Woodfold MFG v. EMI Porto Opco - Complaint

Case: 1:18-cv-03984 Document #: 1 Filed: 06/07/18 Page 1 of 17 PageID #:1
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
WOODFOLD MFG., INC., an Oregon )

corporation, )
) Civil Action No. 18-cv-3984
Plaintiff, )
)
vs. )
)
EMI PORTA OPCO, LLC, an Illinois ) JURY TRIAL DEMANDED
limited liability company, )
)
Defendant. )
COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Woodfold Mfg., Inc. (“Woodfold”), for its Complaint against Defendant EMI
Porta OPCO, LLC (“EMI Porta”) hereby alleges as follows:
NATURE OF THE ACTION

1. This is an action for patent infringement arising under the patent laws of the
United States, including 35 U.S.C. §§ 271, 281-285, and 289.
2. This lawsuit pertains to EMI Porta’s infringement of Woodfold’s U.S. Patent Nos.
9,879,471 and D792,190 (collectively, the “Woodfold Patents”). Collectively, these patents
protect Woodfold’s unique and inventive design for accordion-style doors that are widely used as
gates in residential elevators.
3. Woodfold seeks injunctive relief and damages against Defendant.
THE PARTIES
4. Plaintiff Woodfold is a corporation organized and existing under the laws of the
State of Oregon, with its principal place of business at 1811 18th Avenue, Forest Grove, Oregon.
Woodfold owns the Woodfold Patents.
SCHWABE, WILLIAMSON & WYATT, P.C.

Page 1 - Attorneys at Law
1211 SW 5th Ave., Suite 1900
Portland, OR 97204
Telephone: 503.222.9981
Fax: 503.796.2900
4051752
5. Defendant EMI Porta is an Illinois limited liability company having a principal
place of business at 250 Hamilton Road, Arlington Heights, Illinois. Defendant EMI Porta
manufactures and sells elevator equipment and elevator components, including accordion type
folding doors used in the residential elevator industry.
JURISDICTION AND VENUE

6. Woodfold’s cause of action for patent infringement against EMI Porta arises
under the patent laws of the United States, 35 U.S.C. § 101 et seq., including §§ 271, 281-285,
and 289. This Court has original jurisdiction over this subject matter pursuant to 28 U.S.C.
§§ 1331 and 1338(a).
7. This Court has personal jurisdiction over EMI Porta because it resides in the State
of Illinois; regularly conducts business in the State of Illinois; and continues to commit acts of
patent infringement in the State of Illinois including by making, using, offering to sell, and/or
selling infringing products within the State of Illinois and this district.
8. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b) and (c),
and 1400(b).
FACTS
Woodfold’s Patented Technology
9. Woodfold is a leading innovator in the residential elevator industry. Founded in
1957, Woodfold has grown into one of the nation’s leading suppliers of custom-crafted
accordion doors, roll-up doors, hardwood shutters, and other products for both residential and
commercial installations.
10. Woodfold offers the highest quality and most reliable residential elevator
accordion type gate on the market. Woodfold’s patented product is the first accordion type
elevator gate that satisfies the strength and deflection requirements of ASME 17.1-2016/CSA
B44-16—the safety standard for elevators and escalators.

Portland, OR 97204
Telephone: 503.222.9981
Fax: 503.796.2900
4051752
11. Woodfold owns all right, title, and interest in U.S. Patent No. 9,879,471 (the
“’471 Patent”), entitled “Reinforced Folding Door and Hinge Assembly,” which was duly and
legally issued to Woodfold by the United States Patent and Trademark Office on January 30,
2018. The ’471 Patent is directed to an accordion type folding door comprising an assembly of
vertically arranged panels placed side-by-side and suspended from a suitable track. Figures 1
and 9 of the ’471 Patent depict an accordion-type folding door system, as shown below. A true
and correct copy of the ’471 patent is attached hereto as Exhibit A.
12. Claim 1 recites:
1. An accordion type folding door system comprising
a plurality of adjacent panels arranged vertically and side-by-side, each panel
including a top end having an upper margin, and a bottom end having a
lower margin;
a hinge assembly disposed between and interconnecting a pair of adjacent panels,
each of the pair of adjacent panels including a side edge having
longitudinal groove and an extension flange,

wherein the hinge assembly comprises
a hinge pin,
a plurality of hinge knuckles disposed vertically end-to-end in an
alternating arrangement on the hinge pin, at least one of the hinge knuckles
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comprising a tubular central opening for accepting the hinge pin, an
outwardly extending tongue for connecting to a corresponding longitudinal
groove in an adjacent panel in a tongue and groove connection, and an
outwardly flared wedge that extends between and beyond the extension
flanges of the panels, whereby the wedge cooperates with, and respective
outer surfaces of the wedge directly contact, the extension flanges to limit
angular un-folding extension of the pair of adjacent panels to a maximum
desired angle.
13. Woodfold owns all right, title, and interest in U.S. Patent No. D792,190 (the
“D’190 Patent”), entitled “Hinge Knuckle for Folding Door Assembly,” which was duly and
legally issued to Woodfold by the United States Patent and Trademark Office on July 18, 2017.
The D’190 Patent has a single claim that covers the ornamental design for a hinge knuckle for
folding door assembly, as shown and described in the D’190 Patent’s figures. Figure 1, shown
below, depicts the front portion of a hinge knuckle for folding door assembly.

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14. Figure 6 shows a top plan view:
15. A true and correct copy of the D’190 patent is attached hereto as Exhibit B.
EMI Porta’s Infringing Products
16. EMI Porta manufactures residential accordion gates, power gate operators,
controllers, electromechanical interlocks, and other fixtures.
17. EMI Porta sells, or has offered for sale, a folding door and hinge assembly that
utilizes the technology claimed and taught in the ’471 Patent.

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18. For example, EMI Porta sells an accordion folding door system comprising a
plurality of adjacent panels arranged vertically and side-by-side, each panel including a top end
having an upper margin, and a bottom end having a lower margin:

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19. EMI Porta’s products have a hinge assembly disposed between and
interconnecting a pair of adjacent panels, each of the pair of adjacent panels including a side
edge having longitudinal groove and an extension flange:
Longitudinal Grooves
Hinge Pins
(concealed under rivet)
Extension Flanges
20. As shown in the image above, EMI Porta’s products also have a hinge assembly
comprising a hinge pin, and the hinge knuckles have a tubular opening for accepting the hinge
pin.

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21. EMI Porta’s products have a plurality of hinge knuckles disposed vertically end-
to-end in an alternating arrangement on the hinge pin:

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22. Additionally, the hinge knuckles comprise an outwardly extending tongue for
connecting to a corresponding longitudinal groove in an adjacent panel in a tongue and groove
connection, and an outwardly flared wedge that extends between and beyond the extension
flanges of the panels.
Tongue / Tongue and
Groove Connection
(concealed)
Wedge

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23. In EMI Porta’s products, the wedge cooperates with, and respective outer surfaces
of the wedge directly contact, the extension flanges to limit angular un-folding extension of the
pair of adjacent panels to a maximum desired angle:
Limited Angular
Unfolding
Extension Flange

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24. EMI Porta also sells, or has offered for sale, a hinge knuckle for folding door
assembly that utilizes certain of the patented ornamental features in the D’190 Patent, as shown
below:
Hinge Knuckle
25. Woodfold, suspecting that EMI Porta’s product infringed the ’471 Patent and the
D’190 Patent, promptly notified EMI Porta of the patents and the infringement on February 12,
2018.
26. Upon information and belief, EMI Porta has continued to sell the infringing
products, willfully disregarding Woodfold’s rights in the Woodfold Patents.

Portland, OR 97204
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Fax: 503.796.2900
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COUNT 1 – INFRINGEMENT OF THE ’471 PATENT

27. Woodfold restates and realleges each of the allegations, photographs, and figures
of paragraphs 1 through 26 as if fully set forth herein.
28. EMI Porta is aware of the ’471 Patent and is manufacturing or importing into,
using, selling and/or offering for sale folding doors and hinge assemblies that practice the ’471
Patent.
29. EMI Porta has been, and presently is, directly infringing the ’471 Patent, literally
or under the doctrine of equivalents, within this judicial district by manufacturing or importing
into, using, selling, and/or offering for sale folding door and hinge assemblies that embody the
patented invention disclosed in the ’471 Patent, in violation of 35 U.S.C. § 271.
30. EMI Porta is not licensed or otherwise authorized by Woodfold to make, use,
import, sell, or offer to sell any product with folding door and hinge assemblies covered by the
’471 Patent and its conduct is, in every instance, without Woodfold’s consent.
31. Woodfold is entitled to recover from EMI Porta the damages it has sustained as a
result of EMI Porta’s wrongful acts in an amount subject to proof at trial, and in any event not
less than a reasonable royalty, together with interest and costs as fixed by this Court under 35
U.S.C. § 284.
32. The infringement by EMI Porta of the ’471 Patent will continue to cause
Woodfold irreparable injury and damage for which there is no adequate remedy at law unless
and until EMI Porta is enjoined from infringing the ’471 Patent.
33. EMI Porta’s infringement of the ’471 Patent has been and continues to be willful
in light of its knowledge of the ’471 Patent since at least February 2018. Accordingly, this is an
exceptional case under 35 U.S.C. § 285 and Woodfold is entitled to enhanced damages,
attorneys’ fees, and litigation expenses incurred.

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COUNT 2 – INFRINGEMENT OF THE D’190 PATENT

34. Woodfold restates and realleges each of the allegations, photographs, and figures
of paragraphs 1 through 33 as if fully set forth herein.
35. EMI Porta has been, and presently is, infringing the D’190 Patent within this
judicial district by manufacturing or importing into, using, selling, and/or offering for sale hinge
knuckles for folding door assemblies that embody the patented invention disclosed in the D’190
Patent, in violation of 35 U.S.C. §§ 271 and 289.
36. EMI Porta is not licensed or otherwise authorized by Woodfold to make, use,
import, sell, or offer to sell any hinge knuckles for folding door assembly covered by the D’190
Patent and its conduct is, in every instance, without Woodfold’s consent.
37. The design of EMI Porta’s hinge knuckles for folding door assembly so closely
resemble the invention disclosed in the D’190 Patent that an ordinary observer would be
deceived into purchasing EMI Porta’s hinge knuckles in the mistaken belief that it includes the
invention disclosed in the D’190 Patent.
38. EMI Porta will continue to manufacture and sell its hinge knuckles unless
enjoined by this Court.
39. Due to EMI Porta’s infringement of the D’190 Patent, Woodfold is entitled to
recover from EMI Porta damages adequate to compensate for the infringement in an amount
subject to proof at trial, but in no event less than a reasonable royalty, together with interest and
costs as fixed by this Court under 35 U.S.C. § 284. Alternatively, Woodfold is entitled to
recover EMI Porta’s total profits from the sale of its product under 35 U.S.C. § 289.
40. Due to EMI Porta’s infringement of the D’190 Patent, Woodfold has suffered, is
suffering, and will continue to suffer irreparable injury and damage for which Woodfold has no
adequate remedy at law. Woodfold is therefore entitled to a permanent injunction against EMI
Porta’s further infringing conduct.

Portland, OR 97204
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Fax: 503.796.2900
4051752
41. EMI Porta’s infringement of the D’190 Patent has been and continues to be
willful in light of its knowledge of the D’190 Patent since at least February 2018. Accordingly,
this is an exceptional case under 35 U.S.C. § 285 and Woodfold is entitled to enhanced damages,
attorneys’ fees, and litigation expenses incurred.

Portland, OR 97204
Telephone: 503.222.9981
Fax: 503.796.2900
4051752
PRAYER FOR RELIEF

WHEREFORE, Woodfold respectfully requests that the Court enter judgement in its
favor against Defendant EMI Porta, granting the following relief:
A. A judgment that EMI Porta has infringed the Woodfold Patents literally and/or
under the doctrine of equivalents;
B. Preliminary and permanent injunctions pursuant to 35 U.S.C. § 283, enjoining
EMI Porta and its agents, servants, officers, directors, employees, affiliated entities and all
persons in active concern or participation with them from continued infringement of the
Woodfold Patents;
C. An award of damages adequate to compensate Woodfold for EMI Porta’s
infringement of the ’471 Patent, in an amount no less than a reasonable royalty for the use made
of the invention disclosed in the Woodfold Patents by EMI Porta, together with interest and costs
as fixed by the Court, pursuant to 35 U.S.C. § 284;
D. An award to Woodfold equal to EMI Porta’s total profits from the sale of its
products pursuant to 35 U.S.C. § 289;
E. Enhancement of the damage award based on EMI Porta’s willful infringement of
the Woodfold Patents.
F. An award of attorneys’ fees pursuant to 35 U.S.C. § 285; and
G. Such other relief as this Court deems to be just and equitable.
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Portland, OR 97204
Telephone: 503.222.9981
Fax: 503.796.2900
4051752
DEMAND FOR JURY TRIAL

Pursuant to Fed. R. Civ. P. 38(b), Woodfold respectfully requests a trial by jury of all
issues so triable.
Dated this 7th day of June, 2018.

Respectfully submitted,
SHOOK HARDY & BACON
By: /s/ Lynn H. Murray

Lynn H. Murray, Illinois Bar #6191802
Email: lhmurray@shb.com
111 South Wacker Drive, Suite 5100
Chicago, IL 60606
Telephone: 312.704.7700
Facsimile: 312.558.1195
By: /s/ Nicholas F. Aldrich

Nicholas F. Aldrich, pro hac vice pending
Email: naldrich@schwabe.com
Angela E. Addae, pro hac vice pending
Email: aaddae@schwabe.com
1211 SW 5th Avenue, Suite 1900
Portland, OR 97204
Telephone: 503.222.9981
Facsimile: 503.796.2900
Of Attorneys for Plaintiff

Portland, OR 97204
Telephone: 503.222.9981
Fax: 503.796.2900
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CERTIFICATE OF SERVICE
I hereby certify that on June 7, 2018, I electronically filed the foregoing document to the
Clerk of the United States District Court using the CM/ECF system for filing and service to all
parties/counsel registered to received copies in this case.
/s/ Lynn H. Murray

Lynn H. Murray

Attorneys at Law
Portland, OR 97204
Telephone: 503.222.9981
Fax: 503.796.2900
4051752
Case: 1:18-cv-03984 Document #: 1-1 Filed: 06/07/18 Page 1 of 19 PageID #:18
Exhibit A
IIIIII IIIIIIII Ill lllll lllll lllll lllll lllll lllll lllll lllll 111111111111111111
US0098794 71B2
c12) United States Patent (IO) Patent No.: US 9,879,471 B2

Lewis et al. (45) Date of Patent: Jan.30,2018
(54) REINFORCED FOLDING DOOR AND HINGE (56) References Cited

ASSEMBLY
U.S. PATENT DOCUMENTS
(71) Applicant: Woodfold Mfg., Inc., Forest Grove, OR
(US)
1,463,346 A * 7/1923 Walker .................... E06B 3/481
16/DIG. 31
3,131,753 A * 5/1964 Dixon ..................... E06B 3/481
(72) Inventors: Mark F. Lewis, Portland, OR (US); 16/225
Rick Scott Alvarado, Gaston, OR (US) (Continued)
(73) Assignee: WOODFOLD MFG., INC., Forest
Grove, OR (US) OTHER PUBLICATIONS
Lewis, "Hinge Knuckle for Folding Door Assembly", U.S. Appl.
( *) Notice: Subject to any disclaimer, the term ofthis No. 29/568,458, filed Jun. 17, 2016.
patent is extended or adjusted under 35
(Continued)
U.S.C. 154(b) by O days.
Primary Examiner - Katherine W Mitchell
(21) Appl. No.: 15/171,478
Assistant Examiner - Abe Massad
(22) Filed: Jun. 2, 2016 (74) Attorney, Agent, or Firm - Stoel Rives LLP
(57) ABSTRACT
(65) Prior Publication Data
An accordion type folding door system having a plurality of
US 2017/0089122 Al Mar. 30, 2017 elongated panels hinged together along their longitudinal
side edges into a pleated or zig zag arrangement, the folding
Related U.S. Application Data panels being interconnected by a hinge assembly. The hinge
assembly is disposed between and interconnects a pair of
(60) Provisional application No. 62/235,455, filed on Sep. adjacent panels, each of the pair of interconnected adjacent
30, 2015. panels including a side edge having longitudinal groove and
an extension flange, wherein the hinge assembly includes a
(51) Int. Cl. hinge pin and a plurality of hinge knuckles disposed verti-
E05D 3/02 (2006.01) cally end-to-end in alternating arrangement on the hinge pin,
E06B 3/48 (2006.01) the hinge knuckle having a tubular central opening for
E05D 15/26 (2006.01) accepting the hinge pin, an outwardly extending tongue for
(52) U.S. Cl. connecting to a corresponding longitudinal groove in an
CPC ................ E06B 3/481 (2013.01); E05D 3/02 adjacent panel in a tongue and groove connection, and an
(2013.01); E05D 15/26 (2013.01); E05Y outwardly flared wedge that extends beyond the extension
2900/132 (2013.01) flanges of the panels, whereby the wedge cooperates with
(58) Field of Classification Search the extension flanges to limit angular folding extension to a
CPC .. E06B 3/481; E04D 3/02; E04D 3/04; E04D maximum desired angle.
15/26; E04D 11/06
See application file for complete search history. 7 Claims, 11 Drawing Sheets
Exhibit A
Page 1 of 18
US 9,879,471 B2
Page 2
(56) References Cited D496,248 S 9/2004 Liebendorfer

D520,862 S 5/2006 Munson
U.S. PATENT DOCUMENTS 7,290,581B2 11/2007 Lee
D562,108 S 2/2008 Pester
3,901,302 A * 8/1975 Dagenais .................. E05D 3/02 8,191,603Bl 6/2012 Motosko
16/263 D680,419 S 4/2013 Green
3,913,171 A * 10/1975 Reid E05F 5/06 8,960,257B2 2/2015 Goodman
16/342 D729,605 S 5/2015 Ramey
4,222,428 A * D731,296 S 6/2015 Nelson
9/1980 Scherer ..................... E05D 1/02
D732,703 S 6/2015 Kreutzman
160/231.1
4,387,760 A * 2005/0063058 Al 3/2005 Langley
6/1983 Greschbach .............. E05D 1/04
2011/0155145 Al 6/2011 Chua
160/199
2012/0124776 Al* 5/2012 McDonnell ............. E05D 11/06
4,922,987 A 5/1990 Marontate et al.
4,998,941 A * 3/1991 Smith ..................... E05D 11/06 16/375
16/374 2014/0367056 Al 12/2014 Miller
5,150,501 A 9/1992 Pasternak
5,472,037 A 12/1995 Hoffman OTHER PUBLICATIONS
D370,839 S 6/1996 Harris
5,549,148 A 8/1996 Figueiredo et al.
Notice of Allowance from Lewis et al. U.S. Appl. No. 29/568,458,
D402,536 S 12/1998 Cousins
D411,434 S 6/1999 Russell dated Apr. 14, 2017, 11 pages.
6,669,272 B2 * 12/2003 Ayabe .................... B60J 5/0487
180/89.12 * cited by examiner
Exhibit A
Page 2 of 18
U.S. Patent Jan.30,2018 Sheet 1 of 11 US 9,879,471 B2
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US 9,879,471 B2
1 2
REINFORCED FOLDING DOOR AND HINGE FIG.14 is a partial cross-sectional view ofa portion of the
ASSEMBLY folding door assembly of FIG. 1, on an enlarged scale, with
an alternate hinge knuckle unit.
RELATED APPLICATION DATA FIG. 15 is a top end plan view of the hinge knuckle unit
5 of FIG. 14
This application claims priority under 35 U.S.C. § 119(e) FIG. 16 is a top diagrammatic view of an eight panel
to U.S. Provisional Application No. 62/235,455 filed on Sep. folding door assembly.
30, 2015, hereby incorporated by reference. FIG. 17 is a top diagrammatic view of a nine panel folding
door assembly.
BACKGROUND 10 FIG. 18 is a diagrammatic view of a hinge knuckle
arrangement for a folding door assembly according to an
The field of the present invention is directed to folding embodiment.
doors such as used for closets, elevators and room entrances. Additional aspects and advantages will be apparent from
An accordion type folding door comprises an assembly of the following detailed description of preferred embodi-
15 ments, which proceeds with reference to the accompanying
vertically arranged panels placed side-by-side and sus-
drawings.
pended from a suitable track. The adjacent side edges of the
panels are interconnected by sheet vinyl plastic hinges. DETAILED DESCRIPTION OF PREFERRED
Alternately, the vinyl plastic hinges may be replaced as EMBODIMENTS
described in U.S. Pat. No. 4,922,987 with hinging assem- 20
blies that interconnect the panels, the hinging assemblies Preferred embodiments will now be described with ref-
comprising a plurality of knuckles made of hard durable erence to the drawings. To facilitate description, any element
material (plastic or metal) and tongue and groove means for numeral representing an element in one figure will represent
attachment of the knuckles to the side margins of the the same element in any other figure. The preferred embodi-
adjacent panels in an alternating arrangement, i.e., with 25 ments will describe a particular folding door, but it will be
alternate knuckles attached to the same panel, with a hinge appreciated that details of the system may be applied in other
pin made of steel or other stout material received in the forms such as folding wall sections or the like.
knuckles. Though this design with the interconnection FIGS. 1-3 illustrate an accordion type folding door system
exhibits higher strength over the prior vinyl plastic hinge, 5 according to a first embodiment. Certain features of the
the present inventor(s) have recognized potential for addi- 30 folding door system 5 are similar to those described in U.S.
tional improvement. Pat. No. 4,922,987 hereby incorporated by reference. The
folding door system 5 comprises a plurality of elongated
BRIEF DESCRIPTION OF THE DRAWINGS panels 10 hinged together along their longitudinal side edges
into the illustrated pleated or zig zag arrangement. Four
FIG. 1 is an isometric view of a top portion of a folding 35 panels 10, 10a, 10b, 10c are illustrated in FIG. 1, but there
door assembly in an extended or closed position. may be any suitable plurality of panels, two or more. The
FIG. 2 is a cross-sectional view of the folding door panels 10, lOa, lOb, 10c may comprise any suitable struc-
assembly of FIG. 1 taken along line 2-2. tural material, such as wood, particle board, clear or opaque
FIG. 3 is a partial cross-sectional view of a portion of the plastic, or metal.
folding door assembly of FIG. 1 taken along line 3-3, on an 40 Panels 10, 10a, 10b, 10c are suitably framed, in part by
enlarged scale. cap pieces 12, 12a, 12b, 12c mounted on the top and bottom
FIG. 4 is a partial cross-sectional view, similar to FIG. 3, edges of each panel. The cap pieces 12, 12a, 12b, 12c may
but with the door in a folded or open position. be channel-shaped (in cross-section) and receive the top and
FIG. 5 is a perspective view of a hinge knuckle unit of the bottom margins of the respective panels 10, 10a, 10b, 10c In
folding door assembly of FIG. 1. 45 the first embodiment, the cap pieces 12, 12a, 12b, 12c are
FIG. 6 is a top end plan view of the hinge knuckle unit of hinged together, hinges 13a, 13b, 13c connecting an adja-
FIG. 5 showing example dimensions. cent pair of cap pieces. For example, the hinge 13a connects
FIG. 7 is an isometric view of the bottom connection of the cap piece 12a to the cap piece 12, the hinge 13b connects
the folding door assembly of FIG. 1. the cap piece 12 to the cap piece 12b, and the hinge 13c
FIG. 8 is an isometric view of the retainer screw shown 50 connects the cap piece 12b to the cap piece 12c. The hinges
in FIG. 7. 13a, 13b, 13c are capped at the bottom and do not extend
FIG. 9 is a full length isometric view of a four panel into the central hinge mechanisms described below. Such a
folding door assembly. construction may help prevent binding of adjacent cap
FIG. 10 is a top diagrammatic view of the four panel pieces when folding.
folding door assembly of FIG. 9 in the closed, un-folded, 55 The central segments of cap pieces 12, 12a, 12b, 12c are
extended position. provided with openings 16. These openings provide means
FIG. lOA is a top diagrammatic view of the four panel for mounting roller assemblies 18a, 18b, on selected panels
folding door assembly of FIG. 10 in the open, folded, (in the panel 10 and the panel 10c), by which the folding
contracted position door system 5 is suspended on a ceiling track, not illustrated
FIG. 11 is a front side perspective view of the slide plate 60 but of conventional construction. The ceiling track is
section of the folding door assembly of FIG. 9, on an mounted across the entrance of the space to be closed off by
enlarged scale. the folding door system 5.
FIG. 12 is a left side perspective view of the slide plate The panels 10, 10a, 10b, 10c each includes longitudinal
section of FIG. 11. side framing members along panel side edges. Specifically,
FIG. 13 is a front side perspective view of the slide post 65 the panel 10 includes longitudinal side framing members
section of the folding door assembly of FIG. 9, on an 20a, 20b; the panel 10a includes longitudinal side framing
enlarged scale. member 20c (the other side framing member not shown); the
Exhibit A
Page 14 of 18
US 9,879,471 B2
3 4
panel lOb includes longitudinal side framing members 20d, suitable plastics, metals, or combinations. The PVC plastic
20e; and the panel 10c includes longitudinal side framing may be formed in a desired color to match the panels
member 20/ (the other side framing member not shown). sections for enhancing aesthetics. The hinge knuckle 30a is
FIG. 2 is a cross section of FIG. 1 illustrating a portion of provided with a cylindrical central section 37a forming a
the hinge connections, three of the panels 10, 10a, 10b 5 central opening 32a and a longitudinally extending tongue
showing example construction. Each side framing member 34a terminating in a bead 36a that nests within the longi-
20a-d may comprise a metal strip having the cross section as tudinally extending groove 24a. The hinge knuckle 30a also
illustrated in FIG. 2. Each side framing member is shaped has an outwardly flared wedge section 35a that extends
with an inner side margin provided with a respective lon- beyond the flanges 26a, 26c.
gitudinal recess or groove 22a-d. The outer side margin of 10
The tongue 34a of the hinge knuckle 30a with the
each panel 10, 10a or 10b may be dimensioned to fit into
associated bead 36a cooperates with the longitudinally
respective groove 22a-d, along with a quantity of adhesive
extending groove 24a on the framing member 20a and a
for securing the panel into the groove.
Each side framing member 20a-d is also provided along tongue 34b of the hinge knuckle 30b with an associated bead
its outer margin with a respective longitudinally extending 15 36b cooperates with the longitudinal extending groove 24c,
groove 24a, 24b, 24c, 24d. Each of the side framing mem- thereby collectively forming tongue and groove connections
bers 20a-d is also provided, along its sides, with a respective by means of which the hinge knuckles 30a, 30b, etc. are
pair of longitudinally extending flanges. Framing member coupled to framing members 20a, 20c, in alternating posi-
20a has extending flanges 26a, 28a, framing member 20b tions/orientations. In other words, direction and connection
has extending flanges 26b, 28b, framing member 20c has 20 of the beads will be arranged in an alternating fashion with
extending flanges 26c, 28c, and framing member 20d has one hinge knuckle connecting to a panel on one side and the
extending flanges 26d, 28d. These flanges serve to shield the next/adjacent hinge knuckle (above and below) connecting
mechanism of the central hinge system by means of which to the panel on the other side, thus forming the central hinge
two adjacent panels are coupled together in hinging relation. assembly of the hinge system. The beads 36a, 36b may be
Top hinges 13a, 13b, 13c provide the structural support 25 round rod shape (as illustrated) seating within the respective
for the door structure, by means of which the panels are longitudinally extending grooves 24a, 24c that may be
hinged to each other in the desired configuration. A second round, cylindrical shape, or the beads 36a, 36b may be other
hinging connection is provided by the central hinge system suitable shape such as T-shaped, disposed in a suitably-
that may extend about the full length of the panels, from top shaped groove.
to bottom. 30 Though any number of hinge knuckle units, two or more,
In addition to providing a hinging function, the central may serve the central hinge assembly function, multiple
hinging system may serve a barrier function, sealing off the hinge knuckle units may provide advantages of strength and
space between adjacent panels in such a manner as to visibility blockage. As an example, for a typical height door
prevent access to the area behind the door. The central of781/s inches, seven full length (e.g., 10 inch long) hinge
hinging system between adjacent framing members 20a, 20c 35 knuckles (arranged in alternating directions) may be stacked
of panels 10, 10a includes a plurality of hinge knuckles 30a, with a first partial length (e.g., 4 inch long) hinge knuckle on
30b, etc. and the central hinging system between adjacent the top and a second partial length (4 inch long) hinge
framing members of panels 10, 10b includes a plurality of knuckle (e.g. hinge knuckle 30x) on the bottom. FIG. 18
hinge knuckles 31a, 31b, etc. The hinge knuckle 30a illustrates an example hinge knuckle assembly 100 arrange-
includes an outwardly flared wedge section 35a and the 40 ment with eight full length (10 inch long) hinge knuckles
hinge knuckle 30b disposed below the hinge knuckle 30a 30a, 30b, 30c, 30d, 30e, 30/, 30g, 30h) arranged in alter-
also includes an outwardly flared wedge section (not vis- nating directions stacked with a first partial length (4 inch
ible). A similar plurality of hinge knuckles 31a, 31b are long) hinge knuckle 30x on the bottom and a second partial
shown in FIG. 2 between adjacent framing members 20b, length (4 inch long) hinge knuckle 30y on the top, aligned
20d of panels 10, 10b. The hinge knuckle 31a includes an 45 and secured together by pin/post 33a. Other sizes (and
outwardly flared wedge section 35b and the hinge knuckle numbers) of hinge knuckle units may be employed.
31b disposed below the hinge knuckle 31b also includes an As previously mentioned, the hinge knuckle 30a may
outwardly flared wedge section (not visible) Further details include an outwardly flared wedge section 35a that extends
of the central hinging systems will now be described with beyond the flanges 26a, 26c. The wedge section 35a coop-
respect to just one of the connections with reference to 50 erates with the flanges 26a, 26c (the flanges 26a, 26c
FIGS. 3-7 and 18 but the description equally applies to the contacting respective outer surfaces of the wedge section
other connections and panels in the folding door system 5. 35a) thereby limiting the minimum size of gap Gl and
As shown particularly in FIGS. 2-5, the central hinge limiting the maximum angle Bl (see FIG. 3) that the folding
assembly comprises a plurality of hinge knuckles 30a, 30b door sections may extend to an angle Bl of about 110°. By
disposed end to end between each pair of adjacent framing 55 limiting the angular un-folding extension to a desired maxi-
members 20a, 20c, and a hinge pin 33a received within the mum angle, and providing limiting resistance along the
central tubular openings of the knuckles (an opening 32a in entire length of the door via operation of the wedge sections,
hinge knuckle 30a is shown). Similarly as shown in FIG. 2, the strength of the folding door assembly to resist horizontal
another central hinge assembly comprises a plurality of pressure is enhanced. The wedge section 35a (of the hinge
hinge knuckles 31a, 31b disposed end to end between a pair 60 knuckle 30a) may be flared or pie-shaped as illustrated, or
of adjacent framing members 20b, 20d, and a hinge pin 33b may alternately be square, rectangular, with curved sides or
received within the central tubular openings of the knuckles other suitable shape.
(an opening 32b in hinge knuckle 31a is shown). While FIG. 3 illustrates folding door sections in a maxi-
FIG. 5 illustrates an example hinge knuckle 30a. The mum closed or un-folded position, FIG. 4 illustrates the door
hinge knuckle 30a may be made of PVC plastic having 65 panels 10, 10a of folding door sections in the maximum
desired properties of strength, rigidity, and temperature open position, the door panels in a folded, parallel position
insensitivity. The element may be formed out of other next the wall.
Exhibit A
Page 15 of 18
US 9,879,471 B2
5 6
FIG. 6 illustrates the hinge knuckle 30a of FIGS. 3-5 and etc. may be fabricated from a strong, hard, plastic such as
further provides an example size dimensions: radius Rl (of rigid vinyl (PVC) plastic or other suitable material such as
the central openings 32a)=0.065 inches; radius R2 (of the metal (e.g., brass).
cylindrical central section 37a)=0.133 inches; radius Thus, when the door is in its extended (un-folded) posi-
R3=0.176 inches; radius R4=0.343 inches; radius RS=0.050 5
tion of FIGS. 1, 2, 9 and 10, the joints on one side are
inches; length Dl=0.210 inches; length D2=0.165 inches; protected by means of flanges 26a, 26c engaging the wedge
angle Al (of the wedge section 35a)=63.5°; and angle A2 35a. On the other side of the door, the space between the
(from the wedge section 35a to the bead 36a)=57.5°. panels is protected by the continuous barrier presented by
FIGS. 7-8 illustrate an example bottom connection of the hinge knuckles 30a, 30b, etc. mounted on (e.g., made of
10
folding door assembly of FIG. 1 according to an embodi- steel) hinge pin 33a. The door accordingly is protected
ment. The door panels have bottom cap pieces 42a, 42b against vandalism and entry by the application of force other
(similar to the top cap pieces 12, 12a, 12b) that are hinged than a force of door-destructive caliber.
together via hinge 40 connecting the bottom cap pieces of an
FIGS. 14-15 illustrate an alternate hinge knuckle 131a as
adjacent pair of panels. The hinge 40 is capped and does not 15 described in U.S. Pat. No. 4,922,987. The alternate hinge
extend into the central hinge mechanism. The hinge pin 33a
knuckle 131a includes a cylindrical central section 137a
"floats" in an installed relation through the central openings
forming a central opening 132a and a longitudinally extend-
32a in the hinge knuckles and thus is not secured directly to
ing tongue 134a terminating in a bead 136a that nests within
a structural member. A screw 50 (only the head of the screw
the longitudinal extending groove 24b. Multiple hinge
is visible in FIG. 7, and further details of the screw 50 are 20
knuckles are stacked to a desired (as previously described)
shown in FIG. 8) is secured into the central opening of the
and secured by central pin 133a. The alternate hinge knuckle
bottom-most hinge knuckle 30x thus trapping the hinge pin
131a (hereinafter referred to as the "old hinge knuckle
33a in place in operative position. In the event the screw 50
design" or the "old hinge knuckle configuration") does not
becomes dislodged from the knuckle unit 30x, the screw 50
include the outwardly extending wedge 35a of the hinge
is provided with a sufficient length shaft that the screw 25
knuckle 30a of FIG. 5 and thus permits the adjacent door
would slide down with its head into contact with the hinge
panels 10a, 10b to open to a larger angle B2 as shown in
40 wherein a portion of the screw shaft still extending into
FIG. 14, and a smaller gap G2 between adjacent extending
the central opening of the hinge knuckle 30x and thus
flanges 26b, 26d (the extending flanges 26b, 26d contacting
continue to retain the hinge pin 33a in place.
30 each other to limit opening of the panels).
FIGS. 9-13 illustrate details and operation of a four panel
door assembly Sa. The same elements in these figures are Each of the hinge knuckle assembles lOOa-e, lOOx, lOOy
shown by common numerals from the previously described may comprise the new design of the hinge knuckle 30a of
figures. The door assembly Sa includes four full size door FIG. 5, but a door assembly may comprise a combination of
panels 10, 10b, 10c, 10d, two half door panels lOa, lOx, a the hinge knuckle assemblies of different designs. The new
35
slide panel section lla and a wall panel section llb secured hinge knuckle design 30a of FIG. 5 with the wedge 35a
to the wall 7. The slide panel section lla is supported and provides for stronger force resistance but permits a smaller
guided at the top on the ceiling track by mounting roller extension angle Bl (see FIG. 3) than the extension angle B2
assemblies 19a, 19b, and at the bottom by slide tab 60 that permitted by the old hinge knuckle design 131a (see FIG.
is disposed in and slides along floor channel 110. Alternating 40 14). It has been determined that only smaller number of
panel sections also include a top mounting roller assembly hinge assemblies are needed to be constructed with the new
(the panel section 10 includes a mounting roller assembly hinge knuckle design to achieve superior resistance perfor-
18a and the panel section 10c includes mounting roller mance, and thus most of the hinge assemblies may be
assembly 18b) and alternating panel sections also include a constructed with the old hinge knuckle design to permit
bottom slide post that engages the floor channel 110 (the 45 larger extension angles. For example, the door assembly Sa
panel section 10 includes slide post 70a and the panel of FIG. 10 may be configured as set forth in the following
section 10c includes slide post 70b). The panel sections are Table A with the new hinge knuckle configuration arranged
interconnected by hinge systems, as previously described, only on the inside hinge sections:
both at the top cap pieces (hinges 13a-e, l3x, 13y), at the
bottom rails, and by central hinge assemblies (lOOa-e, lOOx, 50 TABLE A
lOOy (each central hinge assembly comprising a central
hinge pin and a plurality of stacked hinge knuckles such as Four Panel Door Assembly 5a
assembly 100 of FIG. 18). Specifically, slide panel lla is
connected to half panel 10a by hinge knuckle assembly Hinge Knuckle
lOOy, half panel 10a is connected to panel 10 by hinge 55 Hinge Assembly Configuration
knuckle assembly 100a, panel 10 is connected to panel 10b lOOy old

by hinge knuckle assembly 100b, panel 10b is connected to 100a new
panel 10c by hinge knuckle assembly 100c, panel 10c is 100b old
connected to panel 10d by hinge knuckle assembly 100d, 100c new
panel 10d is connected to half panel lOx by hinge knuckle 60 100d old
assembly lOOe, and half panel lOx is connected to wall panel lOOe new
llb by hinge knuckle assembly lOOx. lOOx old
Both elements of the central hinge assembly (the hinge
knuckle and the hinge pin) are fabricated from hard, durable,
strong material so that they resist forcible entry through the 65 Alternately, for a door assembly Sa as in FIG. 10, the new
central hinge structure. Thus hinge pin 33a may be made of hinge knuckle configuration may be disposed only on out-
a suitable metal such as steel. The hinge knuckles 30a, 30b side hinge sections as set forth in Table B:
Exhibit A
Page 16 of 18
US 9,879,471 B2
7 8
TABLE B arranged only on most of the inside hinge sections 100c,
lOOe, 100g as set forth in the following Table D:
Four Panel Door Assembly 5a (alternate)
Hinge Knuckle TABLED

Hinge Assembly Configuration
Nine Panel Door Assembly 5c
lOOy old
100a old Hinge Knuckle
100b new Hinge Assembly Configuration
100c old
100d new lOOy old
10
lOOe old 100a old
lOOx old 100b old
100c new
100d old
lOOe new
FIGS. 16 and 17 illustrate larger size panel door assem-
lOOf old
blies. The eight panel door assembly Sb in FIG. 16 includes 15 100g new
eight full size panels 10, 10b, 10c, lOd, lOe, 10/, 10g, lOh, 100h old
half panel lOa, half panel lOx, slide panel lla, and wall lOOi old
lOOj old
panel llb. The panel sections are pivotally connected by lOOx old
hinge assemblies lOOa-i, lOOx, lOOy. Alternating panel
sections include a top mounting roller assembly (the panel 20
section 10 includes a mounting roller assembly 18a, the Other combinations of old and new style hinge knuckles
panel section 10c includes mounting roller assembly 18b, may be employed to provide a desired strength property
the panel section lOe includes a mounting roller assembly (provided by the new design) or larger extension angle
18c, the panel section 10g includes mounting roller assem- (provided by the old design).
bly 18d) and each alternating panel sections (10, 10c, lOe, 25 Though the present invention has been set forth in the
10g) also includes a bottom slide post (such as slide post 70a form of its preferred embodiments, it is nevertheless
in FIG. 13) that engages the floor channel 110. intended that modifications to the disclosed systems and
The door assembly Sb of FIG. 16 may be configured methods may be made without departing from inventive
entirely with the new style hinge knuckle 30a, but may concepts set forth herein.
alternately be configured with the new hinge knuckle con- 30
figuration arranged on most of the inside ones of hinge The invention claimed is:
assemblies, as set forth in the following Table C, or only on 1. An accordion type folding door system comprising
the outside (100b, 100d, 100/, 100h): a plurality of adjacent panels arranged vertically and
side-by-side, each panel including a top end having an
TABLE C 35 upper margin, and a bottom end having a lower margin;
a hinge assembly disposed between and interconnecting a
Eight Panel Door Assembly 5b pair of adjacent panels, each of the pair of adjacent
Hinge Knuckle panels including a side edge having longitudinal
Hinge Assembly Configuration groove and an extension flange,
40 wherein the hinge assembly comprises
lOOy old
100a old
a hinge pin,
100b old a plurality of hinge knuckles disposed vertically end-
100c new to-end in an alternating arrangement on the hinge
100d old pin, at least one of the hinge knuckles comprising a
lOOe new
lOOf old
45 tubular central opening for accepting the hinge pin,
100g new an outwardly extending tongue for connecting to a
100h old corresponding longitudinal groove in an adjacent
lOOi old panel in a tongue and groove connection, and an
lOOx old
outwardly flared wedge that extends between and
50 beyond the extension flanges of the panels, whereby
The nine panel door assembly Sc in FIG. 17 includes nine the wedge cooperates with, and respective outer
full size panels 10, 10b, 10c, 10d, lOe, 10/, 10g, lOh, lOi, surfaces of the wedge directly contact, the extension
half panel lOa, half panel lOx, slide panel lla, and wall flanges to limit angular un-folding extension of the
panel llb. The panel sections are pivotally connected by pair of adjacent panels to a maximum desired angle.
hinge assemblies lOOa-j, lOOx, lOOy. Alternating panel 55 2. A system according to claim 1 wherein the plurality
sections include a top mounting roller assembly (the panel hinge knuckles comprise a first partial length hinge knuckle
section 10 includes a mounting roller assembly 18a, the disposed at a bottom of the hinge pin, a second partial length
panel section 10c includes mounting roller assembly 18b, hinge knuckle disposed at a top of the hinge pin, and seven
the panel section lOe includes a mounting roller assembly or eight full length hinge knuckles disposed on the hinge pin
18c, the panel section 10g includes mounting roller assem- 60 between the first and second partial length hinge knuckles.
bly 18d, the panel section lOi includes mounting roller 3. A system according to claim 1 further comprising
assembly 18e) and each alternating panel sections (10, 10c, a track positioned across a space to be secured;
lOe, 10g, lOi) also includes a bottom slide post that engages mounting roller assemblies disposed on upper margins of
the floor channel 110. selected panels for mounting the panels on the track.
The door assembly Sc of FIG. 17 may be configured with 65 4. A system according to claim 1 further comprising upper
the new style hinge knuckle 30a, but may also include may and lower hinges mounted at top and bottom margins of each
be configured with the new hinge knuckle configuration panel for hinging the adjacent panels together.
Exhibit A
Page 17 of 18
US 9,879,471 B2
9 10
5. A method of operation for an accordion type folding a plurality of first hinge knuckles disposed vertically
door system, comprising end-to-end in an alternating arrangement on the
arranging a plurality of adjacent panels arranged verti- hinge pin,
cally and side-by-side, each panel including a top end wherein each of the first hinge knuckles comprises a
having an upper margin, and a bottom end, a hinge 5
first hinge knuckle configuration comprising a tubu-
assembly disposed between and interconnecting a pair lar central opening for accepting the first hinge pin,
of adjacent panels, each of the pair of adjacent panels an outwardly extending tongue for connecting to a
including a side edge having longitudinal groove and corresponding longitudinal groove in an adjacent
an extension flange; panel in a tongue and groove connection, and an
forming the hinge assembly via a plurality of hinge 10 outwardly flared wedge that extends between and
knuckles disposed vertically end-to-end in an alternat- beyond the extension flanges of the panels, whereby
ing arrangement on a hinge pin, at least one of the hinge the wedge cooperates with, and respective outer
knuckles comprising a tubular central opening for surfaces of the wedge directly contact the extension
accepting the hinge pin, an outwardly extending tongue flanges to limit angular un-folding extension of the
for connecting to a corresponding longitudinal groove 15 first pair of adjacent panels to a maximum desired
in an adjacent panel in a tongue and groove connection, angle,
and an outwardly flared wedge; wherein the second hinge assembly comprises
extending the outwardly flared wedge between and a second hinge pin,
beyond the extension flanges of the panels for limiting a plurality of second hinge knuckles disposed vertically
angular un-folding extension of the pair of adjacent 20
end-to-end in an alternating arrangement on the
panels to a maximum desired angle via the wedge hinge pin,
cooperating with, and respective outer surfaces of the wherein each of the second hinge knuckles comprises
directly contacting, the extension flanges. a second hinge knuckle configuration comprising a
6. An accordion type folding door system comprising tubular central opening for accepting the second
a plurality of adjacent panels arranged vertically and 25
hinge pin, an outwardly extending tongue for con-
side-by-side, each panel including a top end having an necting to a corresponding longitudinal groove in an
upper_ margin, and a bottom end having a lower margin; adjace!1t panel in a tongue and groove connection,
a plurality of hinge assemblies including (a) first hinge and without an outwardly flared wedge that extends
assembly disposed between and interconnecting a first between and beyond the extension flanges of the
pair of adjacent panels, each of the first pair of adjacent 30
panels.
panels including a side edge having a longitudinal 7. ~ system according to claim 6 wherein the plurality of
groove and an extension flange and (b) a second hinge first hmge knuckles comprises a first partial length hinge
assembly disposed between and interconnecting a sec- knu~kle disposed at a bottom of the first hinge pin, a second
ond pair of adjacent panels, each of the second pair of partial length hinge knuckle disposed at a top of the first
adj~cent panels including a side edge having a longi- 35
hinge pin, and seven or eight full length hinge knuckles
tudmal groove and an extension flange, disposed on the first hinge pin between the first and second
wherein the first hinge assembly comprises partial length hinge knuckles.
a first hinge pin,
* * * * *
Exhibit A
Page 18 of 18
Exhibit B
IIIIII IIIIIIII Ill lllll llllll llll lllll lllll lllll lllll lllll 111111111111111111
USOOD792190S
c12) United States Design Patent c10) Patent No.: US D792,190 S

Lewis et al. (45) Date of Patent: ** Jul. 18, 2017
(54) HINGE KNUCKLE FOR FOLDING DOOR 5,150,501 A 9/1992 Pasternak

ASSEMBLY 5,472,037 A 12/1995 Hoffman
D370,839 S * 6/1996 Harris D25/119
5,549,148 A 8/1996 Figueiredo et al.
(71) Applicant: Woodfold Mfg., Inc., Forest Grove, OR D402,536 S * 12/ 1998 Cousins ... ... ... .... ... ... ... ... D8/3 54
(US) D411,434 S * 6/ 1999 Russell . ... ... ... .... ... ... ... ... D8/3 23
6,669,272 B2 12/2003 Ayabe et al.
(72) Inventors: Mark F. Lewis, Portland, OR (US); D496,248 S * 9/2004 Liebendorfer ................. D8/354
Rick Scott Alvarado, Gaston, OR (US) D520,862 S * 5/2006 Munson ......................... D8/354
7,290,581 B2 11/2007 Lee
D562,108 S * 2/2008 Pester ............................ D8/323
(73) Assignee: WOODFOLD MFG., INC., Forest 8,191,603 Bl 6/2012 Motosko
Grove, OR (US) (Continued)
(**) Term: 15 Years
OTHER PUBLICATIONS
(21) Appl. No.: 29/568,458
Lewis et al., "Reinforced Folding Door and Hinge Assembly", U.S.
Appl. No. 62/235,455, filed Sep. 30, 2015.
(22) Filed: Jun. 17, 2016
(Continued)
Related U.S. Application Data Primary Examiner - John Windmuller
(63) Continuation-in-part of application No. 15/171,478, Assistant Examiner - Benjamin Weeks
filed on Jun. 2, 2016. (74) Attorney, Agent, or Firm - Stoel Rives LLP
(51) LOC (10) Cl. ............................................... 08-06
(57) CLAIM
(52) U.S. Cl.
USPC ........................................................... D8/323 The ornamental design for a hinge knuckle for folding door
(58) Field of Classification Search assembly, as shown and described.
USPC .................. D8/323-329, 354, 356; D23/303
DESCRIPTION
CPC .... E05D 1/00; E05D 3/00; E05D 5/00; E05D
7/00; B29C 31/00; E05Y 2201/00; F16C FIG. 1 is an isometric view of a front portion of a hinge
1/00; F16C 3/00; F16C 9/00 knuckle for folding door assembly showing the new design;
See application file for complete search history. FIG. 2 is a front elevation view thereof;
FIG. 3 is a rear elevation view thereof;
(56) References Cited
FIG. 4 is a right side elevation view thereof;
U.S. PATENT DOCUMENTS FIG. 5 is a left side elevation view thereof;
FIG. 6 is a top plan view thereof; and,
1,463,346 A 7/1923 Walker FIG. 7 is a bottom plan view thereof.
3,131,753 A 5/1964 Dixon The broken lines in the figures represent portions of the
3,901,302 A 8/1975 Dagenais
hinge knuckle for folding door assembly that form no part of
3,913,171 A 10/1975 Reid
4,222,428 A 9/1980 Scherer the claimed design.
4,387,760 A 6/1983 Greschbach
4,922,987 A 5/1990 Marontate 1 Claim, 2 Drawing Sheets
Exhibit B
Page 1 of 4
US D792,190 S
Page 2
(56) References Cited
U.S. PATENT DOCUMENTS
D680,419 S * 4/2013 Green ....................... B07B 1/15

D8/349
8,960,257 B2 2/2015 Goodman
D729,605 S * 5/2015 Ramey ........................... D8/323
D731,296 S * 6/2015 Nelson ........................... D8/356
D732,703 S * 6/2015 Kreutzman .................. D25/122
2005/0063058 Al* 3/2005 Langley . G02B 21/0012
359/510
2011/0155145 Al* 6/2011 Chua. A61B 19/081
128/849
2012/0124776 Al 5/2012 McDonnell
2014/0367056 Al 12/2014 Miller
OTHER PUBLICATIONS
Lewis et al., "Reinforced Folding Door and Hinge Assembly", U.S.

Appl. No. 15/171,478, filed Jun. 2, 2016.
Office Action from Lewis et al. U.S. Appl. No. 15/171,478, dated
Apr. 6, 2017, 8 pages.
* cited by examiner
Exhibit B
Page 2 of 4
U.S. Patent Jul. 18, 2017 Sheet 1 of 2 US D792,190 S
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Exhibit B
Page 3 of 4
U.S. Patent Jul. 18, 2017 Sheet 2 of 2 US D792,190 S
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Page 4 of 4

Woodfold MFG v. EMI Porto Opco - Complaint

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Woodfold MFG v. EMI Porto Opco - Complaint

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Case: 1:18-cv-03984 Document #: 1 Filed: 06/07/18 Page 1 of 17 PageID #:1

IN THE UNITED STATES DISTRICT COURT

WOODFOLD MFG., INC., an Oregon )

COMPLAINT FOR PATENT INFRINGEMENT

Porta OPCO, LLC (“EMI Porta”) hereby alleges as follows:

NATURE OF THE ACTION

United States, including 35 U.S.C. §§ 271, 281-285, and 289.

gates in residential elevators.

3. Woodfold seeks injunctive relief and damages against Defendant.

Woodfold owns the Woodfold Patents.

SCHWABE, WILLIAMSON & WYATT, P.C.

5. Defendant EMI Porta is an Illinois limited liability company having a principal

folding doors used in the residential elevator industry.

JURISDICTION AND VENUE

§§ 1331 and 1338(a).

9. Woodfold is a leading innovator in the residential elevator industry. Founded in

B44-16—the safety standard for elevators and escalators.

SCHWABE, WILLIAMSON & WYATT, P.C.

and correct copy of the ’471 patent is attached hereto as Exhibit A.

12. Claim 1 recites:

1. An accordion type folding door system comprising

a plurality of adjacent panels arranged vertically and side-by-side, each panel

a hinge assembly disposed between and interconnecting a pair of adjacent panels,

each of the pair of adjacent panels including a side edge having

longitudinal groove and an extension flange,

a plurality of hinge knuckles disposed vertically end-to-end in an

comprising a tubular central opening for accepting the hinge pin, an

outwardly extending tongue for connecting to a corresponding longitudinal

groove in an adjacent panel in a tongue and groove connection, and an

angular un-folding extension of the pair of adjacent panels to a maximum

SCHWABE, WILLIAMSON & WYATT, P.C.

14. Figure 6 shows a top plan view:

EMI Porta’s Infringing Products

controllers, electromechanical interlocks, and other fixtures.

utilizes the technology claimed and taught in the ’471 Patent.

SCHWABE, WILLIAMSON & WYATT, P.C.

having an upper margin, and a bottom end having a lower margin:

SCHWABE, WILLIAMSON & WYATT, P.C.

edge having longitudinal groove and an extension flange:

SCHWABE, WILLIAMSON & WYATT, P.C.

to-end in an alternating arrangement on the hinge pin:

SCHWABE, WILLIAMSON & WYATT, P.C.

connecting to a corresponding longitudinal groove in an adjacent panel in a tongue and groove

flanges of the panels.

SCHWABE, WILLIAMSON & WYATT, P.C.

pair of adjacent panels to a maximum desired angle:

SCHWABE, WILLIAMSON & WYATT, P.C.

products, willfully disregarding Woodfold’s rights in the Woodfold Patents.

SCHWABE, WILLIAMSON & WYATT, P.C.

COUNT 1 – INFRINGEMENT OF THE ’471 PATENT

of paragraphs 1 through 26 as if fully set forth herein.

patented invention disclosed in the ’471 Patent, in violation of 35 U.S.C. § 271.

attorneys’ fees, and litigation expenses incurred.

SCHWABE, WILLIAMSON & WYATT, P.C.

COUNT 2 – INFRINGEMENT OF THE D’190 PATENT

of paragraphs 1 through 33 as if fully set forth herein.

Patent, in violation of 35 U.S.C. §§ 271 and 289.

invention disclosed in the D’190 Patent.

enjoined by this Court.

Porta’s further infringing conduct.

SCHWABE, WILLIAMSON & WYATT, P.C.

attorneys’ fees, and litigation expenses incurred.

SCHWABE, WILLIAMSON & WYATT, P.C.