have filed proofs of claim or interest with the Clerk of the Court or the Court-appointed Claims Agent in these cases. In order to avoid the result that creditors file duplicative claims in response to the DOCS DE: /005

9 Case KG Doc 257 Filed 11/17/15 Page 9 of 11 Bar Date Notice to be served by the Debtors, the Debtors hereby propose that creditors who have already filed proofs of claim with the Court or Claims Agent not be required to file a proof of claim a second time. 15. Upon information and belief, the list of creditors that is contained in the Debtors' Schedules and the original matrix of creditors filed at the inception of the case includes the names and addresses of all known creditors and potential creditors of the Debtors, for which there are three distinct creditor bodies set forth above. Based on the disparate nature of these creditor bodies, the Debtors submit that it is in the best interests of the Estates that creditors be required to identify the particular Debtor against whom any proof of claim is asserted. 16. The Debtors intend to serve a copy of the Bar Date Notice on or before December 10, 2015, by U.S. Postal Service first class mail, postage prepaid, on the following parties: (i) all known creditors, (ii) all parties listed on the Debtors' master mailing matrix, (iii) all entities having filed a notice of appearance and demand for papers, (iv) the Debtors' prepetition and postpetition lenders, and (v) the Office of the United States Trustee. The proposed Claims Bar Date of February 8, 2016, is sixty (60) days from the proposed date of service. The proposed Bar Date Notice is attached hereto as Exhibit A. 17. In order to provide broad and appropriate notice to potential creditors, the Debtors propose, pursuant to Fed. R. Bankr. P. 2002(1), to publish notice of the Bar Dates in the national edition of LISA Today or similar paper of national circulation. The Debtors believe that this proposed publication provides more than adequate notice of the $ar Dates to potential unknown holders of claims. The proposed Publication Notice is attached hereto as Exhibit B. DOCS DE /005 D

10 Case KG Doc 257 Filed 11/17/15 Page 10 of 11 Notice 18. Notice of this Motion has been given to the following parties or, in lieu thereof, to their counsel, if known: (a) the Office of the United States Trustee; (b) the Debtors' prepetition and postpetition lenders (c) counsel to the Official Committee of Unsecured Creditors; and (d) any party that has requested notice pursuant to Bankruptcy Rule The Debtors submit that, in light of the nature of the relief requested, no other or further notice need be given. No Prior Repuest 19. No prior application for the relief sought herein has been duly made by the Debtors to this or any other Court. WHEREFORE, the Debtors respectfully request that the Court grant the relief requested herein and issue and enter the affixed order (a) fixing February 8, 2016, as the Claims Bar Date for prepetition claims, including claims arising under 503(b)(9) of the Bankruptcy Code (b) fixing April 5, 2016, as the Governmental Unit Bar Date; (c) authorizing and approving the form and content of the proposed notice of Bar Dates; (d) approving the method and manner of the Debtors' delivery of notice of the establishment of the Bar Dates to creditors ROCS DE /005 1p

11 Case KG Doc 257 Filed 11/17/15 Page 11 of 11 and other parties in interest; (e) and granting the Debtors such other and further relief as this Court deems just, proper and equitable. Dated: November /, 2015 PACHULSKI STANG ZI~HL &JONES LLP Jeffrey N. Pomerantz (CA Bar No ) Maxim B. I~itvak (CA Bar No ) Michael R. Seidl (D~ Bar No. 3889) 919 North Market Street, 17th Floor P.O. Box 87g5 Wilmington, DE Telephone: 302/ Facsimile: 302/ Counsel for the Debtors and Debtors in Possession DOCS DE: /005 11

12 Case KG Doc Filed 11/17/15 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FQR THE DISTRICT QF DELAWARE In re: ) Chapter 11 MALIBU LIGHTING CORPORATION, et al., l) Case No (KG) I)ebtQrs. ) (Jointly Administered) Hearing Date: December 8, 2p1S, at 3:00 p.m. prevailing Eastern time Objection Deadline: December 1, 2p15., at 4:00 p.m. prevailing Eastern time NOTICE QF MQTION OF DEBTpRS FpR AN QRDER (1) FIXING BAR DATE FOR THE FILING OF PRQOFS OF CLAIM, INCLUDING CLAIMS ARISING UNDER SECTIpN 503(b)(9) OF THE BANKRUPTCY CODE, (2) FIXING BAR DATE FpR THE FILING OF PROOFS OF CLAIM BY GOVERNMENTAL UNITS, (3) DESIGNATING FORM AND MANNER OF NOTICE THEREOF, AND (4) GRANTING RELATED RELIEF TO: (a) the Office of the United States Trustee; (b) the Debtors' prepetition and postpetition lenders (c) counsel to the Official Committee of Unsecured Creditors; and (d) any party that has requested notice pursuant t4 Bankruptcy Rule PLEASE TAKE NOTICE that on November 17, 2015, the above-captioned debtors and debtors in possession (the "Debtors") filed the Motion of DebtoNs for an Order (1) Fixing Bar Date for the Filing of Proofs of Claim, Inclu,ding Clazms Arising Under Section 503(b)(9) of the Bankruptcy Code, (2) Fixing Bay Date for the Filing of Proofs of Claim by Governmental Units, (3) Designating form and Manner of Notice Therepf, and (4) Granting Related Relief (the "Motion") with the United States Bankruptcy Court for the District of Delaware, 824 North Market Street, Wilmington, Delaware (the "Bankruptcy Court"). A copy of the Motion is attached hereto. The Debtors, together with the last four digits of each Debtor's tax identification number, are: Malibu Lighting Corporation (0556); Outdoor Direct Corporation f/k/a The Brinkmann Corporation (9246); National Consumer Outdoors Corporation f/k/a Dallas Manufacturing Company, Inc. (1153); Q-Beam Corporation (1560); Smoke `N Pit Corporation (9951); Treasure Sensor Corporation (9938); and Stubbs Collections, Inc. (6615). The location of the Debtors' headquarters and service address is 4215 McEwen Road, I?allas, TX

13 Case KG Doc Filed 11/17/15 Page 2 of 3 PLEASE TAKE FURTHER NOTICE that any response or objection to the entry of an order with respect to the relief sought in the Motion must be filed with the $ankruptcy Court on or before December 1, 2015, at 4:00 p.m. prevailing Eastern time. PLEASE TAKE FURTHER NOTICE that at the same time, you must also serve a copy of the response qr objection upon: (i) counsel to the Debtors: (a) Pachulski Stang Ziehl &Jones LLP, 919 North Market Street, 17th Floor, Wilmington, DE 19801, Attn: Michael R. Seidl, Esq., mseidl@pszjlaw.com, and (b) Pachulski Stang Ziehl &Jones LLP, Santa Monica Blvd., 13th Floor, Los Angeles, California 90067, Attn: Jeffrey N. Pomerantz, jpomerantz@pszjlaw.com; (ii) counsel for Bank of America, N.A. as Agent, Issuer, and Guaranty Agent, (a) Buchanan Ingersoll &Rooney, PC, 919 North Market Street, Suite 1500, Wilmington, DE 19801, Attn: Kathleen A. Murphy, Esq., kathleen.murphy@bipc.com and (b) Bryan Cave LLP, Two North Central Avenue, Suite 2200, Phoenix, AZ, Attn: Robert J. Miller, Esq., rjmiller@bryancave.com and Brian C. Walsh, Esq., bcwalsh@bryancave.com; (iii) Office of the U.S. Trustee, 844 King Street, Suite 2207, Lockbox 35, Wilmington, DE T9801, Attn: Linda Casey, linda.casey@usdoj.gov; and (iv) counsel for Comerica Bank: (a) Jackson Waller L.L.P., 1401 McKinney Street, Suite 1900, Houston, TX 7701 Q, Attn: ~3ruce J. Ruzinsky, Esq., bruzinsky@jw.com, and (b) Buchanan Ingersoll &Rooney PC, 919 North Market Street, Suite 150p, Wilmington, DE Q46, Attn: Peter J. I)uhig, Esq., peter.duhig@bipc.com. PLEASE TAKE FURTHER NOTICE THAT IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT' THE R$LIEF REQUESTED IN THE MOTIQN WITHOUT FURTHER NOTICE OR HEARING. PLEASE TAKE FURTHER NOTICE THAT A HEARING TO CONSIDER THE RELIEF SpUGHT IN THE MOTION WILL BE HELD ON DECEMBER 8, 2015, AT

14 Case KG Doc Filed 11/17/15 Page 3 of 3 3:00 P.M. PREVAILING EASTERN TIME BEFORE THE HONORABLE KEVIN GROSS, UNITED STATES BANKRUPTCY JUDGE, AT THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE, 824 NORTH MARKET STREET, SIXTH FLOOR, COURTROOM 3, WILM1NGTaN, DELAWARE 198Q1. Dated: November/ _ ~, 2015 FACHU SKI STANG ZIEH &JONES ~~ LLP /~~~..--~ Tef rey N. Po ntz (C ~r No ) Maxim B. Litvak (CA Bar No ) Michael R. Seidl (DE Bar No. 3889) 919 North Market Street, 17th Floor P.O. $ox 8705 Wilmington, DE $7Q5 Telephone: 302/ Facsimile: 302/ jpomerantz@pszjlaw.com mlitvak@pszjlaw.com mseidl@pszjlaw.com Counsel to the Debtors and Debtors in Possession

15 Case KG Doc Filed 11/17/15 Page 1 of 4 EXHIBIT A Bar Date Notice DOGS DE /005

16 Case KG Doc Filed 11/17/15 Page 2 of 4 IN THE UNITED STATES BANKRUPTCY GOURT FOR THE DISTRICT QF DELAWARE In re: ) Chapter 11 MALIBU LIGHTING CORPORATION, et a1.,1 ) Case No (KG) Debtors. ) (Jointly Administered) NOTICE OF BAR DATE FOR FILING PROOFS OF CLAIM TO: ALL CREDITORS AND OTHER PARTIES in INTEREST WITH CLAIMS AGAINST THE ABOVE-CAPTIONED DEBTORS: PLEASE TAKE NOTICE that: On October 8, 2015 (the "Petition Date"), each of the above-captioned debtors and debtors in possession (the "Debtors") commenced a chapter 11 case (the "Cases") by filing a voluntary petition for relief under chapter 11 of title 11 of the United States Code (the "Bankruptcy Code") in the United States Bankruptcy Court for the District of Delaware (the "Court"). On December _, 2015, the Court entered an Order (the "Bar Date Order") in the Cases in accordance with Bankruptcy Rule 3003(c) fixing: a. February 8, 2016, at 4:00 p.m. prevailing Pacific time (the "Claims Bar Date") as the last day for the filing of proofs of claim in these Cases for all claims against the Debtors arising prior to the Petition Date), including claims arising under 503(b)(9) of the Bankruptcy Code; and b. April 5, 2016, at 4:00 p.m. prevailing Pacific time (the "Governmental Unit Bar Date") as the last day for all gpvernmental units, as defined in section 101(27) of the Bankruptcy Code, to assert claims arising before the Petition Date. All claims, as defined in section 101(5) of title 11 of the Bankruptcy Code arising before the Petition Date, and claims arising under 503(b)(9) of the Bankruptcy Code, including in each case any claims against the Debtors' estates based on the Debtors' primary, secondary, direct, indirect, fixed, secured, unsecured, contingent, guaranteed, disputed, undisputed, liquidated, unliquidated, matured, unmatured, legal or equitable liability, or otherwise (each a "Claim"), except as otherwise provided for or specifically excepted herein, shall be filed with the claims agent, Kurtzman Carson Consultants, LLC (the "Claims Agent"), in writing, identifying the particular Debtor against whom the claim is asserted, together with supporting documentation, substantially conforming with Official Bankruptcy Form 10 (attached hereto as EXhibit 1), or as otherwise prescribed or authorized under the Bankruptcy Rules, on or before the Claims Bar Date at the following address: 1 The Debtors, together with the last four digits of each Debtor's tax identification number, are: Malibu Lighting Corporation (0556); Outdoor Direct Corpgration f/k/a The Brinkmann Corporation (9246); National Consumer Outdoors Corporation f/k/a Dallas Manufacturing Company, Inc. (1153); Q-Beam Corporation (1560); Smoke `N Pit Corporation (9951); Treasure Sensor Corporation (9938); and Stubbs Collections, Inc. (6615). The location of the Debtors' headquarters and service address is 4215 McEwen Road, Dallas, TX DOCS DE /005

17 Case KG Doc Filed 11/17/15 Page 3 of 4 If by First Class Mail, Hand Delivery or Overnight Mail: Malibu Lighting Corporation Claims Processing Center c/o KCC 2335 Alaska Avenue EI Segundo, CA The following claims are excepted from the provisions of the Bar Date Order (the "Excepted Claims") and are not required to be filed on or before the Claims Bar Date: a. claims already duly filed in these Gases with the Claims Agent, or with the Clerk of the Bankruptcy Court for the District of Delaware, 824 North Market Street, 3rd Floor, Wilmington, DE 19801; b. claims listed in the Debtors' schedules of assets and liabilities and statement of financial affairs [Docket Nos $] (the "Schedules"), if and only if (i) the claimant does not dispute the amount, nature, and priority of its claim as designated in the Schedules, (ii) such claim is not designated in the Schedules as "contingent", "unliquidated", "subject to adjustment," "disputed," or "unknown" (or assigned a zero amount), and (iii) such claimant does not dispute that its claim is an obligation only of the specific Debtor against which the claim is listed in the Schedules; and c. claims arising on or after the Petition Date. Should the Court, in the future, fix a date by which the Excepted Claims must be filed, you will be separately notified. Any proof of Claim required to be filed pursuant to the provisions of the Bar Date Order and not filed on or before the Claims Bar Date or the Gpvernmental Unit Bar Date, as applicable, shall be forever barred from assertion against the Debtors and the property of the Debtors, and the holder of such Claim shall be forever barred from voting pn any plan of reorganization filed in these Cases or participating in any distribution in these Cases, including, but not limited to, any distribution under a confirmed plan. The Debtors' Schedules and/or the Bar Date Order may be examined and inspected by interested parties during regular business hours at the office of the Clerk of the Bankruptcy Court, 824 North Market Street, Wilmington, DE Creditors that wish to rely on the Schedules shall have the responsibility for determining that its Claims are accurately listed therein. Any questions concerning this notice should be directed to the Claims Agent Kurtzman Carson Consultants, LLC by telephone at (864) , from the Kurtzman Carson Consultants, LLC web site at or the pebtors' counsel, Pachulski Stang Ziehl &Jones LLP, 919 North Market Street, 17th Floor, P.O. Box 8705, Wilmin~tQn, DE (Courier 19801) or (302) , Attention: Michael R. Seidl, Esquire. This notice may have been sent inadvertently to persons or entities that may not actually have a Claim against the Debtors. The fact that you have received this notice does not mean that you have a Claim, or that the Debtors or the Bankruptcy Court concede that you have a Claim. 2 DOCS DE: /005

18 Case KG Doc Filed 11/17/15 Page 4 of 4 Dated:, 2015 PACHULSKI STANG ZIEHL &JONES LLP Jeffrey N. Pomerantz (CA Bar No ) Maxim B. Litvak (CA Bar No ) Michael R. Seidl (DE Bar No. 3889) 919 North Market Street, 17th Floor P.O. Box 8705 Wilmington, DE Telephone: 302/ p0 Facsimile: 302/ jpgmerantz@pszjlaw.com mlitvak@pszjlaw.com mseidl@pszjlaw.com Counsel for the Debtors and laebtors in Possession DOCS DE: /005

19 Case KG Doc Filed 11/17/15 Page 1 of 3 EXHIBIT B Publication Notice DOCS DE: /005

20 Case KG Doc Filed 11/17/15 Page 2 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 MALIBU LIGHTING CORPORATION, et al., l) Case No (KG) Debtors. ) (Jointly Administered) NOTICE OF BAR DATES FOR FILING PROOFS OF CLAIM On October 8, 2015, (the"petition Date") each of the above-captioned debtors and debtors in possession (the"debtors") commenced a chapter 11 case (the "Cases") by filing a voluntary petition for relief under chapter 11 of title 11 of the United States Code (the"bankr~tcv Code") in the United States Bankruptcy Court for the District of Delaware (the"court"). On December, 2015, the Court entered an Order (the"bar Date Order") in the Cases in accordance with Bankruptcy Rule 3003(c) fixing: c. February 8, 2016, at 4:00 p.m. prevailing Pacific time (the "Claims Bar Date") as the last day for the filing of proofs of claim in these Cases for all claims against the Debtors arising prior to the Petition Date, including claims arising under 503(b)(9) of the Bankruptcy Code; and d. Apri15, 2016 at 4:00 p.m. prevailing Pacific time (the "Governmental Unit Bar Date") as the last day for all ggvernmental units, as defined in section 101(27) of the Bankruptcy Code, to assert claims arising befgre the Petition Date. All claims, as defined in section 101(5) of title 11 of the Bankruptcy Code, arising before the Petition Date, and claims arising under 503(b)(9) of the Bankruptcy Code, including in each case any claims against the Debtors' estates based on the Debtors' primary, secondary, direct, indirect, fixed, secured, unsecured, contingent, guaranteed, disputed, undisputed, liquidated, unliquidated, matured, unmatured, legal or equitable liability, or otherwise (each a "Claim"), except as otherwise provided for or specifically excepted herein, shall be filed with the claims agent, Kurtzman Carson Consultants, LLC (the "Claims Agent"), in writing, identifying the particular Debtor against whom the claim is asserted, together with supporting dpcumentation, substantially conforming with Official Bankruptcy Form 10, or as otherwise prescribed or authorized under the Bankruptcy Rules, on or before the Claims Bar Date at the following address: 1 The Debtors, together with the last four digits of each Debtor's tax identification number, are: Malibu Lighting Corparation (0556); Outdoor Direct Corporation f/k/a The Brinkmann Corporation (9246); National Consumer Outdoors Corporation f/k/a Dallas Manufacturing Company, Ina (1.153); Q-Beam Corporation (1560); Smoke `N Pit Corporation (9951); Treasure Sensor Corporation (9938); and Stubbs Collections, Inc. (6615). The location of the Debtors' headquarters and service address is 4215 McEwen Road, Dallas, TX DOCS DE: /005

21 Case KG Doc Filed 11/17/15 Page 3 of 3 If by First Class Mail, Hand Delivery or Overnight Mail: Malibu Lighting Corporation Claims Processing Center c/o KCC 2335 Alaska Avenue El Segundo, CA Any proof of Claim required to be filed pursuant to the provisions of the Bar Date Order and not filed on or before the Claims Bar Date or the Governmental Unit Bar Date, as applicable, shall be forever barred from assertion against the Debtors and the property of the Debtors, and the holder of such Claim shall be forever barred from voting on any plan of reorganization filed in these Cases or participating in any distribution in these Cases, including, but not limited to, any distribution under a confirmed plan. Any questions concerning this notice should be directed to the Claims Agent Kurtzman Carson Consultants, LLC by telephone at (866) , from the Kurtzman Carson Consultants, LLC web site at or the Debtors' counsel, Pachulski Stang Ziehl &Jones LLP, 919 North Market Street, 17th Floor, P.O. Box 8705, Wilmington, DE (Courier 19801) or (302) , Attention: Michael R. Seidl, Esquire. Dated:, 2015 PACHULSKI STANG ZIEHL &JONES LLP Jeffrey N. Pomerantz (CA Bar No ) Maxim B. Litvak (CA Bar No ) Michael R. Seidl (DE Bar No. 3889) 919 North Market Street, 17th Floor P.O. Box 8705 Wilmington, DE Q5 Telephone: 302/ Facsimile: 302/ jpomerantz@pszjlaw.com mlitvak@pszj law.com mseidl@pszjlaw.com Counsel for the Debtors and Debtors in Possession DOCS DE: /005

22 Case KG Doc Filed 11/17/15 Page 1 of 4 EX~llblt C Proof of Claim Form DOGS DE: /005

23 Case KG Doc Filed 11/17/15 Page 2 of 4 United States Bankruptcy Court for the District of Delaware Indicate Debtor against which you assert a claim by checking the appropriate box below. (Check only one Debtor ner claim form.) Malibu Lighting Corporation (Case No ) Outdoor Direct Corporation, f/k/a The Brinkmann Corporation (Case No ) National Consumer Outdoors Corporation, f/k/a/ Dallas Manufacturing Company (Case No )' Q-Beam Corporation (Case No ) Smoke'N Pit Corporation (Case No ) Treasure Sensor Corporation (Case No ) Stubbs Collections, Inc.(Case No ) Official Form 410 (Modified) Proof of Claim 12/15 Read the instructions before filling out this form. This form is for making a claim for payment in a bankruptcy case. Do not use this form to make a request for payment of an administrative expense (other than a request for a claim arising under 11 U.S.C. 503(b)(9)) pursuant to the instructions below. All requests for payment of administrative expenses except for claims arising under section 503(b)(9) should be made according to 11 U.S.C Filers must leave out or redact information that is entitled to privacy on this form or on any attached documents. Attach redacted copies or any documents that support the claim, such as promissory notes, purchase orders, invoices, itemized statements of running accounts, contracts, judgments, mortgages, and security agreements. Do not send original documents; they may be destroyed after scanning. If the documents are not available, explain in an attachment. A person who files a fraudulent claim could be fined up to $50Q,pQ0, imprisoned for up to 5 years, or both. 18 U.S.C. 152, 157, and Fill in all the information about the claim as of the date the case was filed. That date is on the notice of bankruptcy (Form 309) that you received. Identify the Claim 1. Who is the current creditor? Name of the current creditor (the person or entity to be paid for this claim) Other names the creditor used with the debtor 2. Has this claim been acquired from No someone else? ~ Yes. From whom? 3. Where should Where se~uld notices to tfte c~recfibar bs sent? Wf~efra sh~utd payments to ttte creditor be sent? (if notices and different} payments to the 'creditor be sent? Name Name Federal Rule of Bankruptcy Procedure Number Street Number Street (FRBP) 2002(g) City State ZIP Gode City ~ State ZIP Code Contact phone Contact Contact phone Contact Uniform claim identifier for electronic payments in chapter 13 (if you use one): 4. Does this claim amend one already ~ No filed? ~ Yes. Claim number on court claims registry (if known) Filed on MM / DD / YYYY 5. Do you know if anyone else has filed ~ No a proof of claim for this claim? [~ Yes. Who made the earlier filing? Official Form 410 Proof of Claim page 1

24 Case KG Doc Filed 11/17/15 Page 3 of 4 Give Information About the Claim as of the Date the Case Was Filed. 6.. Do you have any number No you use to identify the debtor? Yes. Last 4 digits of the debtor's account or any number you use to identify the debtor: 7. How much is the claim? $.Does this amount include interest or other charges? No Yes. Attached statement itemizing interest, fees, expenses, or other charges requires by Bankruptcy Rule 3001(c)(2)(A). 8. What is the basis of the Examples: Goods sold, money loaned, lease, services performed, personal injury or wrongful death, or credit card. claim? Attach redacted copies of any documents supporting the claim required by Bankruptcy Rule 3001(c). Limit disclosing information that is entitled to privacy, such as health care information. 9. is all or part of the claim No secured? Yes. The claim is secured by a lien on property. Nature or property: ~] Real estate: If the claim is secured by the debtor's principle residence, file a Mortgage Proof of Claim Attachment (O~cial Form 410-A) with this Proof of Claim. Motor vehicle Other. Describe: Basis for perfection: Attach redacted copies of documents, if any, that show evidence of perfection of a security interest (for example, a mortgage, lien, certificate of title, financing statement, or other document that shows the lien has been filed or recorded.) Value of property: $ Amount of the claim that is secured: $ Amount of the claim that is unsecured: $ (The sum of the secured and unsecured amount should match the amount in line 7.) Amount necessary to cure any default as of the date of the petition: $ Annual Interest Rate (when case was filed)t% Fixed Variable 10. Is this claim based on a ~ No lease? Yes. Amount necessary to cure any default as of the date of the petition. $ 11. Is this claim subject to a ~ No right of setoff? Yes. Identify the property: Official Form 410 Proof of Claim nanp 7

25 Case KG Doc Filed 11/17/15 Page 4 of Is all or part of the claim entitled to priority under ~ No 11 U.S.C. 507(a)? ~ Yes. Check all that apply: ~0~~ ~~ ~'~ ~4~~ A claim may be partly ~ Domestic support obligations (including alimony and child support) under priority and partly 11 U.S.C. 507(a)(1)(A) or (a)(1)(b). $ nonprio~ity. For example, in some categories, the Up to $2,775" of deposits toward purchase, lease, or rental of property or law limits the amount services for personal, family, or household use. 11 U.S.C. 507(a)(1)(7). $ entitled to priority. Wages, salaries, or commissions (up to $12,475*) earned within 180 days before the bankruptcy petition is filed or the debtor's business ends, $ whichever is earlier. 11 U.S.C. 507(a)(4). Taxes or penalities owed to governmental units. 11 U.S.C. 507(a)(8). $ Contributions to an employee benefit plan. 11 U.S.C. 507(a)(5). $ Other. Specify subsection of 11 U.S.C. 507(a)(_) that applies. $ " Amounts are subject to adjustment of 4/01/16 and every 3 years after that for cases begun on or after the date of adjustment. 13. Is all or part of the claim No pursuant to 71 U.S.C. 503(b)(9)? ~ Yes. Indicate the amount of your claim arising from the value of any goods received by the debtor within 20 days before the date of commencement of the above case, in which the goods have been sold to the Debtor in the ordinary course of such Debtor's business. Attach documentation supporting such claim. Sign Below The person completing Check the appropriate box: this proof of claim must sign and date it. I am the creditor. FRBP 9011(b). If you file this claim ~ ~ am the creditor's attorney or authorized agent. electronically, FRBP 5005(a)(2) authorizes courts ~ I am the trustee, or the debtor, or their authorized agent. Bankruptcy Rule to establish local rules specifying what a signature ~ I am a guarantor, surety, endorser, or other codebtor. Bankruptcy Rule is: A person who files a I understand that an authorized signature on this Proof of Claim serves as an acknowledgement that when calculating the amount of the claim, the creditor gave the debtor credit for any payments received toward the debt. fraudulent claim could be fined up to $500,000, I have examined the information in this Proof of Claim and have reasonable belief that the information is true and correct. imprisoned for uq to 5 years, or both. I declare under penalty of perjury that the foregoing is true and correct. 18 U.S.C. 152, 157, and Executed on date MM / DD / YYYY Signature Print the name of the person who is completing and signing this claim: Name First name Middle name Last name Title Company Identity the corporate servicer aas the company if the authorized agent is a servicer. Address Number Street Contact phone City State ZIP Code Official Form 410 Proof of Claim nano 3

26 Case KG Doc Filed 11/17/15 Page 1 of 6 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 MALIBU LIGHTING CORPORATION, et al., l) Case No (KG) Debtors. ) (Jointly Administered) Re: Docket No. ORDER (1) FIXING BAR DATE FOR THE FILING OF PROOFS OF CLAIM, INCLUDING CLAIMS ARISING UNDER SECTION 503(b)(9) OF THE BANKRUPTCY CODE, (2) FIXING BAR DATE FpR THE FILING OF PROOFS OF CLAIM BY GOVERNMENTAL UNITS, (3) DESIGNATING FORM AND MANNER OF NOTICE THEREOF, AND (4) GRANTING RELATED RELIEF Upon the Motion2 of the above-captioned debtors and debtors in possession (the "Debtors"), seeking the issuance and entry of an order, pursuant to sections 501, 502(b)(9), and 503 of title 11 of the United States Code (the"bankruptcy Code") and Rules 2002 (a)(7) and 3003 of the Federal Rules of Bankruptcy Procedure (the"bankruptc~ules")(i) fixing a bar date for the filing of proofs of claim, including claims arising under 503(b)(9) of the Bankruptcy Code, (ii) fixing a bar date for the filing of proofs of claim by governmental units, as defined in section 101(27) of the Bankruptcy Code, (iii) designating the form and manner of notice thereof, and (iv) granting related relief; and it appearing that the relief sought in the Motion and the entry of this Order is appropriate and necessary in order for the Debtors to determine the nature, scope and classification of all claims; and it appearing that the relief sought 1 The Debtors, together with the last four digits 4f each Debtor's tax identification number, are: Malibu Lighting Corporation (Q556); Outdoor Direct Corporation f/k/a The Brinkmann Corporation (9246); National Consumer Outdoors Corporation f/k/a Dallas Manufacturing Company, Inc. (1153); Q-Beam Corporation (1560); Smoke `N Pit Corporation (9951); Treasure Sensor Corporation (9938); and Stubbs Collections; Inc. (6615). The location of the Debtors' headquarters and service address is 4215 McEwen Road, Dallas, TX Z Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Motion. DOCS DE /005

27 Case KG Doc Filed 11/17/15 Page 2 of 6 in the Motion is reasonable and in the best interests of the Debtors and their estates; and no adverse interest being represented, and sufficient cause appearing therefore, and upon due deliberation given, it is hereby ORDERED, that the Motion is granted as set forth herein; and it is further ORDERED, that all claims, as defined in section 101(5) of title 11 of the United States Code (the"bankruptcy Code"), arising prior to the Petition Date, including claims arising under 503(b)(9) of the Bankruptcy Code, any claims against the Debtors' estates based on the Debtors' primary, secondary, direct, indirect, fixed, secured, unsecured, contingent, guaranteed, disputed, undisputed, liquidated, unliquidated, matured, unmatured, legal or equitable liability, or otherwise (each a "Claim"), except as otherwise provided for or specifically excepted herein, shall be filed with Kurtzman Carson Consultants, LLC (the"claims Agent"), at the office of the Claims Agent or through the electronic claim filing interface available on the Claims Agent's website, in each case as set forth in the Bar Date Notice in writing, identifying the particular Debtor against whom the claim is asserted, together with supporting documentation, substantially conforming with Official Bankruptcy Form 10, or as otherwise prescribed or authorized under the Bankruptcy Rules, so that the proof of Claim is actually received by the Claims Agent on or before 4:00 p.m. prevailing Pacific time on February 8, 2016 (the"claims $ar Date"); and it is further ORDERED, that all governmental units (which shall include all entities defined as such in section 101(27) of the Bankruptcy ~pde, including any such entities that hold a Claim arising from prepetition tax years or periods or prepetition transactions to which a Debtor was a 2

28 Case KG Doc Filed 11/17/15 Page 3 of 6 party) holding or wishing to assert Claims against the Debtors arising before the Petition Date, are required to file a proof of Claim on account of any claims such governmental unit holds or wishes to assert against the Debtors, so that the proof of Claim is actually received by the Claims Agent on or before 4:00 p.m. prevailing Faci~ic Time on April 5, 2016 (the "Governmental Unit Bar Date"); and it is further ORDERED, that the following claims are excepted from the provisions of this Order and are not required to be filed on or before the Claims Bar Date or the Governmental Unit Bar Date, unless otherwise ordered by the Court: a. claims already duly filed in the chapter 11 cases with the Claims Agent or with the Clerk of the Bankruptcy Court for the District of Delaware, 824 North Market Street, 3rd Floor, Wilmington, DE 19801, where such claim is filed in writing, together with supporting documentation, substantially conforming with Official Bankruptcy Form 10 or as otherwise prescribed or authorized under the Bankruptcy Rules; b. claims listed in the debtors' schedules of assets and liabilities and statement of financial affairs [pocket No ] (the "Schedules"), if and only if (i) the claimant does not dispute the amount, nature, and priority of its claim as designated in the Schedules, (ii) such claim is not designated in the Schedules as "contingent,""unliquidated," "subject to adjustment," "disputed," or "unknown"(or assigned a zero amount), and (iii) such claimant does not dispute that its claim is an obligation only of the specific Debtor against which the claim is listed in the Schedules; and c. claims. arising on or after the Petition Date; and it is further

29 Case KG Doc Filed 11/17/15 Page 4 of 6 ORDERED, that the holder of any proof of Claim required to be filed pursuant to the provisions of this Order and not filed on or before the Claims Bar Date or the Governmental Unit Bar Date, as applicable, shall be forever barred and prohibited from assertion against the Debtors, the Debtors' estates and any successor to the Debtors under a confirmed plan of reorganization and/or liquidation or structured dismissal or otherwise (the "Plan"), and the holder of such Claim shall be forever barred and prohibited from voting on any Plan filed in these chapter 11 cases or participating in any distribution in these cases including, but not limited to, any distribution under a confirmed Plan and in a subsequent chapter 7liquidation of the Debtors' estates; and it is further ORDERED, that in the event a claim listed in the Debtors' Schedules is altered as a result of any amendment to the Schedules, the holder of such altered claim shall have until the later of (i) the Bar Date, or (ii) twenty-one (21) days after the Debtors provide notice of the amended Schedules to the holder of the altered claim; and it is further ORDERED, that the following procedures shall apply to the filing of any claim under 503(b)(9) of the Bankruptcy Code ("503~b)(9) Claims Procedures"): a. 503(b)(9) Claimants must use the Claim Form, attached to the Bar Date Notice as exhibit 1, to indicate that a 503(b)(9) Claim is being asserted. As set forth in the Claim Form, each 503(b)(9) Claim against the Debtors must include, with specificity: (i) the amount of the 503(b)(9) Claim; (ii) the particular Debtor against which the 503(b)(9) Claim is asserted; (iii) the date of delivery of the goods the 503(b)(9) Claimant contends the Debtor received within 20 days before the Petition Date; (iv) documentation, including invoices, L'!

30 Case KG Doc Filed 11/17/15 Page 5 of 6 receipts, bills of lading, and the like, identifying the particular goods for which the 503(b)(9) Claim is being asserted; (v) an identification of which goads (if any) were subject to a demand for reclamation asserted under section 546 of the Bankruptcy Code; and (vi) documentation or other evidence that the goods with respect to which the 503(b)(9) Claim is being filed were sold in the ordinary course of the Debtor's business; b. All of the required information shall be sent to the Claims Agent, substantially in the form of the Claim Form, so as to be received on or before the Claims Bar Date; c. Nothing in these 503(b)(9) Claims Procedures shall affect the rights and remedies and/or defenses of the Debtors, claimants or any other party-in-interest with regard to avoidance of any claim or obligation; and it is further ORDERED, that in accordance with Bankruptcy Rule 2002, the Debtors are hereby authorized to cause notice of the Claims Bar Date in a form substantially of that annexed to the Motion as Exhibit A and incorporated herein, which form is hereby approved, to be given by first class mail, postage prepaid, on or before December 10, 2015, upon (i) all known creditors, (ii) all parties listed on the Debtors' master mailing matrix; (iii) all entities having filed a notice of appearance and demand for papers; and (iv) the Office of the United States Trustee; and it is further ORDERED that the Debtors are hereby authorized to cause notice of Claims Bar Date and the Governmental Unit Bar Date in a form substantially of that annexed to the Motion 5