and the Dr LED Polar Star 40 is one single LED that faces up (or down) and a conical/parabolic reflector to project the light 360-degrees. Another issue is color temperature, and I believe this is covered by Dr LED getting approval in the Aqua Signal fixture, and I look at the Owl lights as similar to the function of your garden lights.
Hey at some point this all comes down to common sense and subjective reasonable judgment. You're either visible or not, confusing to others or not, showing good intention or not.