Vous êtes sur la page 1sur 55

Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 1 of 19 PageID #: 1

Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 2 of 19 PageID #: 2


Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 3 of 19 PageID #: 3
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 4 of 19 PageID #: 4
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 5 of 19 PageID #: 5
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 6 of 19 PageID #: 6
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 7 of 19 PageID #: 7
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 8 of 19 PageID #: 8
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 9 of 19 PageID #: 9
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 10 of 19 PageID #: 10
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 11 of 19 PageID #: 11
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 12 of 19 PageID #: 12
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 13 of 19 PageID #: 13
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 14 of 19 PageID #: 14
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 15 of 19 PageID #: 15
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 16 of 19 PageID #: 16
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 17 of 19 PageID #: 17
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 18 of 19 PageID #: 18
Case 3:17-cv-00771 Document 1 Filed 04/28/17 Page 19 of 19 PageID #: 19
US008156980B2

(12) Ulllted States Patent (10) Patent N0.: US 8,156,980 B2


Tatlock (45) Date of Patent: Apr. 17, 2012

(54) SIDEWALL PROTECTOR RIBS 4,219,066 A 8/1980 Tamura ct a1. .............. .. 152/353
4,356,985 A * 11/1982 Ycagcrctal. .... .. 152/523
_ 4,699,193 A 10/1987 Bryant ctal. .. ..... .. 152/523
(75) Inventor. Ronald W. Tatlock, Tallmadge, OH 4,711,283 A * 0/1987 Bonko et a1 15200912
(Us) 4,809,757 A 3/1989 Shurman ............. .. 152/523
4,815,511 A * 3/1989 Brayer ctal. .. .. 152/209.14
(73) Assignee: Bridgestone -Americas Tire Operations, , , 2 i ghinmiya1~~~
emor et a . .. .....
~~ ..
LLCNaShVIHeTNwS) 4,982,773 A 1/1991 Bonko ............. .. 152/209
5,645,660 A 7/1997 Att- 11 t l. 152/523
( * ) Notice: Subject to any disclaimer, the term ofthis 13389104 S 1/1998 Molrrgmo ,,, , , , 12/147
patent is extended or adjusted under 35 6,189,586 B1 * 2/2001 Guidry ......... .. 152/523
U,S_C_ 154(1)) by 720 days_ 6,257,290 B1* 7/2001 Sakamoto ct a1. 152/523
D447,449 S 9/2001 Guspodin ..................... .. 12/152
(21) Appl. No.: 12/328,244 (Continued)
(22) Filed: Dec. 4, 2008 FOREIGN PATENT DOCUMENTS
_ _ _ JP 55091408 A * 7/1980
(65) Prior Publication Data (Continued)
US 2010/0139830 A1 Jun. 10, 2010
OTHER PUBLICATIONS
(51) Int- 0- JPO Englsih Abstract of JP 55091408, 1980*
B60C 13/02 (2006.01) '
(52) us. Cl. 152/523; 152/524; 152/154; 152/209.16 (Con?rmed)
(58) Field of Classl?catilggl/gggrlclh 155545, Primary Examiner i Joseph Del Sole
See application ?le for complete search history. Assistant Examiner * Tlmothy Kennedy _
(74) Attorney, Agent, or Firm * Matthew W. Jup1na; Wayne
(56) References Cited Beavers

U.S. PATENT DOCUMENTS (57) ABSTRACT


1,448,286 A * 3/ 1923 Comstock ................... .. 152/523 A pneumatic tire for use With telescopic material handlers
2D;
a a
15A * gotelliieit ~~~~~
u e SOIl e a . . . . . . . . ,,
2623 includes a ?rst concentrically continuous sideWall protector
- . . . _

3,204,681 A * 9/l965 Wallace


olagnieretet a1 ' 152/l54 ahove a midpoint of the sidewall. A second non-continuous
3,253,634 A * 5/ 1966 De Young ,, 152/524 s1deWall protector nb is located concentrically outWard of the
D206,646 S 1/ 1967 Makris . . . . . . . . . .. 90/20 ?rst sidewall protector rib. The tire is a relatively loW aspect
2 i yen) ~' ratio tire having a relatively ?at sideWall pro?le. This pro
38 1 l 488 A * 5/ 1974 "" " 152623 vides a tire having the advantage of added sideWall protection
338303274 A * 8/1974 Wager, Jr, , ,,, N 152524 Without increasing the overall Width of the in?ated tire.
3,841,373 A * 10/1974 Gilreath .. 152/523
T973,006 I4 * 8/1978 Beyers . . . . . . . . . .. 152/523 23 Claims, 6 Drawing Sheets

58
/ 50,58,60
6B
75 18,62
\ as
__ 48,64

1 30
77 28

J79 12, 70

Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 1 of 13 PageID #: 20


US 8,156,980 B2
Page 2

US. PATENT DOCUMENTS JPO Englsih Abstract of JP 2004291937, 2004*


Exhibit A: Two page printout regarding the Bridgestone Model VUT
D449,803 S 10/2001 Guspodin et al. ............. .. 12/147 G-2, L-2 tire. (undated but admitted to be prior art).
6,533,007 B1 3/2003 McMannis 152/2092
Exhibit B: TWo page printout regarding the Bridgestone Model L-3
6,666,248 B2 12/2003 Omoto et al. 152/523
6,761,198 B2 7/2004 ZanZig et al. 152/209.5 tire. (undated but admitted to be prior art).
D495,294 S 8/2004 Ochi et al. .. 12/604 Exhibit C: two page printout regarding the Firestone Model SGG RB
6,920,906 B2 7/2005 Allison et a1. ........... .. 152/209.2 G-2, G2/L2 tire. (undated but admitted to be prior art).
6,929,044 B1 8/2005 Rodney Exhibit D: Four pages: three page printout from the Solideal Website,
6,941,990 B2 9/2005 Rooney ....................... .. 152/454 fourth page photograph of cross- section cut from Solideal siZe 13 .00
2001/0020505 A1 9/2001 ZanZig et al. 24TG tire. (undated but admitted to be prior art).
Exhibit E: Bridgestone D-LUG tire Which has a noncontinuous
FOREIGN PATENT DOCUMENTS shoulder protection rib. (undated but admitted to be prior art).
JP 61-081207 4/1986 Exhibit F: Five page brochure from the Galaxy Tire Company, re the
JP 63170110 A * 7/1988 Galaxy Super-Sidewall skid steer tire. (undated but admitted to be
JP 06-316206 11/1994 prior art).
JP 2004291937 A * 10/2004 Chun Hee Kim, International Search Report and Written Opinion
from PCT Application PCT/US09/66556, Jul. 1, 2010, 6 pages,
OTHER PUBLICATIONS Korean Intellectual Property Of?ce, Daejeon, Korea.
JPO Englsih Abstract of JP 63170110, 1988* * cited by examiner

Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 2 of 13 PageID #: 21


US. Patent Apr. 17, 2012 Sheet 1 of6 US 8,156,980 B2

Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 3 of 13 PageID #: 22


US. Patent Apr. 17, 2012 Sheet 2 of6 US 8,156,980 B2

Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 4 of 13 PageID #: 23


US. Patent Apr. 17, 2012 Sheet 3 of6 US 8,156,980 B2

Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 5 of 13 PageID #: 24


US. Patent Apr. 17, 2012 Sheet 4 of6 US 8,156,980 B2

24\ /26

FIG. 4

Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 6 of 13 PageID #: 25


US. Patent Apr. 17, 2012 Sheet 5 of6 US 8,156,980 B2

Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 7 of 13 PageID #: 26


US. Patent Apr. 17, 2012 Sheet 6 of6 US 8,156,980 B2

Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 8 of 13 PageID #: 27


US 8,156,980 B2
1 2
SIDEWALL PROTECTOR RIBS includes ?rst and second sideWall portions and a tread portion
extending betWeen the ?rst and second sideWall portions. The
BACKGROUND OF THE INVENTION tread portion includes a base and at least a ?rst circumferen
tially spaced roW of lugs. Each lug of the ?rst roW of lugs
1. Field of the Invention includes an axially outer surface facing in generally the same
The present invention relates generally to pneumatic tires, axial direction as does the ?rst sideWall. Each axially outer
and more particularly, but not by Way of limitation, to pneu surface includes an axially outWardly projecting step adjoin
matic tires especially designed for use With telescopic mate ing the base. A circumferentially continuous sideWall protec
rial handlers. tor rib projects axially outWard from the ?rst sideWall portion
2. Description of the Prior Art and is located radially inWard of and radially adjacent to the
Telescopic material handlers are forklift trucks commonly axially outWard projecting steps of the axially outer surfaces
utiliZed on construction sites. They include a telescoping of the lugs of the ?rst roW of lugs. The circumferentially
boom typically With a reach of from 30 to 40 feet, and they can continuous sideWall protector rib projects axially outWard
steer in a forWard steer or rear steer mode, and also in four further than do the axially outWardly projecting steps.
Wheel steer, crab or craWl modes. Telescopic material han In another aspect of the present invention a pneumatic tire
dlers must be capable of maneuvering in tight places and they includes ?rst and second sideWalls With a tread area extending
have severe steer angles as high as 86 to 88 degrees at the betWeen the ?rst and second sideWalls. The tread area
steered Wheels. includes an inner tread surface and at least a ?rst circumfer
Because telescopic material handlers are used on construc ential roW of lugs extending radially outWard from the inner
tion sites, they encounter rough terrain littered With much tread surface adjacent the ?rst sideWall. A circumferentially
debris such as nails, piles of lumber, broken concrete blocks 20 continuous sideWall protector rib includes a radially outer
and the like. surface de?ned as an integral extension of the inner tread
Additionally, because much of such equipment is provided surface Without any surface break line betWeen the radially
by rental services to the construction contractors, the opera outer surface and the inner tread surface. The sideWall pro
tors of the telescopic material handlers are often inexperi tector rib also includes an axially outer surface projecting
enced drivers. 25 axially at least as far as any other part of the ?rst sideWall to
All of these factors combine to result in a scenario Where protect the ?rst sideWall from damaging engagement With
the tires utiliZed on the telescopic material handlers can be foreign objects.
expected to encounter substantial tire injury due to running In another aspect of the present invention a pneumatic tire
over and against debris, sidesWiping curbs and other abut includes ?rst and second sideWalls and a treadportion extend
ments, and backing into obstacles. Many of these tire injuries, ing betWeen the ?rst and second sideWalls. The tread portion
particularly the sidesWiping of curbs and the like, typically includes a radially inner tread base and a plurality of lugs
injure the tire at the Widest point of the sideWall Which is extending radially outWard from the base. The ?rst sideWall
usually near the mid height of the sideWall. has a sideWall height extending radially from a radially inner
Currently, most telescopic material handlers utiliZe 24 or most part of the ?rst sideWall to a radially outer ground
25 inch diameter Wheel rims and use tires originally designed engaging surface of the tread portion. A circumferentially
for use on road graders and having a tire outside diameter of 35 continuous sideWall protector rib is located entirely above 60
approximately 51 inches. Typical examples of such current percent of the sideWall height. The circumferentially continu
tires produced by the assignee of the present invention ous sideWall protector rib projects axially outWard at least as
include the Bridgestone Model VUT G-2 tire in a 13.00 R 24 far as any other part of the ?rst sideWall. A circumferentially
siZe, the Bridgestone Model L-3 tire in a 13.00-24 siZe and a non-continuous sideWall protector rib is located radially out
Firestone Model SGG RB G-2 or G2/L2 tire in a 13.00-24 40 Ward from and radially adjacent to the circumferentially con
siZe. The aspect ratio of these tires, Which is de?ned as the tinuous sideWall protector rib. The circumferentially non
ratio of sideWall height to the total Width of the tire as a continuous sideWall protector rib projects axially outWard
percentage, is typically relatively high, Well in excess of 90 beyond the ?rst sideWall a distance less than does the circum
percent and in some cases near 100 percent. ferentially continuous sideWall protector rib.
Another typical prior art tire commonly used on telescopic 45 Accordingly, it is an object of the present invention to
material handlers is the Solideal Model TG tire in a 13.00-24
provide improved tires for use With telescopic material han
siZe Which has an overall diameter of 51.1 inches and a
section Width of 14.4 inches. The Solideal tire also has a
dlers Which provide a sideWall protector rib.
relatively high aspect ratio of approximately 96.1 percent. Another object of the present invention is the provision of
The Solideal 13.00-24 TG tire is advertised as having extra a pneumatic tire having a circumferentially continuous side
sideWall protection to resist road abuse, and it achieves this by Wall rib and having a circumferentially non-continuous side
relieving the sideWall area along a Wide band at near mid Wall rib disposed concentrically outside of the circumferen
sideWall height and thickening the area above and beloW the tially continuous sideWall rib.
relieved area. Still another object of the present invention is the provision
Another approach to providing sideWall protection for con of improved designs for sideWall protector ribs for tires.
struction vehicle tires is shoWn in US. Pat. No. 6,666,248 to 55 Another object of the present invention is the provision of
Omoto et al. Which discloses the use of convex shape sideWall a loW pro?le tire With a sideWall protector rib, the tire speci?
protectors embedded in the sideWall along the midline of the cally designed for use With telescopic material handlers and
sideWall. having an aspect ratio of less than 80 percent.
Thus it is seen that there is a continuing need for an effec Other and further objects, features and advantages of the
tive, economical design for a pneumatic tire especially 60 present invention Will be readily apparent to those skilled in
intended for use on telescopic material handlers Which pro the art upon a reading of the folloWing disclosure When taken
vides improved sideWall protection. in conjunction With the accompanying draWings.
SUMMARY OF THE INVENTION BRIEF DESCRIPTION OF THE DRAWINGS
65
In one aspect of the present invention a pneumatic tire FIG. 1 is a perspective vieW of a tire including sideWall
particularly adapted for use With telescopic material handlers protector ribs in accordance With the present invention.
Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 9 of 13 PageID #: 28
US 8,156,980 B2
3 4
FIG. 2 is a front elevation vieW of the tire of FIG. 1. 50. Similarly, the second sideWall 14 includes a circumferen
FIG. 3 is a side elevation vieW of the tire of FIG. 1. tially continuous sideWall protector rib 52 and a circumfer
FIG. 4 is an enlarged front elevation vieW of a portion of the entially non-continuous sideWall protector rib 54.
tire of FIG. 1. Each of the lugs 22 includes an axially outer surface 58
FIG. 5 is a radially sectioned vieW of the tire of FIG. 1 taken facing in generally the same axial direction as does the ?rst
along line 5-5 of FIG. 4. sideWall 12, that is generally to the right as seen in FIGS. 2
FIG. 6 is a perspective, radially sectioned vieW of the tire of and 5. Each axially outer surface 58 includes an axially out
FIG. 1 taken along line 6-6 of FIG. 4. Wardly projecting step 60 adjoining the inner tread surface 18.
As best seen in FIGS. 3 and 5, the axially outWardly project
DETAILED DESCRIPTION OF THE PREFERRED ing steps 60 project axially outWard from the ?rst sideWall
EMBODIMENTS portion 12 and de?ne the circumferentially non-continuous
sideWall protector rib 50 Which is concentrically disposed
Referring noW to the draWings and particularly to FIGS. 1 about the circumferentially continuous sideWall protector rib
and 5, a pneumatic tire 10 includes ?rst and second sideWalls 48.
or sideWall portions 12 and 14, and a tread area or tread The circumferentially continuous sideWall protector rib 48
portion 16 extending betWeen the ?rst and second sideWalls projects axially outWard from the ?rst sideWall portion 12 and
12 and 14. The tire 10 is particularly suited for use With is located radially inWard of and radially adjacent to the
telescopic material handlers, and With other construction axially outWard projecting steps 60 of the axially outer sur
equipment Which must traverse rough terrain and Which is faces 58 of the lugs 22 of the ?rst roW of lugs. The circum
subject to sideWall tire injury from impacts With construction 20 ferentially continuous sideWall protector rib 48 projects axi
debris and surroundings. ally outWard further than do the axially outWard projecting
The tread area 16 includes an inner tread surface or base 18 steps 60. It is preferred that the circumferentially continuous
and a plurality of lugs 20 extending radially outWard from the sideWall protector rib 48 project axially outWard at least as far
inner tread surface 18. as any other part of the ?rst sideWall portion 12 When the tire
For the particular tread pattern illustrated, the lugs 20 25 10 is in an in?ated loaded condition. The rib 48 may project
include three circumferentially spaced roWs of lugs namely axially outWard beyond any other part of the ?rst sideWall
?rst and second circumferentially spaced outer roWs of lugs portion 12.
22 and 24, respectively, and a circumferentially spaced cen As best seen in FIGS. 5 and 6, the circumferentially con
tral roW oflugs 26. tinuous sideWall protector ribs such as 48 and 52 include
The ?rst circumferentially spaced outer roW of lugs 22 can 30 radially outer surfaces 62 and 63, respectively, Which are
be described as extending radially outWard from the inner integral extensions of the inner tread surface 18 Without any
tread surface 18 adjacent the ?rst sidewall 12. The second roW surface break line betWeen the radially outer surfaces 62 and
of lugs 24 can be similarly described With reference to the 63 and the inner tread surface 18. More generally, the radially
second sideWall 14. outer surfaces 62 and 63 of continuous ribs 48 and 52 can be
As best seen in FIG. 5, the tire 10 has a carcass 28. The 35 described as terminating adjacent the inner tread surface 18.
carcass 28 has a plurality of carcass plies 30 extending cir The continuous rib 48 further includes an axially outer sur
cumferentially about an axis of rotation 32 (see FIG. 2) of the face 64 projecting axially at least as far as any other part of the
tire 10. At least one of the carcass plies is anchored on each ?rst sideWall portion 12 to protect the ?rst sideWall portion 12
end to ?rst and second annular beads 34 and 36. The carcass from damaging engagement With foreign objects.
28 is embedded in the molded rubber sideWall portions 12 and 40 As best seen in FIG. 5, the axially outWard facing surface
14 and tread portion 16. 64 of continuous protector rib 48 and axially outWard facing
The sideWalls 12 and 14 each have a sideWall height 38 surface 58 of the step 60 of the non-continuous protector rib
extending radially from a radially innermost edge 40 of the 50 slope in opposite directions With reference to the equato
?rst and second sideWalls 12 and 14 to a radially outer ground rial plane 46. The axially outer surface 64 of the circumfer
engaging surface 42 of the tread area 16. The tire has a 45 entially continuous sideWall protector rib 48 can be described
maximum section Width 44 Which in this case spans betWeen as sloping radially inWard toWard the rotational axis 32 of the
the axially outermost projections of the sideWall protector tire 10 and axially inWard toWard the equatorial plane 46. The
ribs described beloW. The tire 10 has an equatorial plane 46. axially outWard facing surface 58 of the step 60 slopes radi
As used herein, references to axial directions refer to direc ally inWard toWard the rotational axis 32 of tire 10 and axially
tions generally parallel to the rotational axis 32 of the tire 10. 50 outWard aWay from the equatorial plane 46.
References to radial directions refer to directions generally In the example shoWn in FIG. 5, for a tire siZe 370/75-28,
extending along a radius from the rotational axis 32. Refer the circumferentially continuous sideWall protector rib 48 has
ences to circumferential directions such as the circumferen a radial Width 66 corresponding to axially outWardly facing
tially spaced roW of lugs 22 refer to directions extending surface 64 of approximately 1 .349 inches. The radial Width 66
around a circumference of the tire 10. The ?rst circumferen 55 is preferably at least 1.25 inches. The axially outWard facing
tial roW of lugs 22 for example includes circumferentially surface 58 at step portion 60 of the circumferentially non
adjacent lugs 22A and 22B circumferentially spaced from continuous sideWall protector rib 50 has a radial Width 68 of
each other by circumferential space 56 Which is in part approximately 0.685 inches. As used herein, the radial
de?ned by the inner tread surface 18. Width is that Width of the rib 48 or 50 intersected by a radial
In order to provide improved protection to the sideWalls 12 60 plane extending from the axis 32 of the tire. In general, the
and 14 against injury from running over construction debris circumferentially continuous sideWall protector rib 48 can be
and the like or from running against obstacles such as curbs described as having a radial Width 66 in a range of from 1 .5 to
and Walls, each of the sideWalls 12 and 14 are provided With 2.5 times the radial Width 68 of circumferentially non-con
an improved sideWall protector rib structure. Thus, the ?rst tinuous protector rib 50, and more speci?cally that ratio is at
sideWall 12 has a circumferentially continuous sideWall pro 65 least 1.9 and even more speci?cally is approximately 2.0.
tector rib 48 about Which is concentrically received a circum As best seen in FIG. 5, the ?rst sideWall portion 12 has a
ferentially non-continuous or broken sideWall protector rib smooth continuously curved axially outer sideWall pro?le 70
Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 10 of 13 PageID #: 29
US 8,156,980 B2
5 6
when viewed in radial cross-section. Furthermore, that por height 38 and more speci?cally lies entirely above sixty per
tion of the axially outward facing outer surface 58 of lugs 22 cent of the sidewall height 38. Further, the axially outward
located radially outward above the step 60 coincides with and facing surface 64 can be described as lying entirely within the
de?nes a part of that smooth continuously curved outer side range 75 extending from a lower end 77 of about sixty percent
wall pro?le 70, as shown by the imaginary extension of pro to an upper end 79 of about eighty percent of the sidewall
?le 70 in phantom lines in FIG. 5. height 38. As seen in FIG. 5, the smooth continuous sidewall
As is apparent in FIG. 5, both of the sidewall protector ribs pro?le 70 can be described as being broken only by the axially
48 and 50 project axially outward beyond that portion of the outwardly projecting circumferentially non-continuous side
sidewall pro?le 70 immediately adjacent the protector ribs. wall protector rib 50 and the axially outwardly projecting
For a tire siZe 370/75-28, the radially uppermost portion of circumferentially continuous sidewall protector rib 48.
the axially outward facing surface 64 of continuous protector It will be appreciated that the dimensions of the tire 10 will
rib 48 projects beyond the outer sidewall pro?le 70 immedi change somewhat when the tire 10 is mounted on a wheel rim,
ately adjacent the rib 48 by a distance 71 of at least 0.25 inch in?ated and loaded. The tire 10 is shaped and dimensioned
and for a tire of siZe 370/ 75-28 approximately 0.35 inch. As is such that when the tire is in?ated and under load the rib 48 will
also apparent, the continuous sidewall rib 48 projects axially still protrude at least as far as any other part of the sidewall 12.
outward from the sidewall pro?le 70 at least twice as far as Thus with a tire 10 having the sidewall protector rib 48, if the
does the circumferentially non-continuous sidewall protector tire is driven against a curb or the like the sidewall protector
rib 50 which for a tire of siZe 370/ 75-28 projects axially rib 48 will ?rst engage the curb and will protect the other
outward approximately 0.17 inch. portions of the sidewall 12.
The tire 10 has a relatively low aspect ratio as compared to 20 As can be seen in FIG. 5, the non-continuous sidewall
prior art tires traditionally used on telescopic material han protector rib 50 provides somewhat of a tapered transition to
dlers. The sidewall pro?le 70 is relatively ?at and vertical as the larger continuous sidewall protector rib 48 and thus serves
compared to typical prior art tires utiliZed on telescopic mate to provide a more gradual transition from the tread area 16 to
rial handlers which tend to be more bulging and rounded with the continuous sidewall protector rib 48 than would otherwise
their widest point at the midline of the sidewall height. 25 be the case. Thus, if the edge of the tire runs over a broken
This relatively ?at, relatively vertical orientation of the block or other obstacle or is starting to run up on a curb, the
sidewall pro?le 70 substantially aids in the proper functioning presence of the axially shorter non-continuous sidewall pro
of the sidewall protector ribs 48 and 50, thus allowing the tector rib 50 may engage the obstacle before the more promi
distance 71 to be reasonable yet to still project axially out nent continuous sidewall protector rib 48 does so, and thus
ward at least as far as any other part of the sidewall and 30 help de?ect the object away from the tire or help de?ect the
preferably beyond any other part of the sidewall to provide tire away from the object. This multi-tier or multi-step design
protection of the sidewall against lateral impacts with foreign provided by the axially shorter sidewall protector rib 50 and
objects. the axially longer sidewall protector rib 48 is used to progres
This relatively ?at, relatively vertical orientation of the sively push off the sidewall intrusion and protect the sidewall
sidewall pro?le 70 is achieved in part by the mold shape 35 from damage. This minimiZes carcass strain while offering
corresponding to the sidewall pro?le 70 and also in part by the maximum protection.
relatively low aspect ratio of the tire. Also it is noted that due to the proximity of the circumfer
As used herein, the aspect ratio of a tire is determined by entially continuous sidewall protector rib 48 to the tread area
subtracting the wheel diameter from the outside diameter of 16, the rubber compound from which the continuous sidewall
the tire and dividing that by two to get a tire height and then 40 protector rib 48 is molded can more easily be controlled to be
dividing that tire height by the overall width of the tire in an tread compound rather than sidewall compound. As will be
in?ated unloaded condition. In one example of the tire 10 in appreciated by those skilled in the art, a more wear resistant
a tire siZe 370/75-28, the outside dimension of the tire is rubber compound is typically used for the tread area 16
approximately 50.3 inches, the overall width is approxi whereas the rubber compound used for the sidewalls 12 and
mately 14.5 inches, and the tire is designed for use on a 28 45 14 typically includes components to provide more protection
inch diameter rim, thus resulting in an aspect ratio of 76.9 from oZone and sunlight.
percent. The dimensions just given are by way of example As a result of the placement of the sidewall protector ribs
only, and the invention is applicable to other siZes of tires with 48 and 50 relatively high on the sidewall pro?le well beyond
different tire diameters and widths and for use on different the sidewall midpoint, and as a result of appropriate construc
rim diameters. 50 tion of the shape of the sidewall pro?le 70 in combination
It is noted that although the speci?c example of the tire 10 with a low aspect ratio, the sidewall protector ribs 48 and 50
just described having an outside diameter of 50.3 inches has can be provided without any increase in the overall in?ated
approximately the same outside diameter as the prior art tires tire width as compared to typical higher aspect ratio prior art
typically used on telescopic material handlers, the tire 10 has tires not having any sidewall protection. This avoids an unde
been designed as a much lower aspect ratio tire and thus has 55 sirable increase in overall in?ated tire width which would
been designed for use on a larger diameter 28 inch rim as occur from designs such as that of Us. Pat. No. 6,666,248
compared to the prior art tires which are designed for use on which have sidewall protector ribs located approximately
a 24 inch diameter rim. The prior art tires previously used on mid-sidewall height.
telescopic material handlers usually have an aspect ratio of 90 Thus it is seen that the apparatus of the present invention
percent or greater. 60 readily achieves the ends and advantages mentioned as well
In general, the tire 10 should have a relatively low aspect as those inherent therein. While certain preferred embodi
ratio of no greater than about 80 percent. Preferably the tire 1 0 ments of the invention have been illustrated and described for
is constructed to ?t on a wheel rim of approximately 28 inches purposes of the present disclosure, numerous changes in the
diameter. arrangement and construction of parts may be made by those
As seen in FIG. 5, the axially outward facing surface 64 of 65 skilled in the art, which changes are encompassed within the
circumferentially continuous sidewall protector rib 48 is scope and spirit of the present invention as de?ned by the
located substantially above mid height 73 of the sidewall appended claims.
Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 11 of 13 PageID #: 30
US 8,l56,980 B2
7 8
What is claimed is: face projecting axially at least as far as any other part of
1. A pneumatic tire, comprising: the ?rst sidewall to protect the ?rst sidewall from dam
?rst and second sidewalls; aging engagement with foreign objects;
a tread area extending between the ?rst and second side wherein each lug of the ?rst circumferential row of lugs
walls, the tread area including an inner tread surface and includes an axially outward facing outer surface includ
at least a ?rst circumferential row of lugs extending ing a step portion adjacent the inner tread surface, the
radially outward from the inner tread surface adjacent step portions of the lugs of the ?rst circumferential row
the ?rst sidewall; and of lugs forming a circumferentially broken sidewall pro
a circumferentially continuous sidewall protector rib tector rib located immediately radially outward of the
including a radially outer surface de?ned as an integral circumferentially continuous sidewall protector rib and
extension of the inner tread surface without any surface axially projecting from the ?rst sidewall less than the
break line between the radially outer surface and the axially outer surface of the circumferentially continuous
inner tread surface, and including an axially outer sur sidewall protector rib.
face projecting axially at least as far as any other part of 6. The tire of claim 5, wherein:
the ?rst sidewall to protect the ?rst sidewall from dam the axially outer surface of the circumferentially continu
aging engagement with foreign objects; ous sidewall protector rib slopes radially inward toward
wherein the ?rst sidewall has a sidewall height extending a rotational axis of the tire and axially inward toward an
radially from a radially innermost edge of the ?rst side equatorial plane of the tire; and
wall to a radially outer ground engaging surface of the the axially outward facing outer surface of the step portions
tread area; and 20 of the lugs of the ?rst circumferential row of lugs slope
the axially outer surface of the circumferentially continu radially inward toward the rotational axis of the tire and
ous sidewall protector rib is located entirely above 60% axially outward away from the equatorial plane of the
of the sidewall height of the ?rst sidewall. tire.
2. The tire of claim 1, wherein: 7. The tire of claim 5, wherein:
the axially outer surface of the circumferentially continu 25 the circumferentially continuous sidewall protector rib has
ous sidewall protector rib slopes radially inward toward a radial width in a range of from 1.5 to 2.5 times a radial
a rotational axis of the tire and axially inward toward an width of the circumferentially broken sidewall protector
equatorial plane of the tire. rib.
3. The tire of claim 1, wherein: 8. The tire of claim 5, wherein:
the axially outer surface of the circumferentially continu 30 the ?rst sidewall includes an axially outer sidewall pro?le
ous sidewall protector rib is located entirely in a range of when Viewed in a radial cross-section; and
from 60% to 80% of the sidewall height of the ?rst the axially outward facing outer surface radially outward of
sidewall. the step portion of each of the lugs of the ?rst circum
4. A pneumatic tire, comprising: ferential row of lugs coincides with the axially outer
?rst and second sidewalls; 35 sidewall pro?le.
a tread area extending between the ?rst and second side 9. The tire of claim 8, wherein:
walls, the tread area including an inner tread surface and the circumferentially continuous sidewall protector rib
at least a ?rst circumferential row of lugs extending projects axially from the axially outer sidewall pro?le at
radially outward from the inner tread surface adjacent least twice as far as does the circumferentially broken
the ?rst sidewall; and 40 sidewall protector rib.
a circumferentially continuous sidewall protector rib 10. The tire of claim 8, wherein:
including a radially outer surface de?ned as an integral the circumferentially continuous sidewall protector rib
extension of the inner tread surface without any surface projects axially at least 0.25 inch beyond the axially
break line between the radially outer surface and the outer sidewall pro?le.
inner tread surface, and including an axially outer sur 45 11. A pneumatic tire, comprising:
face projecting axially at least as far as any other part of ?rst and second sidewalls;
the ?rst sidewall to protect the ?rst sidewall from dam a tread area extending between the ?rst and second side
aging engagement with foreign objects; walls, the tread area including an inner tread surface and
wherein the ?rst sidewall includes an axially outer sidewall at least a ?rst circumferential row of lugs extending
pro?le when Viewed in a radial cross-section; and 50 radially outward from the inner tread surface adjacent
wherein the axially outer surface of the circumferentially the ?rst sidewall; and;
continuous sidewall protector rib projects axially a circumferentially continuous sidewall protector rib
beyond the axially outer sidewall pro?le immediately including a radially outer surface de?ned as an integral
adjacent the circumferentially continuous sidewall pro extension of the inner tread surface without any surface
tector rib at least 0.25 inch. 55 break line between the radially outer surface and the
5. A pneumatic tire, comprising: inner tread surface, and including an axially outer sur
?rst and second sidewalls; face projecting axially at least as far as any other part of
a tread area extending between the ?rst and second side the ?rst sidewall to protect the ?rst sidewall from dam
walls, the tread area including an inner tread surface and aging engagement with foreign objects;
at least a ?rst circumferential row of lugs extending 60 wherein the tire has an aspect ratio of no greater than 80%
radially outward from the inner tread surface adjacent and ?ts on a wheel rim of 28 inches diameter.
the ?rst sidewall; and 12. A pneumatic tire, comprising:
a circumferentially continuous sidewall protector rib ?rst and second sidewalls;
including a radially outer surface de?ned as an integral a tread portion extending between the ?rst and second
extension of the inner tread surface without any surface 65 sidewalls, the tread portion including a radially inner
break line between the radially outer surface and the tread base, and a plurality of lugs extending radially
inner tread surface, and including an axially outer sur outward from the base, the ?rst sidewall having a side
Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 12 of 13 PageID #: 31
US 8,156,980 B2
10
Wall height extending radially from a radially innermost 17. The tire of claim 12, Wherein:
part of the ?rst sideWall to a radially outer ground engag the circumferentially continuous sideWall protector rib has
ing surface of the tread portion; a radial Width of at least 1.25 inch and projects axially
a circumferentially continuous sideWall protector rib outWard by a distance of at least 0.25 inch beyond any
located entirely above 60% of the sideWall height, the 5 immediately adjacent surface of the ?rst sideWall.
circumferentially continuous sideWall protector rib pro 18. The tire of claim 12, Wherein the tire has an aspect ratio
jecting axially outWard at least as far as any other part of of no greater than 80% and ?ts on a Wheel rim of 28 inches
the ?rst sideWall When the tire is in an in?ated loaded diameter.
condition; and 19. A pneumatic tire, comprising:
a circumferentially non-continuous sideWall protector rib
10 ?rst and second sideWall portions;
a tread portion extending betWeen the ?rst and second
located radially outWard from and radially adjacent to
sideWall portions, the tread portion including a ?oor and
the circumferentially continuous sideWall protector rib, at least a ?rst circumferentially spaced roW of lugs, each
the circumferentially non-continuous sideWall protector
lug of the ?rst roW of lugs including an axially outer
rib projecting axially outWard beyond the ?rst sideWall a
surface facing in generally the same axial direction as
distance less than does the circumferentially continuous
does the ?rst sideWall, each axially outer surface includ
sideWall protector rib.
13. The tire of claim 12, Wherein:
ing an axially outWardly projecting step projecting axi
ally outWard from the axially outer surface and adjoin
the circumferentially continuous sideWall protector rib
radially terminates adjacent the tread base. ing the ?oor; and
20 a circumferentially continuous sideWall protector rib pro
14. The tire of claim 12, Wherein:
jecting axially outWard from the ?rst sideWall portion
the ?rst sideWall includes a smooth continuously curved
and located radially inWard of and radially adjacent to
axially outer sideWall pro?le When VieWed in a radial
the axially outWardly projecting steps of the axially
cross-section; outer surfaces of the lugs of the ?rst roW of lugs, the
the plurality of lugs of the tread portion includes a ?rst roW
25 circumferentially continuous sideWall protector rib pro
of lugs adjacent the ?rst sideWall, each lug of the ?rst jecting axially outWard further than the axially out
roW of lugs includes an axially outer surface a radially
outermost portion of Which coincides With the sideWall
Wardly projecting steps.
20. The tire of claim 19, Wherein:
pro?le; and the circumferentially continuous sideWall protector rib
the sideWall pro?le is broken only by the axially outWardly projects axially outWard at least as far as any other part
projecting circumferentially non-continuous sideWall of the ?rst sideWall portion.
protector rib and the axially outWardly projecting cir 21. The tire of claim 20, Wherein:
cumferentially continuous sideWall protector rib.
15. The tire of claim 14, Wherein:
the axially outWardly projecting steps project axially out
Wardly from the ?rst sideWall portion and de?ne a cir
the circumferentially continuous sideWall protector rib cumferentially non-continuous sideWall protector rib
projects axially outWard beyond the axially outer side
Wall pro?le of the ?rst sideWall at least tWice as far as
concentrically disposed about the circumferentially
continuous sideWall protector rib.
does the circumferentially non-continuous sideWall pro
22. The tire of claim 19, Wherein the tire has an aspect ratio
tector rib.
of no greater than 80%.
16. The tire of claim 12, Wherein:
40 23. The tire of claim 19, Wherein the tire ?ts on a Wheel rim
the circumferentially continuous sideWall protector rib has
of 28 inches in diameter.
a radial Width of at least 1.9 times a radial Width of the
circumferentially non-continuous sideWall protector rib. * * * * *

Case 3:17-cv-00771 Document 1-1 Filed 04/28/17 Page 13 of 13 PageID #: 32


Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 1 of 11 PageID #: 33
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 2 of 11 PageID #: 34
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 3 of 11 PageID #: 35
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 4 of 11 PageID #: 36
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 5 of 11 PageID #: 37
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 6 of 11 PageID #: 38
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 7 of 11 PageID #: 39
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 8 of 11 PageID #: 40
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 9 of 11 PageID #: 41
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 10 of 11 PageID #: 42
Case 3:17-cv-00771 Document 1-2 Filed 04/28/17 Page 11 of 11 PageID #: 43
From: Kingsbury, Tom <KingsburyTom@bfusa.com>
Sent: Thursday, September 19, 2013 7:19 PM
To: Gray, Barb
Cc: Wood, Jon
Subject: Fwd: Ron's patents
Attachments: SidewallProtectorRib8156980B2April17,2012.pdf; ATT00001.htm; INVENTORS%
20INCENTIVE%20RULES[1].doc; ATT00002.htm

Barb,

Good job gathering the information. I'll talk to Jim Sube and Jon or I will respond to Ron.

I'll talk you tomorrow or Monday about it.

Tom

Sent from my iPhone

Begin forwarded message:

From: "Ronald Tatlock" <ronniet8597@att.net>


To: "Gray, Barb" <GrayBarb@bfusa.com>, "Spivey, Mitchell" <SpiveyMitchell@bfusa.com>,
"Kingsbury, Tom" <KingsburyTom@bfusa.com>
Cc: "Anne C. Martin" <amartin@bonelaw.com>, "Sube, Jim" <SubeJim@BFUSA.com>
Subject: Re: Ron's patents

Barb,

Thanks for all your hard work. I appreciate receiving the payment summary for my three patents
and the Inventor's Incentive Rules. The policy you so kindly provided states that utility patents
that have been commercialized are paid at $400 per inventor or $1200/patent. Since the utility
patent attached for which I am the sole inventor has been hugely commercialized, a $250
payment is not sufficient. Bridgestone has and continues to sell thousands of Firestone Duraforce
MH tires with the subject sidewall protector rib. Bridgestone has also marketed many Firestone
Duraload tires with this same feature which I designed into them also. The Duraload is now
coming out in a second size. Please provide assurance of the additional amount due
commensurate with the policy.

Thank you,

Ron Tatlock

From: "Gray, Barb" <GrayBarb@bfusa.com>


To: "Gray, Barb" <GrayBarb@bfusa.com>; Ron Tatlock <ronniet8597@att.net>; "Spivey,
Mitchell" <SpiveyMitchell@bfusa.com>; "Kingsbury, Tom" <KingsburyTom@bfusa.com>
Cc: Anne C. Martin <amartin@bonelaw.com>; "Sube, Jim" <SubeJim@BFUSA.com>

1
Case 3:17-cv-00771 Document 1-3 Filed 04/28/17 Page 1 of 4 PageID #: 44
Sent: Thursday, September 19, 2013 1:46 PM
Subject: RE: Ron's patents

Hi Ron -

Please find the additional information I found on your 2010 issued patents.

(2) paid $250 each (less taxes) - was included in your pay on 12/15/10.

I believe this was while you were still in Akron.

Thanks!

Barb Gray
Bridgestone Americas
Akron Law Department
ph: 330-379-4503
fax: 330-572-5104
email: graybarb@bfusa.com<mailto:graybarb@bfusa.com>

-----Original Message-----
From: Gray, Barb
Sent: Thursday, September 19, 2013 1:44 PM
To: 'Ron Tatlock'; Spivey, Mitchell; Kingsbury, Tom
Cc: Anne C. Martin; Sube, Jim
Subject: RE: Ron's patents

Please find the attached policy on the patent incentive program.

Actual monetary payouts are scheduled as follows:

11/1 - 4/30 - payment is made either 6/15 or last day of the month (included in normal pay)

5/1 - 10/31 - payment is made 12/15 (included in normal pay)

These applications, patents, etc are a one-time payout. No monetary payments continue after
separation of employment.

Retirees are still recognized at the Inventor Dinner when they have a patent granted the previous
year. (plate for plaque - no monetary payment).

Hope this helps!!

Barb Gray
Bridgestone Americas
Akron Law Department
ph: 330-379-4503
fax: 330-572-5104
email: graybarb@bfusa.com<mailto:graybarb@bfusa.com>
2
Case 3:17-cv-00771 Document 1-3 Filed 04/28/17 Page 2 of 4 PageID #: 45
-----Original Message-----
From: Ron Tatlock [mailto:ronniet8597@att.net<mailto:ronniet8597@att.net>]
Sent: Thursday, September 19, 2013 1:11 PM
To: Spivey, Mitchell; kingsberrytom@bfusa.com<mailto:kingsberrytom@bfusa.com>
Cc: Gray, Barb; Anne C. Martin; Sube, Jim
Subject: Re: Ron's patents

Thanks. I have three patents. One is a "utility patent". It is to have payments pursuant to the
added value it creates for the company. I know the now two tire designs duraForce Mh &
DuraLoad that include that patent "sidewall protector rib" are selling very well, especially the
DuraForce MH. I. I need please the policy on computing this in writing. 2, When is it paid? Do
payments continue for the life of the patent or do they cease at separation from employment? I
need assurance of payment pursuant to the policy in writing.

Sent from my iPhone

On Sep 19, 2013, at 9:55 AM, "Spivey, Mitchell"


<SpiveyMitchell@bfusa.com<mailto:SpiveyMitchell@bfusa.com>> wrote:

Ron,
Barb says you are all paid up. And she doesn't show any other record of things
due.

-----Original Message-----
From: Gray, Barb
Sent: Thursday, September 19, 2013 9:49 AM
To: Spivey, Mitchell
Subject: RE: Ron's patents

My records show that he had a patent granted in 2012 and he was paid ($250 less
taxes) in June 2012. The payments are included with regular pay (6/29/12).

He was recognized in Akron in 2013 for the award in 2012.

Mitchell Spivey, PHR


Director, Human Resources
Bridgestone Commercial Solutions
535 Marriott Dr. Nashville, TN, USA 37214
(615) 937-3244 Office | (615) 493-2305 E-Fax
(563) 260-4423 Mobile
3
Case 3:17-cv-00771 Document 1-3 Filed 04/28/17 Page 3 of 4 PageID #: 46
HR Contact Center - 855-873-6947
Click here for the MyHR Portal!

This message (including any attachments) is intended only for the individual or
entity to which it is addressed. It may contain confidential or privileged
information. If you are not the intended recipient, you are prohibited from
copying, disseminating or distributing this information except to the intended
recipient. If you have received this e-mail in error, please notify the sender by
return e-mail or call 615.937.3244. Thank you.

-----Original Message-----
From: Ron Tatlock [mailto:ronniet8597@att.net<mailto:ronniet8597@att.net>]
Sent: Saturday, September 14, 2013 8:35 PM
To: Spivey, Mitchell
Subject: Ron's patents

Mitch,

Barb Grey should have info.

Sent from my iPhone

4
Case 3:17-cv-00771 Document 1-3 Filed 04/28/17 Page 4 of 4 PageID #: 47
LIFT STAR

LIFT STAR is a bias-ply tire specially designed for telehandlers


operating in demanding construction operations and other
severe applications. Its low-profile sidewall ensures excellent
stability in high-lifting operations whereas its non-directional
tread design allows for greater mounting versatility. In addition,
the specially designed sidewall provides added cut-and-
puncture protection.

MACHINERY APPLICATIONS

INDUSTRIAL INDUSTRIAL
TELEHANDLER CONSTRUCTION

PLUS

HEAVY DUTY SERVICE STABILITY DURABILITY CUT & CHIP


RESISTANCE

All product data contained in this publication are for information purposes only and may be modified at any time without prior notice. Balkrishna Industries Ltd. or any of its subsidiary companies does not
undertake any responsibility or liability for undetected errors and/or misprints.
All rights reserved. The materials and contents of this publication and the website are the exclusive property of Balkrishna Industries Ltd. and are protected by industrial and/or intellectual property laws. The
Case 3:17-cv-00771 Document 1-4 Filed 04/28/17 Page 1 of 2 PageID #: 48
user is not permitted to copy, reproduce, transfer, upload, make use of, publish or spread any contents, in whole or in part, on paper format, electronic format or otherwise without prior written consent by
Balkrishna Industries Ltd..
PRODUCT: LIFT STAR

TECHNICAL DATA U/M: US STANDARD (INCH)

Size PR RIM REC SW OD SLR RC Type

370/75 - 28 14 11.00 14.4 50.0 23.0 151.6 TL


400/75 - 28 16 12.00 GR 15.7 51.9 23.3 155.3 TL

Case 3:17-cv-00771 Document 1-4 Filed 04/28/17 Page 2 of 2 PageID #: 49


All product data contained in this publication are for information purposes only and may be modified at any time without prior notice. Balkrishna Industries Ltd. or any of its subsidiary companies does not undertake any responsibility or liability for
undetected errors and/or misprints.
All rights reserved. The materials and contents of this publication and the website are the exclusive property of Balkrishna Industries Ltd. and are protected by industrial and/or intellectual property laws. The user is not permitted to copy, reproduce,
transfer, upload, make use of, publish or spread any contents, in whole or in part, on paper format, electronic format or otherwise without prior written consent by Balkrishna Industries Ltd..
JS 44 (Rev. 07/16) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS


BRIDGESTONE BRANDS, LLC, and BRIDGESTONE AMERICAS TIRE BALKRISHNA INDUSTRIES, LTD., BKT TIRES, INC. and BKT USA,
OPERATIONS, LC INC.
(b) County of Residence of First Listed Plaintiff Davidson County of Residence of First Listed Defendant N/A I ndia
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

Attorneys (IfKnown)
Street, Suite 2700,
Nashville, Tennessee 37219 (615) 244-6380; Finnegan, Henderson,
Farabow, Garrett & Duner, L.L.P. (202)408-4000

II. BASIS OF JURISDICTION (Placean "X" in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Placean "X" in One Box for Plaintiff
(For Diversity Cases Only) and One Boxfor Defendant)
1 U.S. Government H3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State

2 U.S. Government a 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship ofParties in Item III) of Business In Another State

Citizen or Subject of a a 3 3 Foreign Nation 6 6


Foreign Country
IV. NATURE OF SUIT (Place an X" in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES 1
110 Insurance PERSONAL INJURY PERSONAL INJURY fl 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine O 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers Product Liability H 830 Patent 450 Commerce
152 Recovery of Defaulted Liability n 368 Asbestos Personal 840 Trademark 460 Deportation
Student Loans 340 Marine Injury Product 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA(1395ff) 480 Consumer Credit
of Veterans Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) 490 Cable/Sat TV
160 StockholdersSuits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 850 Sccuritics/Commoditics/
190 Other Contract Product Liability 380 Other Personal Relations 864 SSID Title XVI Exchange
195 Contract Product Liability 360 Other Personal Property Damage 740 Railway Labor Act 865 RSI (405(g)) H 890 Other Statutory Actions
196 Franchise Injury 385 Property Damage 751 Family and Medical 891 Agricultural Acts
362 Personal Injury - Product Liability Leave Act 893 Environmental Matters
Medical Malpractice fl 790 Other Labor Litigation 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 791 Employee Retirement FEDERAL TAX SUITS Act
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: Income Security Act 870 Taxes (U.S. Plaintiff 896 Arbitration
220 Foreclosure 441 Voting 463 Alien Detainee or Defendant) 899 Administrative Procedure
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRSThird Party Act/Review or Appeal of
240 Torts to Land 443 Housing/ Sentence 26 USC 7609 Agency Decision
245 Tort Product Liability Accommodations 530 General 950 Constitutionality of
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION State Statutes
Employment Other: fj 462 Naturalization Application
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement

V. ORIGIN (Place an "X" in One Box Only)


X1 Original 2 Removed from 3 Remanded from 4 Reinstated or 0 5 Transferred from O 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 USC 271,281 and 289; 15 USC 1114Q )(b), 1116(d); 15 USC 1114(1), 1125(a)(1)(A),
VI. CAUSE OF ACTION Brief description ot cause:
Patent Infringement, trademark infringement, and unfair competition
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: X Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE
04^/2017
FOR OFFICE USE ONLY

RECEIPT it AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 3:17-cv-00771 Document 1-5 Filed 04/28/17 Page 1 of 4 PageID #: 50


Case 3:17-cv-00771 Document 1-5 Filed 04/28/17 Page 2 of 4 PageID #: 51
JS 44 Reverse (Rev. 07/16)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44


Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the puipose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I. (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy cleric or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.

V. Origin. Place an "X" in one of the seven boxes.


Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation - Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation - Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.

Case 3:17-cv-00771 Document 1-5 Filed 04/28/17 Page 3 of 4 PageID #: 52


Case 3:17-cv-00771 Document 1-5 Filed 04/28/17 Page 4 of 4 PageID #: 53
AO 440 (Rev. 12/09) Summons in a Civil Action

UNITED STATES DISTRICT COURT


for the
Middle District of Tennessee

BRIDGESTONE BRANDS, LLC, and BRIDGESTONE


AMERICAS TIRE OPERATIONS, LLC, )

Plaintiff

V. ) Civil Action No.


BALKRISHNA INDUSTRIES, LTD., BKT TIRES, INC., )
and BKT USA, INC. )

Defendant )

SUMMONS IN A CIVIL ACTION

To: (Defendant's nafne and address) BKT, USA, INC.


Serve through: Corporation Service Company
50 West Broad Street, Suite 1330
Columbus, Ohio 43215

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
whose name and address are: Robert E. Boston
Waller, Lansden, Dortch & Davis, LLP
511 Union Street, Suite 2700
Nashville, Tennessee 37219

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT
APB 2 9 2017
Date: _
Signa ure of Clerk or Deputy Clerk

_
Case 3:17-cv-00771 Document 1-6 Filed 04/28/17 Page 1 of 2 PageID #:
` -54
AO 440 (Rev. 12/09) Summons in a Civil Action

UNITED STATES DISTRICT COURT


for the
Middle District of Temiessee

BRIDGESTONE BRANDS, LLC, and BRIDGESTONE


AMERICAS TIRE OPERATIONS, LLC, )

Plaintiff v)
J
V. ) Civil Action No. -17k ) 7 71
BALKRISHNA INDUSTRIES, LTD., BKT TIRES, INC., )
and BKT USA, INC. )

Defendant )

SUMMONS IN A CIVIL ACTION

To: (Defendant's frame and address) BKT Tires, Inc.


12 Cadillac Drive
Brentwood, Tennessee 37027-5357

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
whose name and address are:
Robert E. Boston
Waller, Lansden, Dortch & Davis, LLP
511 Union Street, Suite 2700
Nashville, Tennessee 37219

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date: A 2 2017
Signature of Clerk or Deputy Clerk

Case 3:17-cv-00771 Document 1-6 Filed 04/28/17 Page 2 of 2 PageID #: 55

Vous aimerez peut-être aussi