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Case 2:18-cv-00778-DBP Document 2 Filed 10/04/18 Page 1 of 18

Peter M. de Jonge (7185)


Jed H. Hansen (10679)
Kurtis M. Hendricks (15626)
THORPE NORTH & WESTERN LLP
175 S. Main St., Suite 900
Salt Lake City, UT 84111
Telephone: (801) 566-6633
Facsimile: (801) 566-0750

Attorneys for
Connor CSCI International, LLC

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF UTAH, CENTRAL DISTRICT

CONNOR SPORT COURT


INTERNATIONAL, LLC, a Delaware
limited liability company, COMPLAINT
WITH JURY DEMAND
Plaintiff
v.
Case No. 2:18-cv-00778-DBP
SHIJIAZHUANG ENLIO SPORTS GOODS
CO., LTD, a Chinese company Magistrate Judge Dustin B. Pead

Defendant.

Connor Sport Court International, LLC, (hereinafter “CSCI” or “Plaintiff”), by and

through its counsel, hereby files this Complaint with Jury Demand against Shijiazhuang Enlio

Sports Goods Co., Ltd, doing business as Enlio Sports Goods (hereinafter “Enlio” or

“Defendant”) and alleges as follows:

PARTIES, JURISDICTION, AND VENUE

1. CSCI is a Delaware limited liability company with a principal place of business at

5445 W. Harold Gatty Drive, Salt Lake City, Utah 84116.

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2. Upon information and belief, Defendant is a Chinese corporation with its

principal place of business at 3-2-1404 Shiaohuayuan, Dong Gang Road, Yu Hua District,

Shijiazhuang, Hebei Province, 050000, China.

3. Plaintiff brings this action under U.S. patent laws, 35 U.S.C. §§ 1 et seq., and

further pursuant to Lanham Trademark Act, Title 15, United States Code § 1051, et seq., Utah

Code Ann. §§ 13-11a-3, 13-5a-102, 103, 70- 3a-403 and Utah common law.

4. This Court has subject matter jurisdiction over this action under 28 U.S.C. §§

1331, 1367, 1338 and 15 U.S.C. §§ 1114 and 1125.

5. This Court has supplemental jurisdiction over any state law, or statutory and

common law claims pursuant to 28 U.S.C. § 1367.

6. Upon information and belief, this Court has specific personal jurisdiction over

Defendant because Defendant has purposefully directed its activities toward the state of Utah by

selling its products—which infringe the patents at issue in this case—directly into the state of

Utah.

7. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391 and § 1400 at

least because, on information and belief, Defendant has committed acts of infringement in this

district, conducts business in this district directly related to the patents at issue in this case and is

subject to the court’s personal jurisdiction in this case.

BACKGROUND

8. CSCI is an industry leader in developing, manufacturing, marketing, distributing,

and selling various flooring products, including modular synthetic floor tiles. Since at least the

1970s, CSCI (and/or its predecessors-in-interest) has been in the business of selling athletic

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flooring and accessories and services, including synthetic modular floor tiles, under its SPORT

COURT mark.

CSCI’S PATENTS

9. CSCI has been awarded and is the owner of many patents relating to and covering

its floor tiles. Among the patents that CSCI has been awarded are U.S. Patent Nos. 8,424,257

(the “’257 Patent”), 8,407,951 (the “’951 Patent”) and D618,368 (the “’368 Patent”) (together,

the “Patents-in-Suit”), attached as Exhibits 1-3, respectively.

10. In accordance with 35 U.S.C. § 287, CSCI has given notice to the public of the

Patents-in-Suit by duly and properly marking all articles covered by these patents that have been

sold, offered for sale, or imported by CSCI.

CSCI’S TRADEMARKS

11. CSCI owns U.S. Trademark Reg. No. 1,100,976 for the mark SPORT COURT for

use in connection with “recreational patio installation services.” Exhibit 4.

12. CSCI owns U.S. Trademark Reg. No. 1,155,586 for the mark SPORT COURT for

use in connection with “sports equipment-namely, backboards, nets, racquets, balls, and ball

rebounders.” Exhibit 4.

13. CSCI owns U.S. Trademark Reg. No. 1,727,818 for the mark SPORT COURT for

use in connection with “recreational and athletic play surfaces and related equipment for said

surfaces; namely, nets, basketball backboards and lighting fixtures sold as a unit.” Exhibit 4.

14. CSCI owns U.S. Trademark Reg. No. 1,177,220 for the mark SPORT COURT for

use in connection with “sports equipment-namely, backboards, nets, racquets, balls, ball

rebounders” and “recreational patio installation services.” Exhibit 4.

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15. CSCI owns U.S. Trademark Reg. No. 2,479,328 for the mark SPORT COURT for

use in connection with “plastic interlocking floor tiles.” Exhibit 4.

16. Since at least April 1973, CSCI (and/or its predecessors-in-interest) has used the

SPORT COURT mark in commerce and enjoys substantial federal and common law trademark

rights in the SPORT COURT mark. These federal and common law marks are collectively

referred to herein as the “SPORT COURT Marks.”

17. As a result of CSCI’s long and extensive use of the SPORT COURT Marks, they

have become well known and highly respected in the athletic flooring industry.

18. CSCI’s goods and services have been widely advertised and extensively promoted

under the SPORT COURT Marks. Their flooring has been used in the National College Athletic

Association tournaments. The SPORT COURT Marks have acquired significant goodwill and

are assets of enormous value.

19. Through CSCI’s promotion and advertising under the SPORT COURT Marks, the

public has come to recognize the SPORT COURT Marks as emanating from CSCI.

20. The SPORT COURT Marks are distinctive and not generic.

21. Upon information and belief, due to CSCI’s quality goods and services and

extensive use of the SPORT COURT Marks, the marks have become famous.

DEFENDANT’S MISCONDUCT

22. Enlio is in the business of making, using, selling, offering for sale, and/or

importing into the United States a variety of athletic flooring products.

23. Enlio’s products are sold through online retailers in U.S. dollars, where they are

purchased by consumers throughout the United States, including the State of Utah. See Exhibit

5.

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24. Upon information and belief, Enlio manufactures, markets, and sells a modular

floor tile marketed as Enlio Double Layer I (hereinafter “Double Layer I”). An example of the

Double Layer I is shown in Exhibit 6.

25. Upon information and belief, Enlio manufactures, markets, and sells a modular

floor tile marketed as Enlio Double Layer Soft-connection II (hereinafter “Soft-connection II”,

and together with Double Layer I referred to hereinafter as “Accused Products”). An example

of the Soft-connection II is shown in Exhibit 7.

26. Enlio has not obtained permission from CSCI to use any of the rights attendant to

the Patents-in-Suit in connection with the Accused Products.

27. The Double Layer I includes design features that are substantially the same as the

claimed subject matter of the ‘368 Patent, as illustrated in the example below:

The ‘368 Patent Double Layer I

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28. As demonstrated above, the design of the Double Layer I is substantially the same

as the claim of the ‘368 Patent such that an ordinary observer purchasing the Double Layer I

would believe that he had purchased the patented CSCI design.

29. By reason of Enlio’s infringing acts, CSCI has suffered damage in an amount to

be proven at trial. The harm to CSCI from Enlio’s infringing activities is not fully compensable

by monetary damages, and CSCI will continue to suffer irreparable harm unless Enlio’s

infringing conduct is enjoined.

30. Upon information and belief, Enlio acted in an objectively reckless manner with

respect to CSCI’ patent rights. Upon information and belief, Enlio has made, sold, offered to sell,

and/or imported into the United States the Accused Products knowing that it was highly likely

that its acts would infringe the Patents-in-Suit. As a result, Enlio has engaged in willful

infringement of the Patents-in-Suit, and CSCI is therefore entitled to treble damages, interest,

costs, and attorney’s fees in accordance with 35 U.S.C. §§ 284 and 285.

31. Upon information and belief, Defendant also uses SPORT COURT in

Defendant’s Name.

32. Upon information and belief, Defendant has represented itself as “ENLIO

SPORT COURT INTERNATIONAL” to the Federation Internationale de Volleyball

(“FIVB”) and its members, as evidenced by the FIVB’s Certificate of Recommendation for

Enlio and the FIVB’s Homologation Equipment List. See Exhibit 8.

33. Upon information and belief, Defendant has constructive notice that CSCI

owns federal trademark registrations for SPORT COURT and that CSCI owns trademark rights

in the SPORT COURT Marks.

34. Upon information and belief, Defendant has actual notice that CSCI owns

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federal trademark registrations for SPORT COURT and that CSCI owns trademark rights in the

SPORT COURT Marks.

35. Upon information and belief, Defendant infringes the SPORT COURT Marks

through its use of the mark and confusingly similar marks in connection with athletic flooring

goods and services.

36. Defendant’s actions are likely to cause consumer confusion as to the

source of its goods and services and cause a false association between Defendant and CSCI.

37. Upon information and belief, Defendant’s actions have resulted in, and will

continue to result in, substantial and irreparable harm to CSCI and to consumers.

38. Upon information and belief, Defendant intended to and did trade on the

substantial goodwill associated with the SPORT COURT Marks, and has intentionally misled

the public into assuming a connection between CSCI and Defendant.

39. Upon information and belief, Defendant’s actions constitute a knowing and

willful false designation of origin of Defendant’s goods and services.

40. Upon information and belief, Defendant’s actions have caused and will

continue to cause irreparable injury to CSCI.

FIRST CAUSE OF ACTION


(Infringement of the ‘257 Patent)

41. CSCI realleges and incorporates by reference all the foregoing paragraphs.

42. Upon information and belief, the Accused Products infringe at least one claim of

the ‘257 Patent.

43. Upon information and belief, by making, using, selling, offering for sale, and/or

importing into the United States the Accused Products, Enlio has in the past, does now, and

continues to directly infringe, contributorily infringe, and/or induce others to infringe the claims
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of the ‘257 patent literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

271.

44. Claim 1 of the ‘257 Patent recites:

A modular floor tile, comprising:

a perimeter;

an upper contact surface within the perimeter;

a plurality of openings formed in said upper contact surface, each of said openings
comprising a plurality of internal angles defined by intersecting structural
members, wherein said structural members comprise an upper planar contact
surface and a side surface;

wherein at least some of said structural members further comprise a transition


surface extending between the upper planar contact surface and the side surface
defining a blunt edge between the upper planar contact surface and the side
surface; and

a plurality of support members extending downward from at least some of the


intersecting structural members.

45. Upon information and belief, both the Double Layer I and Soft-connection II

include each and every element of claim 1 of the ‘257 Patent.

46. By reason of Enlio’s infringement of the claims of the ‘257 Patent alleged herein,

CSCI has suffered damage in an amount to be proven at trial. The harm to CSCI from Enlio’s

infringing activities are not fully compensable by monetary damages, and CSCI will continue to

suffer irreparable harm unless Enlio’s infringing conduct is enjoined.

47. Upon information and belief, Enlio acted in an objectively reckless manner with

respect to CSCI’ patent rights. Upon information and belief, Enlio has made, sold, offered to sell,

and/or imported into the United States the Accused Products knowing that it was highly likely

that its acts would infringe the ‘257 Patent. As a result, Enlio has engaged in willful infringement

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of the ‘257 Patent, and CSCI is therefore entitled to treble damages, interest, costs, and

attorney’s fees in accordance with 35 U.S.C. §§ 284 and 285.

SECOND CAUSE OF ACTION


(Infringement of the ‘951 Patent)

48. CSCI realleges and incorporates by reference all the foregoing paragraphs.

49. Upon information and belief, the Accused Products infringe at least one claim of

the ‘951 Patent.

50. Upon information and belief, by making, using, selling, offering for sale, and/or

importing into the United States the Accused Products, Enlio has in the past, does now, and

continues to directly infringe, contributorily infringe, and/or induce others to infringe the claims

of the ‘951 patent literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

271.

51. Claim 1 of the ‘951 Patent recites:

A modular synthetic floor tile comprising:

an upper contact surface;

a plurality of openings formed in said upper contact surface, each of said openings
having a geometry defined by structural members configured to intersect with one
another at various intersection points to form at least one acute angle as measured
between imaginary axes extending through said intersection points, said structural
members having a smooth, planar top surface forming said contact surface, and a
face oriented transverse to said top surface; and

a transition surface extending between said top surface and said face of said
structural members comprising a blunt edge between said top surface and said
face.

52. Upon information and belief, both the Double Layer I and Soft-connection II

include each and every element of claim 1 of the ‘951 Patent.

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53. By reason of Enlio’s infringement of the claims of the ‘951 Patent alleged herein,

CSCI has suffered damage in an amount to be proven at trial. The harm to CSCI from Enlio’s

infringing activities are not fully compensable by monetary damages, and CSCI will continue to

suffer irreparable harm unless Enlio’s infringing conduct is enjoined.

54. Upon information and belief, Enlio acted in an objectively reckless manner with

respect to CSCI’ patent rights. Upon information and belief, Enlio has made, sold, offered to sell,

and/or imported into the United States the Accused Products knowing that it was highly likely

that its acts would infringe the ‘951 Patent. As a result, Enlio has engaged in willful infringement

of the ‘951 Patent, and CSCI is therefore entitled to treble damages, interest, costs, and

attorney’s fees in accordance with 35 U.S.C. §§ 284 and 285.

THIRD CAUSE OF ACTION


(Infringement of the ‘368 Patent)

55. CSCI realleges and incorporates by reference all the foregoing paragraphs.

56. Upon information and belief, the Double Layer I includes design features that are

substantially the same as the ornamental design claimed in the ‘368 Patent to an ordinary

observer giving such attention as a purchaser usually gives.

57. By making, using, selling, offering for sale, and/or importing into the United

States the Double Layer I, Enlio has in the past, does now, and continues to directly infringe the

claims of the ’368 patent in violation of 35 U.S.C. § 271.

58. By reason of Enlio’s infringement of the claim of the ’368 Patent alleged herein,

CSCI has suffered damage in an amount to be proven at trial. The harm to CSCI from Enlio’s

infringing activities is not fully compensable by monetary damages, and CSCI will continue to

suffer irreparable harm unless Enlio’s infringing conduct is enjoined.

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59. Upon information and belief, Enlio acted in an objectively reckless manner with

respect to CSCI’ patent rights. Upon information and belief, Enlio has made, sold, offered to sell,

and/or imported into the United States the Double Layer I knowing that it was highly likely that

its acts would infringe the ‘368 Patent. As a result, Enlio has engaged in willful infringement of

the ‘368 Patent, and CSCI is therefore entitled to treble damages, interest, costs, and attorney’s

fees in accordance with 35 U.S.C. §§ 284 and 285.

FOURTH CAUSE OF ACTION


(Infringement of Federally Registered Trademarks - 15 U.S.C. § 1114)

60. CSCI realleges and incorporates by reference all the foregoing paragraphs.

61. CSCI owns valid U.S. trademark registrations for the SPORT COURT Marks.

62. Defendant’s acts are likely to cause confusion, to cause mistake, or to deceive and

are trademark infringement pursuant to 15 U.S.C. § 1114.

63. Upon information and belief, Defendant’s infringement of the SPORT COURT

Marks has caused and continues to cause damage and irreparable injury to the value and

goodwill of the SPORT COURT Marks as well as damage and cause irreparable injury to

CSCI’s goodwill, business, and reputation.

64. Upon information and belief, Defendant’s actions are deliberate, willful,

fraudulent, and constitute a knowing infringement of the SPORT COURT Marks.

65. CSCI is entitled to injunctive relief under 15 U.S.C. § 1114.

66. CSCI is entitled to damages and to recover Defendant’s profits, in an amount to

be proven at trial, pursuant to 15 U.S.C. § 1117(a).

67. CSCI is entitled to recover treble damages pursuant to 15 U.S.C. § 1117(b).

68. CSCI is entitled to an award of costs and attorneys’ fees pursuant to 15 U.S.C. §

1117(a).

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FIFTH CAUSE OF ACTION


(Federal False Designation of Origin and Unfair Competition - 15 U.S.C. § 1125(a))

69. CSCI realleges and incorporates by reference all of the foregoing paragraphs.

70. CSCI owns the SPORT COURT Marks.

71. Defendant’s actions are likely to cause confusion, or to cause mistake, or to

deceive as to the affiliation, connection, or association of Defendant with CSCI, or as to the

origin, sponsorship, or approval of Defendant’s goods, services, or commercial activities.

72. Defendant’s conduct constitutes false designation of origin and unfair competition

pursuant to 15 U.S.C. § 1125(a).

73. Upon information and belief, CSCI has been and will continue to be damaged by

Defendant’s actions.

74. Upon information and belief, CSCI has suffered actual damages and lost profits

caused by Defendant’s infringement of the SPORT COURT Marks, in an amount to be proven at

trial. Additionally, the harm to CSCI from Defendant’s actions is not fully compensable by

money damages. CSCI has suffered and continues to suffer, irreparable harm that has no

adequate remedy at law and that will continue unless the infringement committed by Defendant

is permanently enjoined.

75. Upon information and belief, Defendant knew of CSCI’s trademark rights and

willfully infringed the SPORT COURT Marks and Defendant’s actions are willful, intentional

and/or deliberate.

76. CSCI is entitled to injunctive relief and monetary damages against Defendant

pursuant to 15 U.S.C. § 1117.

77. CSCI is entitled to an award of treble damages pursuant to 15 U.S.C. § 1117.

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78. CSCI is entitled to an award of attorneys’ fees pursuant to 15 U.S.C. § 1117.

SIXTH CAUSE OF ACTION


(Utah Deceptive Trade Practices - Utah Code Ann. § 13-11a-3)

79. CSCI realleges and incorporates by reference all of the foregoing paragraphs.

80. Upon information and belief, Defendant has passed off Defendant’s goods and/or

services as those of CSCI.

81. On information and belief, Defendant has knowingly made false representations

as to source, sponsorship, approval, or certification of Defendant’s goods and/or services by use

of the SPORT COURT Marks, and did so having knowledge of the SPORT COURT Marks.

82. Defendant’s conduct is likely to cause confusion or misunderstanding as to

affiliation, connection, or association between Defendant and CSCI.

83. Defendant’s conduct constitutes a violation of the Utah Deceptive Trade Practices

Act, Utah Code Ann. § 13-11a-3.

84. CSCI is entitled to recover damages for Defendant’s conduct pursuant to Utah

Code Ann. § 13-11a-4.

85. CSCI is entitled to recover attorneys’ fees pursuant to Utah Code Ann. § 13-11a-

4.

86. CSCI is entitled to enjoin Defendant from further use of its marks pursuant to

Utah Code Ann. § 13-11a-4.

SEVENTH CAUSE OF ACTION


(Utah Unfair Competition - Utah Code Ann. § 13-5a-101 et seq.)

87. CSCI realleges and incorporates by reference all of the foregoing paragraphs.

88. Upon information and belief, Defendant has willfully, intentionally, and/or

recklessly infringed the SPORT COURT Marks.

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89. Defendant’s infringement of the SPORT COURT Marks is unlawful.

90. Upon information and belief, Defendant’s infringement of the SPORT COURT

Marks leads to a material diminution in value of the SPORT COURT Marks.

91. Accordingly, Defendant’s actions constitute unfair competition in violation of the

Utah Unfair Competition Act, Utah Code Ann. § 13-5a-101 et seq.

92. CSCI has suffered actual damages, including lost profits, as a result of

Defendant’s unfair business practices in an amount to be proven at trial. Additionally, the harm

to CSCI arising from these acts is not fully compensable by money damages. CSCI has suffered,

and continues to suffer, irreparable harm that has no adequate remedy at law and that will

continue unless the unfair competition committed by Defendant is permanently enjoined.

93. CSCI is entitled to damages in an amount to be proven at trial pursuant to Utah

Code Ann. § 13-5a-103.

94. CSCI is entitled to punitive damages in an amount to be proven at trial pursuant to

Utah Code Ann. § 13-5a-103.

95. CSCI is entitled to costs and attorneys’ fees Pursuant to Utah Code Ann. § 13-5a-

103.

EIGHTH CAUSE OF ACTION


(Federal Trademark Dilution - 15 U.S.C. § 1125(c))

96. CSCI realleges and incorporates by reference all of the foregoing paragraphs.

97. CSCI’s SPORT COURT Marks are famous and distinctive and are entitled to

protection against dilution pursuant to 15 U.S.C. § 1125(c).

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98. Defendant’s use of CSCI’s SPORT COURT Marks and/or marks that are

confusingly similar is likely to cause dilution by blurring or dilution by tarnishment, pursuant to

15 U.S.C. § 1125(c).

99. Upon information and belief, CSCI has been and will continue to be damaged by

Defendant’s use of CSCI’s SPORT COURT Marks and/or marks that are confusingly similar.

100. Upon information and belief, Defendant’s actions are willful, intentional and/or

deliberate.

101. CSCI is entitled to injunctive relief pursuant to 15 U.S.C. § 1117.

102. CSCI is entitled to an award of treble damages and an award of attorneys’ fees

pursuant to 15 U.S.C. § 1117.

NINTH CAUSE OF ACTION


(Utah Trademark Dilution - Utah Code Ann. § 70-3a-403)

103. CSCI realleges and incorporates by reference all of the foregoing paragraphs.

104. Plaintiff’s SPORT COURT Marks are famous and distinctive in Utah and are

entitled to protection against dilution.

105. Defendant’s use of SPORT COURT and/or confusingly similar terms commenced

after the SPORT COURT Marks became famous.

106. By using the SPORT COURT Marks and/or confusingly similar terms in

connection with its own goods and services, Defendant has created a likelihood of consumer

confusion, has lessened the capacity of CSCI’s famous marks to identify and distinguish CSCI’s

goods and services, and has consequently diluted the distinctive quality of the SPORT COURT

Marks in violation of Utah Code Ann. § 70- 3a-403.

107. Upon information and belief, CSCI has been and will continue to be damaged by

Defendant’s use of the SPORT COURT mark and/or confusingly similar terms.

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108. Because, upon information and belief, Defendant’s actions were willful,

intentional and/or deliberate, CSCI is entitled to an award of damages and disgorgement of

profits, pursuant to Utah Code Ann. §§ 70-3a-403, 404.

109. CSCI is entitled to injunctive relief pursuant to Utah Code Ann. § 70-3a-404.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor

and award Plaintiff relief as follows:

A. That the Court enter judgment that Defendant has infringed the claims of the

Patents-in-Suit either directly and/or by the doctrine of equivalents;

B. That the Court enter judgment that Defendant’s Double Layer I product infringes

the ‘257 Patent;

C. That the Court enter judgment that Defendant’s Double Layer I product infringes

the ‘951 Patent;

D. That the Court enter judgment that Defendant’s Double Layer I product infringes

the ‘368 Patent;

E. That the Court enter judgment that Defendant’s Soft-connection II product

infringes the ‘257 Patent;

F. That the Court enter judgment that Defendant’s Soft-connection II product

infringes the ‘951 Patent;

G. That the Court preliminarily and permanently enjoin Defendant, its officers,

agents, servants, employees, successors, assigns and all other persons in active concert or

participation with any of them, enjoining them from directly or indirectly infringing in any

manner the claims of the Patents-in-Suit;

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H. That the Court enter judgment granting Plaintiffs damages adequate to

compensate it for Defendant’s infringement of the Patents-in-Suit, including an award of

Defendant’s total profits, in amounts to be proven at trial;

I. That the Court enter judgement finding that Defendant willfully infringed the

Patents-in-Suit, that this is an exceptional case, and that the Court award Plaintiff enhanced

damages, costs, and attorney’s fees in accordance with 35 U.S.C. § 285 or other applicable law;

J. That the Court enter judgment declaring that Defendant’s actions infringe

Plaintiff’s registered SPORT COURT Marks in violation of 15 U.S.C. § 1114;

K. That the Court enter judgment declaring that Defendant’s actions infringe

Plaintiff’s common law trademark rights in the SPORT COURT Marks in violation of the

Lanham Act, 15 U.S.C. § 1125;

L. That the Court enter judgment declaring that Defendant’s actions constitute unfair

competition and false designation of origin in violation of 15 U.S.C. § 1125;

M. That the Court enter judgment that Defendant is liable for deceptive

trade practices under Utah Code Ann. § 13-11a-3;

N. That the Court enter judgment declaring that Defendant’s conduct

constitutes unfair competition in violation of Utah Code Ann. §13-5a-101 et seq.;

O. That the Court enter judgment that Defendant has diluted the famous SPORT

COURT Marks in violation of 15 U.S.C. § 1125;

P. That the Court enter judgment that Defendant has diluted the SPORT

COURT Marks in violation of Utah Code Ann. § 70-2a-403;

Q. That the Court preliminarily and permanently enjoin Defendant from using the

terms “sports court” or any term that infringes the SPORT COURT Marks, unfairly competes

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with CSCI, or dilutes the SPORT COURT Marks;

R. That the Court require Defendant to pay monetary damages to CSCI in an

amount to be proven at trial;

S. That the Court require Defendant to pay prejudgment and post-judgment

interest until such awards are paid;

T. That the Court require Defendant to pay treble damages in an amount to be proven

at trial;

U. That the Court award CSCI punitive damages;

V. That the Court require Defendant to pay CSCI’s costs and attorneys’ fees

incurred in this action;

W. That CSCI have such other and further relief as shall seem just and proper to

the Court.

JURY DEMAND

Plaintiff demands that all claims and causes of action raised in this Complaint be tried to a

jury to the fullest extent possible under the United States and Utah Constitutions.

DATED this 4th day of October, 2018

THORPE NORTH & WESTERN LLP

/s/ Peter M. de Jonge


Peter M. de Jonge
Jed H. Hansen
Kurtis M. Hendricks

Attorneys for
Connor Sport Court International, LLC

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EXHIBIT 1 
Case 2:18-cv-00778-DBP Document 2-1 Filed 10/04/18 Page 2 of 23
USOO8424257B2

(12) United States Patent (10) Patent No.: US 8.424,257 B2


Jenkins et al. (45) Date of Patent: *Apr. 23, 2013

(54) MODULARTILE WITH CONTROLLED (56) References Cited


DEFLECTION
U.S. PATENT DOCUMENTS
(76) Inventors: Mark L. Jenkins, Salt Lake City, UT 69,297 A 9, 1867 Stafford
(US); Jeremiah Shapiro, West Valley 321,403 A 6, 1885 Underwood
City, UT (US); Cheryl Forster, Salt 658,868 A 10/1900 Rosenbaum
Lake City, UT (US); Vaughn W. North, (Continued)
Salt Lake City, UT (US); David L. Stott,
Providence, UT (US) FOREIGN PATENT DOCUMENTS
CN 222 1623 6, 1996
(*) Notice: Subject to any disclaimer, the term of this EP 0044371 1, 1982
patent is extended or adjusted under 35 (Continued)
U.S.C. 154(b) by 0 days.
OTHER PUBLICATIONS
This patent is Subject to a terminal dis
claimer. Synthetic Floor Tile; 88 pages.
(21) Appl. No.: 13/079,572 (Continued)
(22) Filed: Apr. 4, 2011 Primary Examiner – William Gilbert
Assistant Examiner — Chi Nguyen
(65) Prior Publication Data (74) Attorney, Agent, or Firm — Thorpe North & Western
LLP
US 2012/OO85043 A1 Apr. 12, 2012
(57) ABSTRACT
Related U.S. Application Data A modular tile configured to interlock with multiple tiles to
(63) Continuation of application No. 12/789,161, filed on form a modular floor covering over a floor. The tile includes a
May 27, 2010, which is a continuation of application top Surface having a periphery defining side walls extending
No. 11/065,192, filed on Feb. 24, 2005, now Pat. No. 7, downward from the top surface, the side walls having a cou
748,177. pling portion configured to couple with other tiles adjacent
thereto to form the modular floor covering. The tile also
(60) Provisional application No. 60/547,489, filed on Feb. includes a bottom side, opposite the top surface, having a
25, 2004. Support grid including an array of downward extending poly
meric post structures, at least Some of the post structures
(51) Int. Cl. including at least one resilient end portion with a radial end
E04F II/6 (2006.01) Surface configured to be positioned against the floor to facili
(52) U.S. Cl. tate controlled deflection of the post structures. The post
USPC ................. 52/177; 52/180; 52/390; 52/591.1 structures may comprise primary and secondary post struc
(58) Field of Classification Search .................... 52/177, tures, with the secondary post structures limiting the deflec
52/506.01, 592.1, 391, 386, 387: 404/35, tion of the primary post structures.
404/41, 47: 15/215
See application file for complete search history. 23 Claims, 10 Drawing Sheets
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U.S. PATENT DOCUMENTS 5,022,200 A 6, 1991 Wilson et al.


1,177,231 3, 1916 Carter 5,039,365 A 8, 1991 Rutledge et al.
5,048.448 A 9, 1991 Yoder
1425,324 8, 1922 Kennedy 5,052,158 A 10, 1991 D'Luzansky
1896,957 2, 1933 Hutcheson 5, 1992 Munsey et al.
1971,320 8, 1934 Cederquist 5,111,630 A
D327,748 S 7, 1992 Dorfman, Jr.
2,082.563 6, 1937 Bauer 9, 1992 Skinner
2,653.525 9, 1953 Sargeant 5,143,757 A
5,160,215 A 11, 1992 Jensen
2,680,698 6, 1954 Schnee 2, 1993 Phenicie et al.
2,810,672 10, 1957 Taylor 5,185,193 A
1, 1962 Doe 5, 190,799 A 3, 1993 Ellingson
3,015, 136 5,205,091 A 4, 1993 Brown
3,122,073 2, 1964 Masse 4, 1993 Taylor
3,251,076 5, 1966 Burke 5,205,092 A
3,310,906 3, 1967 Glukes 5,215,802 A 6, 1993 Kaars Sipsteijin
5,228,253 A 7, 1993 WatteleZ.
3,332,192 7, 1967 Kessler et al. 7, 1993 Knight
3,428,920 2, 1969 Oleksiak 5,229.437 A
5,234,738 A 8, 1993 Wolf
3,438,312 4, 1969 Becker et al. 10, 1993 Bohnhoff
3,511,001 5, 1970 Morgan 5,250,340 A
5,253,464 A 10, 1993 Nilsen
3,531,902 10, 1970 Costa 3, 1994 Kajiwara
10, 1971 5,295,341 A
3,611,609 Nelnhard 5,303,669 A 4, 1994 Szekely
3,614.915 10, 1971 Perry 5,323,575 A 6, 1994
3,717.247 2, 1973 Moore 8, 1994 Close
3,735.988 5, 1973 Palmer et al. 5,342,141 A
5,364,204 A 11, 1994 MacLeod
3,775,918 12, 1973 Johnson 11, 1994 Randjelovic
3,795,180 3, 1974 Larsen 5,365,710 A
5,412,917 A 5, 1995 Shelton
3,802,144 4, 1974 Spica 5,418,036 A 5, 1995 Tokikawa et al.
3,823,521 7, 1974 Heitholt et al. 9, 1995 Housley
3,909,996 10, 1975 Ettlinger et al. 5.449.246 A
5,466,489 A 11, 1995 Stahl
3,922.409 11, 1975 Stark 4, 1996 Bentzon
3,925,946 12, 1975 Balinski et al. 5,509,244 A
5,511,353 A 4, 1996 Jones
3,946,529 3, 1976 Chevaux
4,008,548 2, 1977 Leclerc 5,527,128 A 6, 1996 Rope et al.
5,542,221 A 8, 1996 Streitet al.
4,018,025 4, 1977 Collette 1/1997 Adam
4,054,987 10, 1977 Forlenza D377,398 S
5,616,389 A 4, 1997 Blatz
4,118,892 10, 1978 Nakamura et al. 5, 1997 Kung
4,133,481 1, 1979 Bennett 5,628, 160 A
5,634,309 A 6, 1997 Polen
4,167,599 9, 1979 Nissinen 6, 1997 Koch
4,201.965 5, 1980 Onyshkevych 5,640,821 A
5,642,592 A 7/1997 Andres
D255,744 T. 1980 Dekko 7/1997 Davis
4,226,060 10, 1980 Sato 5,647,184 A
10, 1980 Kraayenhof 5,682,724 A 11/1997 Randjelovic
4,226,064 5,693,395 A 12, 1997 Wine
4,274,626 6, 1981 Grosser et al. 2, 1998 Mitchell
4,287,693 9, 1981 Collette 5,713, 175 A
4,361,614 11, 1982 Moffitt, Jr. 5,713,806 A 2, 1998 Teitgen et al.
5,735,096 A 4, 1998 Krass
4,436,779 3, 1984 Menconi et al. 5, 1998 Jank
4,440,818 4, 1984 Buchan et al. 5,749,787 A
5,758.467 A 6, 1998 Snear et al.
D274,948 T. 1984 Swanson et al. 6, 1998 Carling
4,468,910 9, 1984 Morrison 5,761,867 A
5,787,654 A 8, 1998 Drost
4.478,901 10, 1984 Dickens et al. 10, 1998 Adam
4.478,905 10, 1984 Neely, Jr. et al. 5,815,995 A
5,816,010 A 10, 1998 Conn
4497,858 2, 1985 Dupont et al. 5,816,738 A 10, 1998 Harnapp
4,509,930 4, 1985 Schweigert et al. 5,820,294 A 10, 1998 Baranowski
4,526,347 7, 1985 McLoughlin 5,822,828 A 10, 1998 Berard et al.
4,577,448 3, 1986 Howorth 11, 1998 Rosan et al.
4,584,221 4, 1986 Kung 5,833,386 A
5,848,856 A 12, 1998 Bohnhoff
4,590,731 5, 1986 DeGooyer 5,865,007 A 2, 1999 Bowman et al.
4,596,729 6, 1986 Morrison 5, 1999 Stroppiana
D286,575 11, 1986 Saunders 5,899,038 A
5,906,082 A 5, 1999 Counihan
4,640,075 2, 1987 Nuncio 5, 1999 Medico et al.
4,648,592 3, 1987 Harinishi 5,906,454 A
5,907,934. A 6, 1999 Austin
4,650, 180 3, 1987 Blondel 6, 1999 Anderson et al.
4,681,786 7, 1987 Brown 5,910.401 A
5.937,602 A 8, 1999 Jalbert
4,694,627 9, 1987 Omholt 9, 1999 Council et al.
4,702.048 10, 1987 Millman 5,950,378 A
D415,581 S 10, 1999 Bertolini
4,715,743 12, 1987 Schmanski 11, 1999 Carling et al.
4,727,697 3, 1988 Vaux 5.992,106 A
6,017,577 A 1, 2000 Hostettler et al.
4,728,468 3, 1988 Duke 3, 2000 Rosan et al.
4,749,302 6, 1988 DeClute 6,032,428 A
6,044,598 A 4, 2000 Elsasser et al.
4,766,020 8, 1988 Ellingson, Jr. 6,047,663 A 4, 2000 Moreau et al.
4,807,412 2, 1989 Frederiksen 5/2000 Kessler et al.
4,819,932 4, 1989 Trotter 6,068,908 A
5, 1989 Haberhauer et al. 6,095,718 A 8, 2000 Bohnhoff
4,826,351 8, 2000 Skandis
4,849,267 7, 1989 Ward et al. 6,098,354 A
4,860,510 8, 1989 Kotler 6,101,778 A 8, 2000 Martensson
4,875,800 10, 1989 Hicks 6,112,479 A 9, 2000 Andres
4,877,672 10, 1989 Shreiner 6,128,881 A 10, 2000 Bue et al.
4,917,532 4, 1990 Haberhauer et al. 6,134,854 A 10, 2000 Stanchfield
4,930,286 6, 1990 Kotler D435,122 S 12, 2000 Ross et al.
4,948,116 8, 1990 Vaux 6,171,015 B 1, 2001 Barth et al.
4,963,054 10, 1990 Hayashi D437.427 S 2, 2001 Shaffer
Case 2:18-cv-00778-DBP Document 2-1 Filed 10/04/18 Page 4 of 23

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6,189,289 B1 2/2001 Quaglia et al. 7,527.451 B2 5, 2009 Slater


6,228.433 B1 5, 2001. Witt 7,531,055 B2 5, 2009 Mead
6,230,460 B1 5/2001 Huyett 7,563,052 B2 7/2009 Van Reijen
6,231939 B1 5, 2001 Shaw et al. 7,571,572 B2 8/2009 Moller, Jr.
6,286,272 B1 9, 2001 Sandoz 7,571,573 B2 8, 2009 Moller
6,301,842 B1 * 10/2001 Chaney et al. .................. 52/177 7.587,865 B2 9/2009 Moller, Jr.
6,302,803 B1 10/2001 Barlow RE41,140 E 2/2010 Heath
6,321,499 B1 1 1/2001 Chuang D611,626 S 3/2010 Arden
6,324,796 B1 12/2001 Heath 7,676,291 B2 3/2010 Gettig
6,345.483 B1 2, 2002 Clark 7,704,011 B2 4/2010 Marshall
6,355,323 B1 3, 2002 Iwen et al. 7,748,176 B2 7/2010 Harding et al.
D456,533 S 4/2002 Moller, Jr. 7,748,177 B2 7/2010 Jenkins et al.
6,418,683 B1 7/2002 Martensson et al. 7,900,416 B1 3/2011 Yokubison et al.
6,428,870 B1 8, 2002 Bohnhoff 7,950,191 B2 5, 2011 Brouwers
6,436,159 B1 8, 2002 Safta et al. 2001/0002523 A1 6/2001 Chen
6,444,284 B1 9, 2002 Kessler et al. 2002/0152702 A1 10/2002 Tseng
6,451,400 B1 9, 2002 Brocket al. 2003/OOO9971 A1 1/2003 Palmberg
6,453,632 B1 9/2002 Huang 2003. O148813 A1 8, 2003 Barlow
6,467,224 B1 10/2002 Bertolini 2003. O190969 A1 10, 2003 Barlow et al.
6,526,705 B1 3/2003 MacDonald 2004/OO23006 A1 2/2004 Mead
6,531,203 B2 3/2003 Kessler et al. 2004/OO35079 A1 2/2004 Even
6,543,196 B1 4/2003 Gonzales 20040182030 A1 9, 2004 Hinault et al.
6,562.414 B2 5/2003 Carling 2004/0235580 A1 11/2004 Barlow et al.
6,578,324 B2 6, 2003 Kessler et al. 2004/0258869 A1 12, 2004 Walker
6,585,449 B2 7, 2003 Chen 2005, OO16098 A1 1, 2005 Hahn
6,588,166 B2 7/2003 Martensson et al. 2005/0O28475 A1 2/2005 Barlow et al.
6,605,333 B2 8, 2003 Ferreira et al. 2005. O144867 A1 7, 2005 Clarke
6,606,834 B2 8/2003 Martensson et al. 2005/O193670 A1 9, 2005 Niese et al.
6,617,009 B1 9, 2003 Chen et al. 2005/0202208 A1 9/2005 Kelly
D481,138 S 10/2003 Forster et al. 2005/0204676 A1 9, 2005 Weitzer
D481,470 S 10/2003 Moller, Jr. 2005/0252109 A1 11/2005 Fuccella et al.
6,637,163 B2 10/2003 Thibault et al. 2006,0070314 A1 4/2006 Jenkins
6,669,572 B1 12/2003 Barlow 2006, 0080909 A1 4/2006 Harding et al.
6,672,970 B2 1/2004 Barlow 2006/0265975 A1 11, 2006 Geffe
6,672,971 B2 1/2004 Barlow 2006/0272252 Al 12/2006 Moller, Jr.
6,682,254 B1 1/2004 Olofsson et al. 2006/0285920 A1 12/2006 Gettig et al.
D486,592 S 2/2004 Hong 2007/0214741 A1 9/2007 Llorens Miravet
6,684,582 B2 2/2004 Peart et al. 2007/0289244 Al 12/2007 Haney et al.
6,684,592 B2 2/2004 Martin 2008/0092473 A1 4/2008 Heyns
6,695,527 B2 2/2004 Seaux et al. 2008/O127593 A1 6/2008 Janesky
6,718,714 B1 4/2004 Montgomery 2008. O168736 A1 7, 2008 Pervan
6,718,715 B2 4, 2004 Elliott 2008/0172968 A1 7/2008 Pacione
6,736,569 B2 5, 2004 Lee 2008/0216437 A1 9, 2008 Prevost et al.
6,739,797 B1 5, 2004 Schneider 2008/0271410 A1 11/2008 Matthee
D492.426 S 6, 2004 Strickler 2008/0295437 A1 12/2008 Dagger
6,751,912 B2 6/2004 Stegner et al. 2009 OO31658 A1 2/2009 Moller, Jr. et al.
6,769,219 B2 8, 2004 Schwitte et al. 2009.0049768 A1 2, 2009 Kim
6,793,586 B2 9, 2004 Barlow et al. 2009, O1391.60 A1 6, 2009 H11
6,802,159 B1 10/2004 Kotler 2009/0235,605 A1 9/2009 Haney
6,833,038 B2 12/2004 Iwen et al. 2010. 0236176 A1 9/2010 Jenkins
6,851,236 B1 2/2005 Harvey 2011/004.5916 A1 2/2011 Casimaty et al.
6,878.430 B2 4/2005 Milewski et al.
6,880,307 B2 4/2005 Scheitte et al. FOREIGN PATENT DOCUMENTS
6,895,881 B1 5, 2005 Whitaker EP 1167652 1, 2002
6,962,463 B2 11/2005 Chen FR 2240320 3, 1975
7,021,012 B2 4/2006 Zeng et al. GB 1504811 3, 1978
7,029,744 B2 4/2006 Horstman et al. GB 2262437 12/1991
D522,149 S 5, 2006 Shin GB 2263644 8, 1993
7,047,697 B1 5, 2006 Heath GB 2353543 10, 2000
7,065,935 B2 6, 2006 Ralf JP O1-226978 9, 1989
7,090,430 B1 8, 2006 Fletcher et al. JP 3045,788 11, 1997
7,096,632 B2 8, 2006 Pacione JP 2000-248729 9, 2000
7,114.298 B2 10, 2006 Kotler KR 20-0239521 10, 2001
7,127,857 B2 10, 2006 Randjelovic KR 10-2006-0 127635 12/2006
D532,530 S 11/2006 Shuman et al. KR 100743984 8, 2007
7,131,788 B2 11/2006 Ianniello et al. WO WO92-O1130 1, 1992
7,144,609 B2 12/2006 Reddick
7,155,796 B2 1, 2007 Cook OTHER PUBLICATIONS
7,211,314 B2 5, 2007 Nevison
7,299,592 B2 11/2007 Moller, Jr. Inter Partes Reexamination for Patent No. 7,748,177; Request filed
7.303,800 B2 12/2007 Rogers Dec. 29, 2011; 192 pages.
7.340,865 B2 3/2008 Vanderhoef Application 95/000,651; filed Dec. 29, 2011; office action issued Feb.
7,383,663 B2 6, 2008 Pacione 3, 2012.
7,386,963 B2 6, 2008 Pervan U.S. Appl. No. 12/789,161, filed May 27, 2010; Mark L. Jenkins;
7,412,806 B2 8, 2008 Pacione et al. office action issued Sep. 1, 2010.
7.464510 B2 12/2008 Scott et al. Synthetic Floor Tile; pp. 1-254.
7,516,587 B2 4/2009 Barlow www.invisiblestructures.com webiste Jul. 26, 2006, 109 pages.
7,520,948 B2 4/2009 Tavy et al. www.mateflex.stores.yahoo.net websiter Jul. 26, 2006, 68 pages.
D593,220 S 5, 2009 Reed www.namintec.com, website, Jul. 26, 2006, 28 pages.
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www.polypavement.com/costs.htm, website Mar. 24, 2006, pp. 1-2. Inter Partes Reexamination 95/000,651; filing date Dec. 29, 2011;
www.polypavement.com/more info.htm, website Mar. 24, 2006 pp. Response to Office Action filed May 2, 2012.
1-12. Inter Partes Reexamination 95/000,651; filing date Dec. 29, 2011;
www.polypavement.com/index.htm, website Mar. 24, 2006, pp. 1-6. Petition Under 37 C.F.R. SS 1.181-182 for 30 Days From Service to
www.arplastsrl.com website, 1 page. File Third-Party Comments in Inter Partes Reexamination in View of
www.polypavement com contactus. Non-Service of Office Action; Petition filing date Apr. 3, 2012.
PCT Application PCT/US2011/022802; filed Jan. 28, 2011; Ronald Inter Partes Reexamination 95/000,651; filing date Dec. 29, 2011;
N. Cerny; International Search Report mailed Sep. 1, 2011.
Affidavit of Christopher Butler; signed Jan. 24, 2011; received by Third Party Requester Comments. After Non-Final Action filed May
Thorpe North and Western on Jul. 8, 2011; 13 pages. 29, 2012.
Inter Partes Reexamination 95/000,651; filing date Dec. 29, 2012; Inter Partes Reexamination 95/000,651; filing date Dec. 29, 2011;
Declaration of Jeremiah Shapiro; filed Nov. 18, 2011. Reexam Petition Decision filed Jun. 5, 2012.
Inter Partes Reexamination 95/000,651; filing date Dec. 29, 2011; Ex Parte Reexamination 90/020,003; filing date May 29, 2012:
Request for Inter Partes Reexamination filed Dec. 29, 2011. Request for Ex Parte Reexamination.
Inter Partes Reexamination 95/000,651; filing date Dec. 29, 2011;
Office Action mailed Feb. 3, 2012. * cited by examiner
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U.S. Patent Apr. 23, 2013 Sheet 1 of 10 US 8.424,257 B2

118

FIG.

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Case 2:18-cv-00778-DBP Document 2-1 Filed 10/04/18 Page 8 of 23

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US 8,424,257 B2
1. 2
MODULARTILE WITH CONTROLLED ranges and impacts on the synthetic flooring. Further, the
DEFLECTION current synthetic flooring materials do not exhibit the spring
or bounce characteristics found in wood flooring.
RELATED APPLICATIONS Therefore, it would be advantageous to provide a flooring
tile that facilitates greater "give' to impacts as well as pro
This application is a continuation of U.S. patent applica viding a spring characteristic to the flooring tile that is com
tion Ser. No. 12/789,161, filed May 27, 2010; which is a parable or superior to that found in wood flooring while also
continuation of U.S. patent application Ser. No. 11/065,192, being easy to manufacture, long lasting and cost efficient.
Further, it would be advantageous to provide a flooring tile
filed Feb. 24, 2005, now U.S. Pat. No. 7,748,177 and entitled, that has predictable load absorbing characteristics.
“Modular Tile with Controlled Deflection, which claims the 10
benefit of U.S. Provisional Patent Application No. 60/547, SUMMARY OF THE INVENTION
489, filed Feb. 25, 2004, and entitled, “Modular Tile with
Controlled Deflection.” both of which are incorporated by In light of the problems and deficiencies inherent in the
reference in their entirety herein. prior art, the present invention seeks to overcome these by
15 providing a tile configured to interlock with multiple tiles to
FIELD OF THE INVENTION form a modular floor covering over a floor, wherein the tile is
configured to provide controlled deflection of its support
The present invention relates generally to modular syn members.
thetic tiles for use as a floor covering and, more particularly, In accordance with the invention as embodied and broadly
the present invention relates to a Support grid in the tiles. described herein, the present invention features a tile config
ured to form a floor covering over a floor. In one exemplary
BACKGROUND OF THE INVENTION AND embodiment, the tile comprises (a) a top surface having a
RELATED ART periphery defining side walls extending downward from the
top surface, the side walls having a coupling portion config
Numerous types of flooring have been used to create play 25 ured to couple with other tiles adjacent thereto to form the
ing areas for Such sports as basketball and tennis, as well as modular floor covering; and (b) a bottom side, opposite the
for other purposes. These flooring assemblies include con top surface, having a Support grid including an array of down
crete, asphalt, wood and other materials which have varying ward extending polymeric post structures, at least Some of the
characteristics. For each type of flooring, there are corre post structures including at least one resilient end portion
sponding advantages and disadvantages. For example, con 30
with a radial end Surface configured to be positioned against
crete flooring is easy to construct and provides long term the floor to facilitate controlled deflection of the post struc
tures.
wear. However, the concrete provides no "give” during use In another exemplary embodiment the tile comprises (a) a
and many people are injured each year during sporting events top surface configured to receive and distribute a load; (b) side
due to falls and other mishaps. Wood floors, such as are used walls extending downward from the top surface and defining
for many basketball courts, have an appropriate amount of 35 a periphery of the tile; (c) a bottom side, opposite the top
give to avoid such injuries. The wood floors, however, are Surface, having a Support grid configured to support the top
expensive to install and require continued maintenance to surface above the floor; (d) a plurality of primary post struc
keep them in good condition. tures extending downward from and arranged about the bot
Due to these concerns, the use of modular flooring assem tom side, the primary post structures including at least one
blies made of synthetic materials has grown in popularity. The 40 end portion in contact with the floor and configured to facili
synthetic floors are advantageous for several reasons. A first tate controlled deflection of the primary post structures in
reason for the flooring assemblies' popularity is that they are response to a load; and (e) a plurality of secondary post
typically formed of materials which are generally inexpen structures also extending downward from the bottom side and
sive and lightweight. If a tile is damaged it may easily be interspaced with or about the primary post structures, the
replaced. If the flooring needs to be temporarily removed, the 45 secondary post structures including at least one end portion
individual tiles making up the floor can easily be detached, configured to contact the ground and Support the top surface
relocated, and then reattached to form a new floor in another upon deflection of the primary post structures.
location. Examples of modular flooring assemblies include The present invention also features a method for manufac
U.S. Pat. No. Des. 274,588; U.S. Pat. Nos. 3,438,312; 3,909, turing a tile configured to form a floor covering over a floor. In
996; 4,436,799; 4,008,548; 4,167,599; 4,226,064 and U.S. 50 one exemplary embodiment, the method comprises (a) pro
Pat. No. Des. 255,744. viding a tile having a top surface, a bottom Surface, and sides
A second reason for the popularity of the flooring assem extending down from the top surface to form a periphery of
blies is that the durable plastics from which they are formed the tile; (b) arranging a plurality of primary post structures
are long lasting. Unlike other long lasting alternatives, such as about the bottom side, wherein the primary post structures
asphalt and concrete, the material is generally better at 55 include at least one end portion in contact with the floor and
absorbing impacts, and there is less risk of injury if a person configured to facilitate controlled deflection of the primary
falls on the plastic material, as opposed to concrete or asphalt. post structures in response to a load; and (c) interspacing a
The connections for the modular flooring assembly can even plurality of secondary post structures with or about the pri
be specially engineered to absorb lateral force to avoid inju mary post structures, wherein the secondary post structures
ries, as is described in U.S. Pat. No. 4,930.286. Additionally, 60 include at least one end portion configured to contact the
the flooring assemblies generally require little maintenance ground and Support the top Surface upon the deflection of the
as compared to other flooring, such as wood. However, there primary post structures.
is a need for synthetic flooring to have better impact absorb
ing qualities than that found in current synthetic flooring BRIEF DESCRIPTION OF THE DRAWINGS
materials. In particular, current synthetic flooring does not 65
include characteristics of predictable and controlled deflec The present invention will become more fully apparent
tion within the synthetic tiles under certain predicted load from the following description and appended claims, taken in
Case 2:18-cv-00778-DBP Document 2-1 Filed 10/04/18 Page 17 of 23

US 8,424,257 B2
3 4
conjunction with the accompanying drawings. Understand FIG. 16 illustrates a detailed side view of the exemplary
ing that these drawings merely depict exemplary embodi modular floor tile of FIG. 10 showing the deflection positions
ments of the present invention they are, therefore, not to be of the primary post structures and the downward displace
considered limiting of its scope. It will be readily appreciated ment of the secondary post structures to engage or contact the
that the components of the present invention, as generally 5 floor.
described and illustrated in the figures herein, could be
arranged and designed in a wide variety of different configu DETAILED DESCRIPTION OF EXEMPLARY
rations. Nonetheless, the invention will be described and EMBODIMENTS
explained with additional specificity and detail through the
use of the accompanying drawings in which: 10 The following detailed description of exemplary embodi
FIG. 1 illustrates a partial top view of a modular tile, ments of the invention makes reference to the accompanying
depicting coupling portions extending from the tile, accord drawings, which form a part hereof and in which are shown,
ing to an embodiment of the present invention; by way of illustration, exemplary embodiments in which the
FIG. 2 illustrates a top view of multiple tiles modularly invention may be practiced. While these exemplary embodi
interconnected in an array, according to an embodiment of the 15 ments are described in sufficient detail to enable those skilled
present invention; in the art practice the invention, it should be understood that
FIG. 3 illustrates a partial profile view of a modular tile, other embodiments may be realized and that various changes
depicting a Support grid with post structures for the tile that to the invention may be made without departing from the
allows deflection of end portions of the post structures upon a spirit and scope of the present invention. Thus, the following
load being placed on the tile, according to an embodiment of more detailed description of the embodiments of the present
the present invention; invention, as represented in FIGS. 1 through 16, is not
FIG. 3(a) illustrates an enlarged view the post structure, intended to limit the scope of the invention, as claimed, but is
depicting end portions of the post structures in a deflected presented for purposes of illustration only and not limitation
position, according to an embodiment of the present inven to describe the features and characteristics of the present
tion; 25 invention, to set forth the best mode of operation of the
FIG. 4 illustrates a partial bottom view of the support grid invention, and to sufficiently enable one skilled in the art to
of the tile in FIG. 3, depicting end portions oriented to deflect practice the invention. Accordingly, the scope of the present
in first and second bi-lateral directions, according to an invention is to be defined solely by the appended claims.
embodiment of the present invention; The following detailed description and exemplary embodi
FIG. 5 illustrates a partial bottom view of another embodi 30 ments of the invention will be best understood by reference to
ment of the modular tile depicted in FIG. 3, depicting the end the accompanying drawings, wherein the elements and fea
portions having an elongated configuration and oriented to tures of the invention are designated by numerals throughout.
deflect in the first and second bi-lateral directions, according The present invention describes a method and system for
to the present invention; controlling the deflection of a modular tile.
FIG. 6 illustrates a partial profile view of another embodi 35 FIGS. 1-3 illustrate a modular tile 100 configured to be
ment of a modular tile, depicting the post structures of the interconnected into a tile array 105 to form a floor covering
Support grid having a single end portion extending therefrom, over a floor surface 101, such as a tennis court, basketball
according to the present invention; court or any other suitable floor surface. The modular tiles
FIG. 7 illustrates a partial bottom view of the support grid 100 of the present invention are configured to provide
of the modular tile in FIG. 6, according to an embodiment of 40 enhanced "give' or, rather, means for absorbing impacts to
the present invention; facilitate improved safety for the various sporting activities
FIG. 8 illustrates a partial profile view of another embodi typically conducted on the tile array105. Further, the tiles 100
ment of a Support grid of a modular tile, according to the of the present invention can provide bounce or spring to those
present invention; playing on the tile array 105 similar to wood flooring. Such
FIG. 9 illustrates a partial profile view of another embodi 45 tiles 100 can be formed from any suitable synthetic type
ment of a Support grid of a modular tile, according to the material. Such as a polymeric material, and formed using
present invention; conventional molding techniques, such as injection molding,
FIG. 10 illustrates a perspective view of a modular tile as well known by one of ordinary skill in the art.
according to another exemplary embodiment of the present The modular tile 100 can include a top surface 110 with an
invention, wherein the modular floor tile comprises a plurality 50 opposite bottom side 112 or under-side. The top surface 110
of primary post structures and a plurality of secondary post can be Smooth, perforated, grid-like, bumped or any other
structures comprising a shorter length than the primary post suitable surface desired for a synthetic tile floor covering. The
structures, such that the secondary post structures are caused bottom side 112 may also comprise a smooth, perforated,
to contact the floor upon deflection of the primary post struc grid-like, bumped, or other Suitable Surface configuration.
tures under a given load; 55 The top surface 110 can include a periphery with a square or
FIG. 11 illustrates a top view of the surface of the exem rectangular shape, defining a front side 114, a rear side 116, a
plary modular floor tile of FIG. 10; FIG. 12 illustrates a first side 118 and a second side 120. Other suitable peripheral
detailed perspective view of the surface of the exemplary shapes for the tiles can also be employed. Such as triangular,
modular floor tile of FIG. 10; hexagonal, etc.
FIG. 13 illustrates a rear view of the post structure configu 60 Each of the front side, rear side, first side and second side
ration of the exemplary modular floor tile of FIG. 10; can include side walls 122 with one or more coupling portions
FIG. 14 illustrates a detailed rear view of the post structure 124 integrated therewith. In particular, two adjacent sides,
configuration of the exemplary modular floor tile of FIG. 10; such as the first side 118 and the front side 114, can include
FIG. 15-A illustrates a side view of the exemplary modular one or more male coupling portions 126 while the opposite
floor tile of FIG. 10; 65 two sides, namely the second side 120 and the rear side 116
FIG. 15-B illustrates a detailed side view of the exemplary can include one or more female coupling portions 128. The
modular floor tile of FIG. 10; and male and female coupling portions 126 and 128 of one tile can
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be configured to complimentarily mate with respective bi-lateral direction 150 and the end portions 134 for an adja
female and male coupling portions of other adjacently posi cent post structure 130 can be oriented to allow the end
tioned tiles. With this arrangement, the tiles 100 can be modu portions 134 to controllably deflect laterally in a second bi
larly interconnected, via the male and female coupling por lateral direction 152. The first bi-lateral direction 150 can be
tions 126 and 128, into columns and rows to form the tile transverse to the second bi-lateral direction 152. In this man
array 105 for positioning over the floor surface 101. ner, the orientation of the end portions 134 in the post struc
With reference to FIG.3, the bottom side 112 of the tile 100 ture array 135 can be a checkered orientation configuration.
includes a Support grid configured to Support the top Surface Other orientation configurations can also be implemented,
110 of the tile 100. The support grid can include multiple post Such as staggered orientation configurations, row orientation
structures 130 extending downward a length so as to Suspend 10 configurations, column orientation configurations, etc. For
the side walls 122 of the tile 100. The post structures 130 can example, a column orientation configuration can include the
include an upper portion 132 and one or more end portions orientation of the end portions 134 being similarly oriented
134. The upper portion 132 can extend downward from the within one column with the first bilateral direction 150 and an
bottom side 112 of the tile 100 and the end portions can extend adjacent column can include orientations of the end portions
downward from the upper portion 132. In one embodiment, 15 134 with the second bilinear direction 152. As one of ordinary
each post structure 130 can include two end portions 134 skill in the art can readily appreciate, there are numerous
extending from the upper portion 132. Each end portion 134 orientation configurations that can be implemented in the post
can include a radial surface end 136, of which the radial structures to control the directional deflection or movement of
Surface end 136 can be configured to be positioned against the end portions 134 and, further, control the impact absor
and directly contact the floor surface 101. The end portions bency of the tiles 100.
134 can be sized and configured to be flexible and resilient as With reference to FIG. 5, in another embodiment of the
well as durable. modular tile 200, the upper portion 232 of the post structures
With reference to FIGS. 3 and 3(a), the end portions 134 of 230 can include a square periphery 242. As in the previous
the post structures 130 are configured to absorb impacts embodiment, there can also be two end portions 234 extend
applied at the top surface of the modular tile 100. In particular, 25 ing downward from the upper portion 232 of the post struc
when a load L or impact is applied to the top surface 110, the tures 230, as depicted and described with respect to FIG.3. In
radial surface end 136 of the end portions below the load L this embodiment, the two end portions 234, for one post
induces such end portions 134 to displace against the floor structure 230, can be elongated at least partially along a width
surface 101 and be forced in a lateral direction 148 to a lateral 238 of the post structure 230, spaced apart, and oriented
deflected position. As can be appreciated by one of ordinary 30 substantially parallel to each other. The elongated structure of
skill in the art, the direction by which the end portions 134 the end portions 234 can facilitate resilient deflection of the
slide and deflect can be dependent upon the placement and end portions 234 with controlled bi-lateral movement, as in
direction of the load L with respect to the radial surface end the embodiment previously set forth. Further, the orientation
136 of the endportions 134. When such load L is removed, the configuration of the respective end portions 234 in the post
end portions 134 can resiliently move back to their original 35 structure array 235 can be in a checkered orientation configu
position. Further, as the end portions 134 are in a loadbearing ration, or any other Suitable orientation configuration as set
deflected position, the end portions provide an upward spring forth in the previous embodiment.
force F due to the resilient characteristic of the end portions FIGS. 6 and 7 illustrate another embodiment of the support
134. With this arrangement, the end portions 134 facilitate grid of the modular tile 300 including the post structure array
impact absorbency or “give in the tile to provide a greater 40 335. In this embodiment, the post structures 330 can include
degree of safety for those on the tiles 100 as well as provide a single end portion 334 configured to extend downward from
additional spring in the tiles 100. the upper portion 332 of the post structure 330. As in the
Further, the end portions 134, in this embodiment, can previous embodiments, the end portion 334 can include a
resiliently deflect while the upper portion 132 of the post radial surface end 336 to facilitate resilient deflection in a
structures 130 can be configured to have a substantially main 45 lateral direction dependent upon the position of the load L
tained position. As such, the upper portion 132 of each of the applied at the top surface 310. In this embodiment, the end
post structures 130 provides the necessary support for the tiles portions 334 can be an elongated projection extending down
100 while the end portions 134 provide the impact absor ward from the upper portion 332 of the post structure 330.
bency component for the tiles 100. As one of ordinary skill in Further, the end portions 334 can resiliently deflect in any
the art can readily appreciate, the end portions 134 of the post 50 suitable lateral direction 350 with respect to a longitudinal
structures 130 can be modified in size and configuration axis 352 of the post structure 330.
according to the amount of controlled deflection or impact FIG. 8 illustrates another embodiment of the post structure
absorbency desired for an intended use or activity for playing array 435 at the bottom side 412 of the tile 400. In this
on the tiles 100. Further, the type of synthetic material embodiment, the post structures 430 can include an end por
employed for the tiles 100 can also be a factor for the size and 55 tion 434 with a cross-sectional area similar to the upper por
configuration of the post structures 130 to provide the amount tion 432 of the post structures 430. The cross-section of each
of deflection or impact absorbency desired in the tiles 100. of the post structures 430 can be sized and configured such
With reference to FIG.4, a bottom view of the support grid that the end portions 434 can provide the impact absorbency
is depicted, illustrating the post structures 130 in a post struc intended by being resiliently deflectable while also providing
ture array 135 of rows and columns. In one embodiment, the 60 sufficient support at the upper portion 432 of the post struc
upper portion 132 of the post structures 130 can include a tures 430. As in the previous embodiments, the end portions
circular periphery 142. As such, the upper portion can have a 434 can include the radial surface end 436 to readily facilitate
cylindrical shape or conical shape. Further, each post struc lateral sliding against the floor Surface 101 upon a load L
ture 130 can include two end portions 132, spaced apart, with being applied to the top surface 410 of the tile 100. In one
opposing outer circular peripheries 144. As depicted, the end 65 embodiment, the post structures 430 can be sized and config
portions 134 for one post structure 130 can be oriented to ured so that the end portions 434 can resiliently deflect in any
allow the end portions 134 to controllably deflect in a first suitable lateral direction 450 with respect to a longitudinal
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axis 452 of the post structure 430, as in the previous embodi the modular tiles described above are designed to do, the
ment. Alternatively, the post structures 430 can be sized and modular tile 600 shown in FIG. 10 is configured to provide
configured to be elongated along their width to control the enhanced "give' or, rather, means for absorbing impacts to
direction of lateral movement by which the end portions 434 facilitate improved safety for the various sporting activities
can bend, similar to that described and depicted with respect typically conducted on the tile array. Further, the modular tile
to FIG.S. 600 of the present invention can provide bounce or spring to
FIG. 9 illustrates another embodiment of the tile 500 with those playing on the tile array in a similar manner as wood
the post structure array 535. The post structures 530 in this flooring and the like. The modular tile 600 is also configured
embodiment can taper downward to an end portion 534, to perform other functions that will be addressed below or that
wherein the end portion 534 can include a radial surface end 10 will be obvious to those skilled in theart. The modulartile 600
536. As such, the end portion 534 of each of the post struc may be formed from any suitable synthetic type of material,
tures 530 can be resiliently deflectable upon a load L being Such as a polymeric material, and may be formed using con
applied to the top surface 510 of the tiles 500, similar to the ventional molding techniques, such as injection molding, and
previous embodiments. The post structures 530 in this others that are commonly known.
embodiment can be conical, pyramidal, or any other suitable 15 With reference to FIGS. 10-13, the modular tile 600
tapering post structure, such as an elongated width structure includes a surface configuration. In one aspect, the tile 600
to facilitate directional control in the deflection of the end can include a surface 610 with an opposite bottom side or
portions 534. In one embodiment where the post structures under-side and sidewalls defining a periphery. The top Surface
530 are conical, the end portions 534 can resiliently bend in 610 can be smooth, perforated, grid-like, bumped or any other
any suitable lateral direction 550 with respect to a longitudi suitable surface desired for a synthetic tile floor covering. The
nal axis 552 of the post structure 530. In an alternative bottom side may also be Smooth, perforated, grid-like,
embodiment where the post structures 530 include an elon bumped or any other Suitable Surface. As shown, the Surface
gated width, the direction by which the end portions resil 610 of the modular tile 600 comprises a bi-level surface, or a
iently deflect can be substantially controlled to bend with plurality of surfaces. An upper surface 611 is defined by a
bi-lateral movement. 25 diamond-shaped grid-like pattern. A lower surface 613 is
As one of ordinary skill in the art can readily appreciate, the defined by a square-shaped grid-like pattern formed and oper
post structures of the present invention can include various able with the upper surface 611. The modular tile 600 can
configurations that can deflect under various ranges of loads include a periphery with a square or rectangular shape, defin
and impacts. As such, the configuration of the post structures ing a front side 614, a rear side 616, a first side 618 and a
can be formed with deflection control to deflect at particular 30 second side 620. Other suitable peripheral shapes for the
load ranges by, for example, manipulating the radius of cur modular tile 600 can also be employed, such as triangular,
vature of the end portions, sizing the cross-sectional area of hexagonal, etc.
the end portions and/or sizing the upper portions of the post Each of the front side 614, rear side 616, first side 618 and
structures to withstand over-deflection, manipulating the ori second side 620 can include side walls 622 with one or more
entation configuration of the post structures to control the 35 coupling portions 624 integrated therewith. In particular, two
direction of deflection of the post structures, etc. For example, adjacent sides, such as the first side 618 and the frontside 614,
the radius of curvature in the end portions radial surface end can include one or more male coupling portions 626 while the
can be smaller in the embodiment depicted in FIG. 9 com opposite two sides, namely the second side 620 and the rear
pared to the radius of curvature in the end portions depicted in side 616 can include one or more female coupling portions
FIG. 8. As such, the end portions depicted in FIG. 8 may 40 628. The male and female coupling portions 626 and 628 of
require a larger load or impact to effect deflection of the end one tile can be configured to complimentarily mate with
portions than that required in the end portions depicted in respective female and male coupling portions of other adja
FIG.9. Such various configurations of the post structures can cently positioned tiles. With this arrangement, the several
be determined by one of ordinary skill in the art to facilitate tiles can be modularly interconnected, via the male and
the controlled deflection desired for a given type of activity 45 female coupling portions 626 and 628, into columns and rows
predicted to be played on the array of tiles. to form a tile array for positioning over the surface of a floor.
FIGS. 10-16 illustrate various features of a modular tile With reference to FIGS. 13 and 14, illustrated are respec
configuration according to another exemplary embodiment of tive rear views of the modular tile 600 shown in FIGS. 10-12,
the present invention. The modular tile illustrated in FIGS. and described above, with FIG. 14 illustrating a detailed rear
10-16 is similar to the exemplary modular tiles discussed 50 view of a portion of the modular tile 600. The bottom side of
above and shown in the drawings. However, this particular the tile 600 includes a support grid configured to support the
modular tile embodies an alternative controlled deflection top surface 610 of the tile 600. The support grid can include
concept. multiple post structures in the form of primary and secondary
With reference to FIG. 10, illustrated is a perspective view post structures 630 and 660, each extending downward a
of an exemplary modular tile 600 having a bi-level or multi 55 length from the bottom side. The primary post structures 630
level surface structure. However, other single level surface include an upper portion 632 and one or more end portions
tile configurations may also be used with the controlled 634. The upper portion 632 can extend downward from the
deflection concept discussed herein, thus the illustration of a bottom side of the tile 600 and the end portions 634 can extend
bi-level Surface is not meant to be limiting in any way. Indeed, downward from the upper portion 632. The primary post
the controlled deflection concept discussed herein with ref 60 structure 630 may comprise any shape, size, and configura
erence to FIGS. 10-16 may be incorporated into any single tion, such as those discussed above in relation to FIGS. 1-9.
Surface tile configuration, Such as those discussed above in Likewise, the secondary post structures 660 include an upper
reference to FIGS. 1-9. portion 662 and one or more end portions 664. The upper
The modular tile 600 is configured to be interconnected portion 662 can extend downward from the bottom side of the
with a plurality of other tiles to form a tile array, such as the 65 tile 600 and the end portions 664 can extend downward from
one described above, for the purpose of forming a floor cov the upper portion 662. These also can be any shape, size, and
ering over a floor surface, similar to those identified above. As configuration. The primary and secondary post structures 630
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and 660 are arranged about the bottom side of the tile accord detailed side view of a portion of the modular tile 600. As
ing to any conceivable arrangement, which may include a shown, the primary post structures 630 extend downward
patterned arrangement, a random arrangement, and a layered from the underside of the lower surface (not shown, but see
arrangement. surface 613 in FIG. 12) and comprise end portions 634 that
As shown, the modular tile 600 comprises a plurality of 5 are configured to be in contact with the floor or ground 601 at
primary post structures 630 interspaced with a plurality of all times. The secondary post structures 660 extend down
secondary post structures 660 to comprise the support for the ward from the underside of the upper surface (not shown, but
modular tile 600, and particularly the surface 610 of the see upper surface 611 in FIG. 12) and comprise end portions
modular tile 600. More specifically, each secondary post 664 configured to terminate at a position above the floor 601
structure 660 is positioned to be immediately adjacent or 10 a distance X. This distance X may vary as desired. As such, the
surrounded by four primary post structures 630 located at secondary post structures 660 may comprise the same or a
quadrant positions. In addition, each primary post structure different length than the primary post structures 630, depend
630 is immediately adjacent or surrounded by at least four ing upon the surface configuration of the modular tile 600. For
secondary post structures 660. This alternating pattern of example, the secondary post structures 660 may comprise a
primary and secondary post structures is repeated several 15 different length than the primary post structures both are
times to comprise the Support structure of the modular tile extending from a single Surface configuration; and they may
600. The particular post structure pattern, as well as the spac comprise the same or a different length if each is extending
ing between the various primary and secondary posts, as from different surfaces of a bi-level surface configuration. In
shown in FIGS. 13 and 14, is not meant to be limiting in any addition, the size of the primary and secondary post structures
way, but instead comprises merely one exemplary arrange 630 and 660 may be the same or different. In essence, the size,
ment. shape, configuration, pattern, location, and number of pri
The primary post structures 630 are formed from or are mary and secondary post structures and may vary, depending
extensions of or are coupled to the underside of the lower upon the functional performance desired to be achieved by a
surface 613. The primary post structures 630 are intended to particular modular tile.
contact the floor or ground at all times, and are considered the 25 The secondary post structures 660 are configured to acti
primary support structures for the modular tile 600. In addi vate and contact the floor 601 only upon sufficient deflection
tion, the primary post structures 630 are configured to deflect of the primary post structures 630 adjacent the secondary post
laterally instead of to deform (e.g., mashing). On the other structures 660 in response to a load or impact L. Depending
hand, the secondary post structures are formed from or are upon the distribution area of the applied load to the surface
extensions of or are coupled to the underside of the upper 30 610 of the modular tile 600, one or more primary post struc
surface 611. The secondary post structures 660 are designed tures 630 may deflect a sufficient distance to cause one or
to terminate a pre-determined distance so that their ends are more secondary post structures 660 to contact the floor 601.
not in contact with the floor when the modular tile 600 is With reference to FIG. 16, illustrated is a cross-sectional
Subject to non-deflecting loads (loads below the primary load side view of a portion of the modular tile 600 depicting
threshold described below) or no load at all. As will be 35 exemplary deflection positions of several primary post struc
explained below, the secondary post structures 660 are con tures 630 under a load L, as well as the contact positions of
figured to contact the floor or ground only in the event all or several secondary post structures 660 with respect to the floor
a portion of the upper surface 610 of the tile is subject to an 601. As in other embodiments, the end portions 634 of the
applied load capable of deflecting the primary post structures primary post structures 630 are configured to absorb impacts
630 a sufficient distance to cause the secondary post struc 40 applied at the surface 610 of the modular tile 600. In particu
tures 660 to displace toward and contact the floor or ground. lar, when a load L or impact is applied to the top surface 610,
Some of the purposes or functions of the secondary post the end portions 634 of the primary post structures 630 within
structures 660 are to control the deflection of the primary post the distribution area of the load L are caused to displace
structures 630, or rather to limit the degree of deflection of the against the floor surface 601 and be forced in a lateral direc
primary post structures 630; to improve the durability of the 45 tion 648 to a lateral deflected position. As can be appreciated
modular tile 600 tile in response to applied loads; to increase by one of ordinary skill in the art, the direction by which the
the load bearing capabilities of the modular tile 600, to help end portions 634 slide and deflect can be dependent upon the
prevent premature or inadvertent damage to the modular tile placement and direction of the load L. For example, FIG. 16
600 under applied loads; and to preserve and improve the illustrates several primary post structures 630 deflecting in
integrity, functionality, and operability of the modular tile 50 one direction in response to the load L, as well as the deflec
600. tion of primary post structure 630-bin another opposite direc
It is noted that the secondary post structures of the modular tion.
tile 600 described herein may also be incorporated into any of As will be apparent to one skilled in the art, the magnitude
the modular tile configurations described above and shown in of the load L will determine the magnitude of deflection of the
FIGS. 1-9. For example, the post structures 130 identified 55 primary post structures 630. Some loads may cause nominal
above and illustrated in FIG.3 may be termed as primary post or marginal deflection of the primary post structures 630 such
structures, with the modular tile 100 comprising a plurality of that the secondary post structures 660 are not caused to con
secondary post structures positioned between or arranged tact the floor 601. Under a sufficient pre-determined load L.
about the primary post structures according to a pre-deter the primary post structures 630 are caused to laterally deflect,
mined post structure patternor arrangement, as taught herein. 60 which results in the displacement of the surface 610 of the
The concept of primary and secondary post structures as modular tile 600 toward the floor 601 as a result of the short
disclosed herein may also be incorporated into other floor tile ening effect on the primary post structures 630 caused by their
designs not specifically described and shown herein, as will deflection. As the surface 610 displaces downward toward the
be appreciated and apparent to those skilled in the art. floor 601, the secondary post structures 660 are caused to also
With reference to FIGS. 15-A and 15-B, illustrated are 65 displace in a downward direction towards the floor 601. If the
respective side views of the modular tile 600 shown in FIGS. load L is great enough, the end portions 664 of the secondary
10-14 and described above, with FIG. 15-B illustrating a post structures 660 are caused to engage or come in contact
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with the floor 601, thus activating the secondary post struc “give' in the tile to provide a greater degree of safety for those
tures 660 as support members for the modular tile 600. Due to using the modular tiles 600. They also provide additional
their structural formation, the secondary post structures 660 spring in the tiles 600.
function as additional supports for the modular tile 601 in As in other embodiments, the end portions 634, in this
response to the load L. The secondary post structures 660 are embodiment, can resiliently deflect while the upper portion
also designed to support the primary post structures 630, up to 632 of the post structures 630 can be configured to have a
a pre-determined threshold. Of particular note is the ability of Substantially maintained or stationary position. As such, the
the secondary post structures 660 to control or limit the upper portion 632 of each of the post structures 630 provides
deflection of the primary post structures 630 and support the the necessary support for the tiles 600 while the end portions
modular tile 600 and primary post structures 630 under a 10 634 provide the impact absorbency component for the modu
sufficient given load L by contacting the floor 601. In other lar tiles 600. As one of ordinary skill in the art can readily
words, the secondary post structures 660 function as addi appreciate, the end portions 634 of the primary post structures
630 can be modified in size and configuration according to the
tional support members of the modular tile 600 under loads amount of controlled deflection or impact absorbency desired
large enough to deflect the primary post structures 630 and 15 for an intended use or activity for playing on the modular tiles
cause the secondary post structures 660 to come in contact 600. In addition, the end portions 634 may further comprise
with the floor 601. In one exemplary embodiment, the breach radial end Surfaces designed to facilitate the sliding and lat
of a primary load threshold at and above 160 psi will cause the eral deflection of the end portions 634, which radial end
primary post structures 630 to deflect enough to enable the surfaces are described above in relation to FIGS. 1-9. Further,
secondary post structures 660 to displace and contact the the type of synthetic material employed for the modular tiles
floor. Of course, the present invention is not limited in any 600 can also be a factor for the size and configuration of the
way by this. The primary load threshold for causing the pri primary post structures 630 to provide the amount of deflec
mary post structures to deflect enough to cause the secondary tion or impact absorbency desired in the modular tiles 600.
post structures to activate and displace to contact the floor There are many other advantages in addition to those
may be pre-determined and may be set at any desirable limit, 25 already discussed in providing a modular tile with secondary
depending upon, among other things, the construction, con post structures as taught herein. The secondary post structures
figuration, post structure pattern, and/or material make-up of and their ability to control the deflection of the primary post
the modular tile. Preferably, this primary load threshold will structures also functions to provide the modular tile with
range between 100 and 300 psi, as this is a reasonable range controlled shock absorption, meaning that the modular tile
corresponding to the weight range of different individuals 30 comprises an increased elastic capacity to give' when Sub
that might be using the tiles, and the forces that may be ject to an applied load.
induced upon the tiles by them. Another advantage is to provide the modular tile with an
The modular tile also has a secondary load threshold. increase in bounce or spring as compared to prior related
Loads below this secondary load threshold and in excess of modular tiles. By limiting the deflection of the primary post
the primary load threshold define acceptable operating con 35 structures under prescribed loads, the primary post structures
ditions that allow the modular tile to remain functional with are able to essentially spring back into their initial position
out deflection or deformation of the secondary post structure. once the load is removed. This also functions to provide
This secondary load threshold is also pre-determined and greater ball rebound, as well as to assist, to a limited degree,
may be set at any desirable limit. The secondary load thresh jumping by an individual.
old defines the load that the secondary post structures, along 40 Still another advantage to providing a modular tile with
with the deflected post structures, may bear without deflect deflecting primary post structures and controlling or limiting
ing or deforming (e.g., being mashed), thus possibly damag their deflection with secondary post structures is that the
ing the modular tile. Loads in excess of this secondary load modular tile comprises an improved surface feel. Due to the
threshold will cause a degree of deflection and/or deforma controlled deflection, the tile is and feels less rigid. Unlike
tion of the secondary post structures, some of which may be 45 prior related modular tiles existing in the art, the “give' in the
acceptable, and which may result without damage to the tile results in lower and/or absorbed impact forces, thus
modular tile. Indeed, the primary and secondary posts are reducing injury to individuals using the array of modular tiles.
elastically deformable up to a pre-determined load. However, It is noted and emphasized herein that the features and
the modular tile is also designed with a maximum load thresh elements of the different embodiments discussed above are
old. The maximum load threshold describes or defines the 50 related in that any one or more elements from any one or more
load that modular tile is able to bear without being damaged. embodiments may be incorporated into any other embodi
Again, this maximum load threshold is pre-determined and ment. A such, the present invention is not limited to the tile
may be set at any desirable limit. Loads in excess of this embodiments specifically discussed and shown in the draw
maximum load threshold will cause irreversible damage to 1ngS.
the modular tile and cause the primary and secondary posts, 55 The foregoing detailed description describes the invention
the surface, and/or other vital components of the modular tile with reference to specific exemplary embodiments. However,
to inelastically deform. it will be appreciated that various modifications and changes
Under normal operating conditions, when the load L is can be made without departing from the scope of the present
removed, the end portions 634 of the primary post structures invention as set forth in the appended claims. The detailed
630 resiliently move back to their original position, thus also 60 description and accompanying drawings are to be regarded as
causing the end portions 664 of the secondary post structures merely illustrative, rather than as restrictive, and all such
660 to disengage the floor 601 and return to their normal, modifications or changes, if any, are intended to fall within
inactive position. Furthermore, in the event the end portions the scope of the present invention as described and set forth
634 are in a load bearing deflected position, they are capable herein.
of providing an upward spring force F, due to the resilient 65 More specifically, while illustrative exemplary embodi
characteristics of the end portions 634. With this arrange ments of the invention have been described herein, the present
ment, the end portions 634 facilitate impact absorbency or invention is not limited to these embodiments, but includes
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any and all embodiments having modifications, omissions, second plurality of support members have a length different
combinations (e.g., of aspects across various embodiments), from the length of the first plurality of support members.
adaptations and/or alterations as would be appreciated by 10. The modular floor tile of claim 9, wherein the plurality
those in the art based on the foregoing detailed description. of primary Support members are configured to deflect under
The limitations in the claims are to be interpreted broadly an applied load.
based the language employed in the claims and not limited to 11. The modular floor tile of claim 10, wherein the plurality
examples described in the foregoing detailed description or of secondary Support members are configured to contact an
during the prosecution of the application, which examples are underlying Surface only when the plurality of primary Support
to be construed as non-exclusive. For example, in the present members deflect under an applied load.
disclosure, the term “preferably' is non-exclusive where it is 10 12. A modular floor tile, comprising
intended to mean "preferably, but not limited to.” Any steps a first plurality of parallel linear structural members:
recited in any method or process claims may be executed in a second plurality of parallel linear structural members
any order and are not limited to the order presented in the intersecting the first plurality of parallel linear structural
claims. Means-plus-function or step-plus-function limita members and defining a plurality of openings, wherein
tions will only be employed where for a specific claim limi 15 each of the plurality of openings comprises a plurality of
tation all of the following conditions are present in that limi opposing internal angles:
tation: a) “means for or “step for is expressly recited; b) a wherein the first and second plurality of parallel linear
corresponding function is expressly recited; and c) structure, structural members comprise an upper planar contact
material or acts that Support that structure are expressly Surface and a side Surface and a transition Surface
recited. Accordingly, the scope of the invention should be extending between the upper planar contact surface and
determined solely by the appended claims and their legal the side Surface defining a blunt edge between the upper
equivalents, rather than by the descriptions and examples planar contact surface and the side Surface;
given above. a plurality of support members disposed beneath the floor
tile configured to Support the floor tile atop and Surface;
What is claimed and desired to be secured by Letters Patent 25 and
1S a mechanism for linking the modular floor tile to an adja
1. A modular floor tile, comprising: cent floor tile.
a perimeter; 13. The modular floor tile of claim 12, wherein the plurality
an upper contact surface within the perimeter; of Support members comprises a first plurality of Support
a plurality of openings formed in said upper contact Sur 30 members and a second plurality of post members, wherein the
face, each of said openings comprising a plurality of second plurality of support members have a length different
internal angles defined by intersecting structural mem from the length of the first plurality of support members.
bers, wherein said structural members comprise an 14. The modular floor tile of claim 13, wherein the plurality
upper planar contact Surface and a side Surface; of primary Support members are configured to deflect under
wherein at least some of said structural members further 35 an applied load.
comprise a transition Surface extending between the 15. The modular floor tile of claim 14, wherein the plurality
upper planar contact surface and the side surface defin of secondary Support members are configured to contact an
ing a blunt edge between the upper planar contact Sur underlying Surface only when the plurality of primary Support
face and the side Surface; and members deflect under an applied load.
a plurality of Support members extending downward from 40 16. A modular floor tile, comprising:
at least some of the intersecting structural members. a top Surface comprising a plurality of openings defined by
2. The modular floor tile of claim 1, wherein the internal intersecting structural members, said openings compris
angles comprise at least one acute angle. ing at least two opposing equal internal angles;
3. The modular floor tile of claim 1, wherein the internal wherein the intersecting structural members comprise an
angles comprise equal opposing acute angles. 45 upper planar contact Surface, a side Surface and a tran
4. The modular floor tile of claim 1, wherein the internal sition Surface extending between the upper planar con
angles comprise equal opposing obtuse angles. tact Surface and the side Surface defining a blunt edge
5. The modular floor tile of claim 1, further comprising between the upper planar contact Surface and the side
primary and secondary structural members, wherein the pri Surface;
mary structural members define the openings and the second 50 a plurality of Support members extending downward from
ary structural members are disposed within the openings at an said top Surface; and
elevation below the upper planar contact surface of the pri a device for linking the modular floor tile to an adjacent
mary structural members. floor tile.
6. The modular floor tile of claim 5, wherein the secondary 17. The modular floor tile of claim 16, further comprising
structural members are configured to bisect the openings. 55 primary and secondary structural members, wherein the pri
7. The modular floor tile of claim 5, wherein the plurality of mary structural members define the openings and the second
Support members extend downward from the primary struc ary structural members are disposed within the openings at an
tural members. elevation below the upper planar contact surface of the pri
8. The modular floor tile of claim 1, wherein the perimeter mary structural members.
further comprises an upperplanarcontact Surface and a planar 60 18. The modular floor tile of claim 16, wherein the plurality
side Surface and a transition Surface extending between the of Support members comprises a first plurality of Support
upperplanar contact surface and the planar side surface defin members and a second plurality of post members, wherein the
ing a blunt edge between the upperplanar contact Surface and second plurality of support members have a length different
the planar side Surface. from the length of the first plurality of support members.
9. The modular floor tile of claim 1, wherein the plurality of 65 19. The modular floor tile of claim 18, wherein the plurality
Support members comprises a first plurality of Support mem of primary Support members are configured to deflect under
bers and a second plurality of post members, wherein the an applied load.
Case 2:18-cv-00778-DBP Document 2-1 Filed 10/04/18 Page 23 of 23

US 8,424,257 B2
15 16
20. The modular floor tile of claim 19, wherein the plurality
of secondary Support members are configured to contact an
underlying Surface only when the plurality of primary Support
members deflect under an applied load.
21. The modular floor tile of claim 16, wherein the side
Surface comprises a planar Surface.
22. The modular floor tile of claim 16, wherein the oppos
ing internal angles are acute angles.
23. The modular floor tile of claim 16, wherein the oppos
ing internal angles are obtuse angles. 10
k k k k k
Case 2:18-cv-00778-DBP Document 2-2 Filed 10/04/18 Page 1 of 38

EXHIBIT 2 
Case 2:18-cv-00778-DBP Document 2-2 Filed 10/04/18 Page 2 of 38
USOO8407951B2

(12) United States Patent (10) Patent No.: US 8,407,951 B2


Haney et al. (45) Date of Patent: Apr. 2, 2013
(54) MODULAR SYNTHETIC FLOORTLE (56) References Cited
CONFIGURED FOR ENHANCED
PERFORMANCE U.S. PATENT DOCUMENTS
321,403 A 6, 1885 Underwood
(75) Inventors: Thayne Haney, Syracuse, UT (US); 658,868 A 10/1900 Rosenbaum
1,177,231 A 3, 1916 Carter
Mark Jenkins, Salt Lake City, UT (US); 1425,324 A 8/1922 Kennedy
Cheryl Forster, Salt Lake City, UT 1472,956 A 1 1/1923 Biegler
(US); Jeremiah Shapiro, West Valley 1,824,571 A 5, 1927 Richardson
City, UT (US); Dana Hedquist, 1,896.957 A 2f1933 Hutcheson
Bountiful, UT (US) 1971,320 A 8/1934 Cederquist
2,082.563 A 6, 1937 Bauer
2,225,828 A 12/1940 Godschall
(73) Assignee: Connor Sport Court International, (Continued)
LLC, Salt Lake City, UT (US)
FOREIGN PATENT DOCUMENTS
(*) Notice: Subject to any disclaimer, the term of this CN 222 1623 6, 1996
patent is extended or adjusted under 35 EP 0044371 1, 1982
U.S.C. 154(b) by 163 days. (Continued)
OTHER PUBLICATIONS
(21) Appl. No.: 11/732,714
Synthetic Floor Tile, pp. 1-7.
(22) Filed: Apr. 3, 2007 (Continued)
Primary Examiner – William Gilbert
(65) Prior Publication Data
Assistant Examiner — Chi Nguyen
US 2007/0289244A1 Dec. 20, 2007 (74) Attorney, Agent, or Firm — Thorpe North & Western
LLP
(57) ABSTRACT
Related U.S. Application Data
A modular synthetic floor tile comprising: (a) an upper con
(63) Continuation-in-part of application No. 1 1/244,723, tact surface; (b) a plurality of openings formed in the upper
filed on Oct. 5, 2005. contact Surface, each of the openings having a geometry
(60) Provisional application No. 60/616,885, filed on Oct. defined by structural members configured to intersect with
6, 2004, provisional application No. 60/834,588, filed one another at various intersection points to form at least one
on Jul. 31, 2006. acute angle as measured between imaginary axes extending
through the intersection points, the structural members hav
ing a smooth, planar top surface forming the contact surface,
(51) Int. C. and a face oriented transverse to the top Surface; (c) a transi
E04F II/6 (2006.01) tion Surface extending between the top surface and the face of
(52) U.S. Cl. .............. 52/177; 52/180; 52/390; 52/591.1 the structural members configured to provide a blunt edge
(58) Field of Classification Search .................... 52/177, between the top surface and the face, and to reduce abrasive
52/180, 384 387, 390,392,591.1-591.3; ness of the floor tile; and (d) means for coupling the floor tile
to at least one other floor tile.
404/41, 47: 15/215
See application file for complete search history. 27 Claims, 21 Drawing Sheets
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US 8,407,951 B2
Page 2

U.S. PATENT DOCUMENTS 4,650,188 A 3, 1987 Schroeder


4,681.482 A 7, 1987 Arciszewski et al.
2,653.525 A 9/1953 Sargeant 4,681,786. A 7, 1987 Brown
2,680,698 A 6, 1954 Schnee 4694,627 A 9, 1987 Omholt
2,735,166 A 2f1956 Hoseason 4,702.048 A 10, 1987 Millman
3:19.
W k-
A 1918, Flor
O
4,715,743 A
4,727,697 A
12/1987 Schmanski
3, 1988 Vaux
3,122,073. A 2f1964 Masse 4.728.468 A 3, 1988 Duke
32:3: A 12. R. 4,749,302 A 6/1988 DeClute
3.310906 A 3, 1967 E. 4,766,020 A 8/1988 Ellingson, Jr.
338.476 A 5, 1967 ls 4,807,412 A 2f1989 Frederiksen
3.332.19 A 7, 1967 k al 4,819,932 A 4, 1989 Trotter
--4 essler et al. 4,826,351 A 5/1989 Haberhauer et al.
3,350,013 A 10/1967 Bergquist 4,849.267 A 7, 1989 Ward et al.
3.425,624 A 2f1969 Jacobs 4,860,510 A 8, 1989 Kotler
3,438,312 A 4, 1969 Becker et al. 4875.800. A 10/1989 Hicks
3.68 A
3500 A
1992 S.
5, 1970 M armby
4,877,672 A
4,917.532 A
10/1989 Shreiner
4, 1990 Haberhauer et al.
- J. J. Organ 4,930,286 A 6, 1990 Kotler
3,531,902 A 10, 1970 Costa 4.948,116 A 8, 1990 Vaux
3,565,276 A 2, 1971 O'Brien 4.963,054 A 10/1990 Hayashi
3,611,609. A 10/1971 Nelnhard 4,964,751 A 10/1990 Rope et al.
392, A 1918. S. 4,973,505. A 1 1/1990 Bielous
3.723.233 A 3, 1973 S. 5,022,200 A 6, 1991 Wilson et al.
4- OUK 5,039,365 A 8/1991 Rutledge et al.
3,735,988 A 5, 1973 Palmer et al. 5.048.448 A 9, 1991 YOder
3,736,713 A 6, 1973 Flachbarth et al. 5,052,158. A 10, 1991 D'Luzansky
376. A 1332 h 5,111,630 A 5/1992 Munsey et al.
3.802.144. A 4, 1974 D327,748 S 7/1992 Dorfman, Jr.
3820.913 A 6, 1974 E. 5,143,757 A 9, 1992 Skinner
wa. W ughes 5,157,804. A 10/1992 Williams
3,823,521 A 7, 1974 Heitholt et al. 5,160,215. A 1 1/1992 Jensen
3,836,075 A 9/1974 Botbol 5,185,193 A 2/1993 Phenicie et al.
3,844,440 A 10/1974 Hadfield et al. 5.190.799. A 3, 1993 Ellingson
3,909,996 A 10/1975 Ettlinger, Jr. et al. 5.195.288 A 3, 1993 E.
3,911,635 A 10/1975 Traupe 5.305.09. A 4/1993 Brown
3,922409 A
3,925,946 A
112/1975
1/1975 Stark
Balinski et al.
5,205,092 A
5.215,802 A
4/1993 Taylor
6/1993 Siipestein
3,937,861 A 2, 1976 Zuckerman et al. 5228,353 A 36 SE
3,946,529 A 3, 1976 Chevaux 5.229.437 A. 7/1993 Knight
3,955,836 A 5/1976 Traupe 5,234.738 A 8, 1993 Wolf
4,008,352 A 2f1977 Dawes et al. 5.250.340 A 10, 1993 Bohnhoff
4,008,548 A 2f1977 Leclerc 5.255.464 A 10/1993 Nilsen
4,018,025 A 4, 1977 Collette 5,295.34. A 3, 1994 Kaiiwara
4,054,987 A 10, 1977 Forlenza 5.303.669 A 4, 1994 SE
4,118,892 A 10, 1978 Nakamura et al. 5.333,575 A 6, 1994 Yeh y
4,133,481 A 1/1979 Bennett 5.333.423 A 8, 1994 Proost
4,167,599 A 9, 1979 Nissinen ......................... 428/44 5.342,141 A 8, 1994 E
E.
4- 4 W
68. atO
so 5,364,204 A
5,365,710 A
1 1/1994 MacLeod
1 1/1994 Randjelovic
4,226,064 A 10/1980 Kraayenhof 5,379.557 A 1/1995 Kotter
4,244,484 A 1/1981 Guritz et al. 5.387,842 A 2f1995 Roth etal
4,274,626 A 6, 1981 Grosser et al. 5.403.453 A 4, 1995 Roth et al.
4,285,518 A 8/1981 Pearo 5,403,637 A 4, 1995 Pickard et al.
4,287,693 A 9, 1981 Collete 5,412.917. A 5, 1995 Shelton
4.338,758. A 7/1982 Hagbjer 5.414,324. A 5/1995 Rothet al.
3.- ww.
A 3. Mit.
o
Jr. 5,418,036
5.449.246 A
A 5/1995 Tokikawa et al.
9/1995 Housley
4.419,382 A 12/1983 Sliemers et al. 5.456.972 A 10, 1995 Roth etal
4,424.968 A 1/1984 Smith 5,462,771. A 10/1995 Motoki et al.
4,436,779 A 3, 1984 Menconi et al. 5,466,424 A 11/1995 Kusano et all
4,440,818 A 4, 1984 Buchan et al. 5.466,489 A 1/1995 Stahl
D274,948 S 7, 1984 Swanson et al. 5,502,148 A 3/1996 Hentschel et al.
4,468,910 A 9, 1984 Morrison 5.509,244 A 4/1996 BentZOn
4.478,901 A 10, 1984 Dickens et al. 551.353 A 4/1996 Jones
4,478,905 A 10/1984 Neely, Jr. et al. 5,518,799 A 5/1996 Finestone et al.
4497,858 A 2/1985 Dupont et al. 5,526.619. A 6/1996 Vagedes
4,509,930 A 4, 1985 Schweigert et al. 5527.2s A 6, 1996 Real
4,526,347 A 7/1985 McLoughlin 5,542,221. A 8/1996 Streitetal.
3.
- --
A 38. E.
9.
5,567,490 A
5,573,715 A
10/1996 Papazian et al.
1 1/1996 Adams et al.
4,577,448 A 3, 1986 Howorth D377.398 S 1/1997 Adam
4.58.4.221 A 4, 1986 K
23875. A 3.58. Soyer 5,616,389 A 4/1997 Blatz
4,596,729 A 6, 1986 Morrison 5,628, 160 A 5/1997 Kung ........................... 52.5911
4,596,731 A 6, 1986 Cudmore et al. 5,634,309 A 6, 1997 Polen
D286,575 S 11, 1986 Saunders 5,640,821 A 6, 1997 Koch
4,640,075 A 2f1987 Nuncio 5,642,592 A 7/1997 Andres
4,648,592 A 3, 1987 Harinishi 5,647,184 A 7, 1997 Davis
4,650, 180 A 3, 1987 Blondel 5,679,385 A 10/1997 Adams et al.
Case 2:18-cv-00778-DBP Document 2-2 Filed 10/04/18 Page 4 of 38

US 8,407,951 B2
Page 3

5,682,724 A 1 1/1997 Randjelovic 6,672,971 B2 1/2004 Barlow


5,693,390 A 12/1997 Inagaki et al. 6,682,254 B1 1/2004 Olofsson et al.
5,693,395 A 12, 1997 Wine D486,592 S 2/2004 Hong
5,695,064 A 12/1997 Huang et al. 6,684,582 B2 2/2004 Peart et al.
5,713, 175 A 2, 1998 Mitchell 6,684,592 B2 2/2004 Martin
5,713,806 A 2/1998 Teitgen et al. 6,695,527 B2 2/2004 Seaux et al.
5,735,096 A 4, 1998 Krass 6,718,714 B1 4/2004 Montgomery
5,749,787 A 5, 1998 Jank 6,718,715 B2 4, 2004 Elliott
5,758.467 A 6, 1998 Snear et al. 6,736,569 B2 5, 2004 Lee
5,761,867 A 6/1998 Carling 6,739,797 B1 5, 2004 Schneider
5,787,654 A 8, 1998 Drost D492.426 S 6/2004 Strickler
5,803,973 A 9/1998 Szczyrbowski et al. 6,751,912 B2 6/2004 Stegner et al.
5,815,995 A 10, 1998 Adam 6,769,219 B2 8, 2004 Schwitte et al.
5,816,010 A 10, 1998 Conn 6,793,586 B2 9, 2004 Barlow et al.
5,816,738 A 10/1998 Harnapp 6,802,159 B1 10/2004 Kotler
5,819,491 A 10, 1998 Davis 6.820,386 B2 11/2004 Kappeli et al.
5,820,294 A 10, 1998 Baranowski 6,833,038 B2 12/2004 Iwen et al.
5,822,828 A 10, 1998 Berard et al. 6,851,236 B1 2/2005 Harvey
5,833,386 A 11/1998 Rosan et al. 6,878.430 B2 4/2005 Milewski et al.
5,848,856 A 12, 1998 Bohnhoff 6,880,307 B2 4/2005 Schwitte et al.
5,865,007 A 2f1999 Bowman et al. 6,895,881 B1 5, 2005 Whitaker
5,899,038 A 5/1999 Stroppiana 6,931,808 B2 8, 2005 Hamar
5,904,021 A 5, 1999 Fisher 6,962,463 B2 11/2005 Chen
5,906,082 A 5, 1999 Counihan 7,021,012 B2 4/2006 Zeng et al.
5,906,454 A 5, 1999 Medico et al. 7,029,744 B2 4/2006 Horstman et al.
5,907,934. A 6, 1999 Austin D522,149 S 5, 2006 Shin
5,910.401 A 6, 1999 Anderson et al. 7,047,697 B1 5, 2006 Heath
5.937,602 A 8, 1999 Jabert 7,065,935 B2 6, 2006 Ralf
5,950,378 A 9, 1999 Council et al. 7,090,430 B1 8, 2006 Fletcher et al.
D415,581 S 10, 1999 Bertolini 7,096,632 B2 8, 2006 Pacione
5.992,106 A 1 1/1999 Carling et al. 7,114,298 B2 10/2006 Kotler
6,017,577 A 1/2000 Hostettler et al. 7,127.857 B2 10/2006 Randjelovic
6,032,428 A 3, 2000 ROSan et al. D532,530 S 11/2006 Shuman et al.
6,044,598 A 4/2000 Elsasser et al. 7,131,788 B2 11/2006 Ianniello et al.
6,047,663 A 4/2000 Moreau et al. 7,144,609 B2 12/2006 Reddick
6,068,908 A 5, 2000 Kessler et al. 7,155,796 B2 1, 2007 Cook
6,095,718 A 8, 2000 Bohnhoff 7,211,314 B2 5, 2007 Nevison
6,098,354 A 8/2000 Skandis .......................... 52/177 7,299,592 B2 11/2007 Moller, Jr.
6,101,788 A 8, 2000 Weder et al. 7.303,800 B2 12/2007 Rogers
6,112,479 A 9, 2000 Andres 7.340,865 B2 3/2008 Vanderhoef
6,128,881 A 10, 2000 Bue et al. 7,383,663 B2 6/2008 Pacione
6,134,854 A 10, 2000 Stanchfield 7,386,963 B2 6/2008 Pervan
D435,122 S 12/2000 ROSS et al. 7,412,806 B2 8, 2008 Pacione et al.
6,171,015 B1 1/2001 Barth et al. 7.464510 B2 12/2008 Scott et al.
D437.427 S 2/2001 Shaffer 7,516,587 B2 4/2009 Barlow
6,189,289 B1 2/2001 Quaglia et al. 7,520,948 B2 4/2009 Tavy et al.
6,228.433 B1 5, 2001. Witt D593,220 S 5, 2009 Reed
6,230,460 B1 5/2001 Huyett 7,527.451 B2 5, 2009 Slater
6,231939 B1 5, 2001 Shaw et al. 7,531,055 B2 5, 2009 Mead
6,286,272 B1 9, 2001 Sandoz 7,563,052 B2 7/2009 Van Reijen
6,301,842 B1 10/2001 Chaney et al. 7,571,572 B2 8/2009 Moller, Jr.
6,302,803 B1 10/2001 Barlow 7,571,573 B2 8/2009 Moller, Jr. ....................... 52/177
6,321,499 B1 1 1/2001 Chuang 7.587,865 B2 9/2009 Moller, Jr.
6,324,796 B1 12/2001 Heath RE41,140 E 2/2010 Heath
6,345.483 B1 2, 2002 Clark D611,626 S 3/2010 Ardern
6,355,323 B1 3, 2002 Iwen et al. 7,676,291 B2 3/2010 Sheffield et al.
D456,533 S 4/2002 Moller, Jr. 7,704,011 B2 4/2010 Marshall
6,397.543 B1 6, 2002 Hamar 7,748,176 B2 7/2010 Harding et al.
6,418,683 B1 7/2002 Martensson et al. 7,748,177 B2 7/2010 Jenkins et al.
6,428,870 B1 8, 2002 Bohnhoff 7,900,416 B1 3/2011 Yokubison et al.
6,436,159 B1 8, 2002 Safta et al. 7,950,191 B2 5, 2011 Brouwers
6,451,400 B1 9/2002 Brock et al. .................... 428/44 2001/0002523 A1 6/2001 Chen
6,453,632 B1 9/2002 Huang 2002fOO71927 A1 6/2002 Kessler et al.
6,467,224 B1 10/2002 Bertolini 2002/0152702 A1 10/2002 Tseng
6,526,705 B1 3/2003 MacDonald 2002/0189176 Al 12/2002 Stegner et al.
6,531,203 B2 3/2003 Kessler et al. 2003/OOO9971 A1 1/2003 Palmberg
6,543,196 B1 4/2003 Gonzales 2003/0093.964 A1 5/2003 Bushey et al.
6,562.414 B2 5/2003 Carling 2003. O148813 A1 8, 2003 Barlow
6,578,324 B2 6, 2003 Kessler et al. 2003. O190969 A1 10, 2003 Barlow et al.
6,585,449 B2 7, 2003 Chen 2004/OO23006 A1 2/2004 Mead
6,588,166 B2 7/2003 Martensson et al. 2004/OO35079 A1 2/2004 Even
6,605,333 B2 8, 2003 Ferreira et al. 20040182030 A1 9, 2004 Hinault et al.
6,606,834 B2 8/2003 Martensson et al. 2004/0235580 A1 11/2004 Barlow et al.
6,617,009 B1 9, 2003 Chen et al. 2004/0258869 A1 12, 2004 Walker
D481,138 S 10/2003 Forster et al. 2005, OO16098 A1 1, 2005 Hahn
D481,470 S 10/2003 Moller, Jr. 2005/0O28475 A1 2/2005 Barlow et al.
6,637,163 B2 10/2003 Thibault et al. 2005. O144867 A1 7, 2005 Clarke
6,669,572 B1 12/2003 Barlow 2005/O193670 A1 9, 2005 Niese et al.
6,672,970 B2 1/2004 Barlow 2005/0202208 A1 9/2005 Kelly
Case 2:18-cv-00778-DBP Document 2-2 Filed 10/04/18 Page 5 of 38

US 8,407,951 B2
Page 4

2005/0204676 A1 9, 2005 Weitzer Synthetic Floor Tile, pp. 103-107.


2005/O2S2109 A1 11/2005 Fuccella et al. Synthetic Floor Tile, pp. 108-112.
2006,0070314 A1 4, 2006 Jenkins Synthetic Floor Tile, pp. 113-117.
2006, 0080909 A1 4, 2006 Harding et al. Synthetic Floor Tile, pp. 118-122.
2006/0265975 A1 11, 2006 Geffe
2006/0272.252 A1 12, 2006 Moller, Jr. Synthetic Floor Tile, pp. 123-127.
2006/0285920 A1 12, 2006 Gettig et al. Synthetic Floor Tile, pp. 128-133.
2007/0214741 A1 9, 2007 Llorens Miravet Synthetic Floor Tile, pp. 134-138.
2007/0289244 A1 12, 2007 Haney et al. Synthetic Floor Tile, pp. 139-143.
2008/0092473 A1 4, 2008 Heyns Synthetic Floor Tile, pp. 144-148.
2008/O127593 A1 6, 2008 Janesky Synthetic Floor Tile, pp. 149-153.
2008. O168736 A1 T/2008 Pervan
2008/0172968 A1 T/2008 Pacione Synthetic Floor Tile, pp. 154-159.
2008/0216437 A1 9, 2008 Prevost et al. Synthetic Floor Tile, pp. 160-164.
2008/0271410 A1 11, 2008 Matthee Synthetic Floor Tile, pp. 165-169.
2008/029.5437 A1 12, 2008 Dagger Synthetic Floor Tile, pp. 170-174.
2009 OO31658 A1 2, 2009 Moller, Jr. et al. Synthetic Floor Tile, pp. 175-179.
2009.0049768 A1 2, 2009 Kim Synthetic Floor Tile, pp. 180-184.
2009, O1391.60 A1 6, 2009 Hill Synthetic Floor Tile, pp. 185-189.
2009/0235605 A1 9, 2009 Haney Synthetic Floor Tile, pp. 190-194.
2010. 0236176 A1 9, 2010 Jenkins
2011/004.5916 A1 2, 2011 Casimaty et al. Synthetic Floor Tile, pp. 195-199.
Synthetic Floor Tile, pp. 200-204.
FOREIGN PATENT DOCUMENTS Synthetic Floor Tile, pp. 205-209.
EP 1167652 1, 2002 Synthetic Floor Tile, pp. 210-214.
FR 2240320 3, 1975 Synthetic Floor Tile, pp. 215-219.
GB 1504811 3, 1978 Synthetic Floor Tile, pp. 220-224.
GB 2262437 6, 1993 Synthetic Floor Tile, pp. 225-229.
GB 2263644 A 8, 1993 Synthetic Floor Tile, pp. 230-234.
GB 2353543 2, 2001 Synthetic Floor Tile, pp. 235-239.
JP O1-226978 9, 1989 Synthetic Floor Tile, pp. 240-244.
KR 10-2006-0 127635 12/2006 Synthetic Floor Tile, pp. 245-249.
KR 20-0239521 10, 2011 Synthetic Floor Tile, pp. 250-254.
WO WO92O1130 1, 1992 PCT Application PCT/US2011/022802; filed Jan. 28, 2011; Ronald
OTHER PUBLICATIONS N. Cerny; International Search Report mailed Sep. 28, 2011.
Synthetic Tile Floor; 88 pages,
Synthetic Floor Tile, pp. 8-12. www.invisiblestructures.com webiste Jul. 26, 2006, 109 pages.
Synthetic Floor Tile, pp 13-17. www.mateflex.stores.yahoo.net websiter Jul. 26, 2006, 68 pages.
Synthetic Floor Tile, pp 18-21. www.namintec.com, website, Jul. 26, 2006, 28 pages.
Synthetic Floor Tile, p. 22. www.polypavement.com/costs.htm, website Mar. 24, 2006, pp. 1-2.
Synthetic Floor Tile, pp. 23-27. www.polypavement.com/more info.htm, website Mar. 24, 2006 pp.
Synthetic Floor Tile, pp. 28-32. 1-12.
Synthetic Floor Tile, pp. 33-37. www.polypavement.com/index.htm, website Mar. 24, 2006, pp. 1-6.
Synthetic Floor Tile, pp. 38-42. Inter Partes Reexamination for Patent No. 7,748,177; Request filed
Synthetic Floor Tile, pp. 43-47. Dec. 29, 2011; 192 pages.
Synthetic Floor Tile, pp. 48-52. U.S. Appl. No. 95/000,651; filed Dec. 29, 2011; office action issued
Synthetic Floor Tile, pp. 53-57. Feb. 3, 2012.
Synthetic Floor Tile, pp. 58-62. Affidavit of Christopher Butler; signed Jan. 24, 2011; received by
Synthetic Floor Tile, pp. 63-67. Thorpe North and Western on Jul. 8, 2011; 13 pages.
Synthetic Floor Tile, pp. 68-72. "Standard Test Method for Relative Abrasiveness of Synthetic Turf
Synthetic Floor Tile, pp. 73-77. Playing Surfaces”; Copyright ASTM International; Jul. 10, 2003.
Synthetic Floor Tile, pp. 78-82. "Standard Test Method for Abrasion Resistance of Textile Fabrics
Synthetic Floor Tile, pp. 83-87. (Rotary Platform, Double-Head Method)”; Copy right by ASTM;
Synthetic Floor Tile, pp. 88-92. Jan. 15, 2009.
Synthetic Floor Tile, pp. 93-97.
Synthetic Floor Tile, pp. 98-102. * cited by examiner
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US 8,407,951 B2
1. 2
MODULAR SYNTHETIC FLOORTLE thetic flooring systems may further be engineered to provide
CONFIGURED FOR ENHANCED more or less shock absorption, depending upon various fac
PERFORMANCE tors such as intended use, cost, etc. In a related advantage, the
interlocking connections or interconnects for modular floor
RELATED APPLICATIONS ing assemblies can be specially engineered to absorb various
applied forces, such as lateral forces, which can reduce cer
The present application is a continuation in-part applica tain types of injuries from athletic or other activities.
tion, which claims the benefit of U.S. patent application Ser. Unlike traditional flooring made from asphalt, wood, or
No. 1 1/244,723, filed Oct. 5, 2005, which claims the benefit concrete, modular synthetic flooring systems present certain
of U.S. Provisional Application No. 60/616,885, filed Oct. 6, 10 unique challenges. Due to their ability to be engineered, the
2004. The present application also claims the benefit of U.S. configuration and material makeup of individual floor tiles
Provisional Application No. 60/834,588, filed Jul. 31, 2006. varies greatly. As a result, the performance or performance
Each of the above-referenced applications are incorporated characteristics provided by these types of floor tiles, and the
by reference in their entirety herein. corresponding flooring systems created from them, also
15 greatly varies. There are two primary performance character
FIELD OF THE INVENTION istics, beyond those described above (e.g., shock absorption),
that are considered in the design and construction of synthetic
The present invention relates generally to synthetic floor floor tiles—1) traction or grip of the contact Surface, which is
tiles, and more particularly to a modular synthetic floor tile in a measure of the coefficient of friction of the contact surface;
which its elements are designed and configured to enhance and 2) contact surface abrasiveness, which is a measure of
the performance characteristics of the floor tile through opti how much the contact surface abrades a given object that is
mization of various design factors. dragged over the Surface.
In order for the contact Surface of a flooring system to
BACKGROUND OF THE INVENTION AND provide high performance characteristics, such as those that
RELATED ART 25 would enable athletes to quickly start, stop, and turn, the
contact Surface must provide good traction. Currently, efforts
Numerous types of flooring have been used to create multi have been undertaken to improve the traction of synthetic
use Surfaces for sports, activities, and for various other pur flooring systems. Such efforts have included forming nubs or
poses. In recent years, the technology in modular flooring a pattern of protrusions that extend upward from the contact
assemblies or systems made of a plurality of modular floor 30 surface of the individual floor tiles. However, such nubs or
tiles has become quite advanced and, as a result, the use of protrusions, while providing somewhat of an improvement in
such systems has grown significantly in popularity, particu traction over the same surface without such nubs, signifi
larly in terms of residential and mobile game court use. cantly increases the abrasiveness of the contact Surface, and
Modular synthetic flooring systems generally comprise a therefore the likelihood of injury in the event of a fall. Indeed,
series of individual interlocking or removably coupling floor 35 Such nubs create a rough or coarse surface. In addition, the
tiles that can either be permanently installed over a Support existence of nubs or protrusions creates irregular or uneven
base or Subfloor, such as concrete or wood, or temporarily Surfaces that may actually reduce traction depending upon
installed over a similar support base or subfloor from time to their configuration and size.
time when needed. Such as in the case of a mobile game court Another effort undertaken to improve traction has involved
installed and then removed in different locations for a par 40 forming a degree of texture, particularly an aggressive tex
ticular event. Another These floors and floor systems can be ture, in the upper or top Surfaces of the various structural
used both indoors or outdoors. members or elements defining the contact surface of the floor
Modular synthetic flooring systems utilizing modular syn ing system. However, this only marginally improves traction,
thetic floor tiles provide several advantages over more tradi primarily because the texture, although seemingly aggres
tional flooring materials and constructions. One particular 45 sive, is unable to be pronounced enough to have any signifi
advantage is that they are generally inexpensive and light cant effect on the Surface area of an object moving about the
weight, thus making installation and removal less burden contact surface. This is particularly the case in the event the
some. Another advantage is that they are easily replaced and object comprises a large Surface area (as compared to the
maintained. Indeed, if one tile becomes damaged, it can be Surface area of the contact surface) and exerts a large normal
removed and replaced quickly and easily. In addition, if the 50 force. Such as an athlete whose shoe Surface area and large
flooring system needs to be temporarily removed, the indi normal force almost negate Such practices.
vidual floor tiles making up the flooring system can easily be With respect to the performance characteristic of abrasive
detached, packaged, stored, and transported (if necessary) for ness of the contact surface of the flooring system, many floor
Subsequent use. tile designs sacrifice this in favor of improved traction.
Another advantage lies in the types materials that are used 55 Indeed, the two most common ways to increase traction dis
to construct the individual floor tiles. Since the materials are cussed above, namely providing raised nubs or other protru
engineered synthetics, the flooring systems may comprise sions and providing aggressive texture on the contact surface,
durable plastics that are extremely durable, that are resistant function to negatively increase the abrasiveness of the floor
to environmental conditions, and that provide long-lasting tiles and the flooring system in most prior art floor tiles. Thus,
wear even in outdoor installations. These flooring assemblies 60 although a flooring system may provide good traction, there is
generally require little maintenance as compared to more most likely a higher risk for injury in the event of a fall due to
traditional flooring, such as wood. the abrasive nature of the flooring system.
Still another advantage is that synthetic flooring systems Abrasiveness may further be compounded by the sharp
are generally better at absorbing impact than other long edges existing about the tile. Indeed, it is not uncommon for
lasting flooring alternatives, such as asphalt and concrete. 65 individual floor tiles to have a perimeter around and defining
Better impact absorption translates into a reduction of the the dimensions of the floor tile consisting of two surfaces
likelihood or risk of injury in the event a person falls. Syn extending from one another on an orthogonal angle. It is also
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US 8,407,951 B2
3 4
not uncommon for the various structural members extending Surface, a face oriented transverse to the top Surface, and a
between the perimeter and defining the contact Surface to also transition Surface extending between the top Surface and the
comprise two orthogonal Surfaces. Each of these represents a face to provide the structural members with a blunt edge
sharp, rough edge likely to abrade, or at least have a tendency configured to reduce abrasiveness of the floor tile; and (e)
to abrade, any object that is dragged over these edges under 5 means for coupling the floor tile to at least one other floor tile.
any amount of force. The combination of current traction The present invention further features a modular synthetic
enhancing methods along with the edges of sharp perimeter floor tile comprising: (a) an upper contact surface; (b) a
and structural members, all contribute to a more abrasive perimeter Surrounding the upper contact surface, the perim
contact Surface. eter having a blunt edge configured to soften the interface
10 between the floor tile and an adjacent floor tile; (c) a plurality
SUMMARY OF THE INVENTION of recurring openings formed in the upper contact surface,
each of the openings having a diamond shaped geometry
In light of the problems and deficiencies inherent in the defined by structural members configured to intersect with
prior art, the present invention seeks to overcome these by one another at various intersection points, the structural mem
providing a unique floor tile designed to provide an increase 15 bers having a smooth, planar top surface forming the contact
of traction without the abrasiveness of prior related floor tiles. Surface, and a face oriented transverse to the top surface; (d)
Rather than providing raised nubs or an abrasive aggressive a curved transition Surface extending between the top Surface
texture to increase traction about the contact surface of the and the face of the structural members configured to provide
floor tile, the present invention increases traction by increas a blunt edge between the top surface and the face, and to
ing coefficient of friction about the contact surface. Coeffi reduce the abrasiveness of the floor tile; and (e) means for
cient of friction may be increased by Striking an optimized coupling the floor tile to at least one other floor tile.
balance between the Surface area and the openings of the The present invention still further features a method for
contact surface. Stated differently, the coefficient of friction enhancing the performance characteristics of a modular syn
of the contact surface may be manipulated by manipulating thetic floor tile, the method comprising: (a) providing a plu
various design factors, such as the size of the contact Surface 25 rality of structural members to form an upper contact surface;
openings, the geometry of Such openings, as well as the size (b) configuring the structural members to intersect one
and configuration of the various structural members defining another at intersection points and to define a plurality of
Such openings. Each of these, either individually or collec openings having at least one acute angle as measured between
tively, function to affect the coefficient of friction depending imaginary axes extending through the intersection points, the
on their configuration. In any given embodiment, each of 30 openings wedging configured to receive and wedge at least a
these parameters may be manipulated and optimized to pro portion of an object acting on the contact Surface to provide
vide a floor tile having enhanced performance characteristics. increased traction about the contact surface, the structural
A floor tile formed in accordance with an effort to optimize members having a top Surface forming the contact surface,
the above parameters also benefits from being much less and a face oriented transverse to the top surface; and (c)
abrasive as compared to other prior related floor tiles. Abra 35 configuring the structural members with a transition Surface
siveness is further reduced by providing blunt edges or tran extending between the top surface and the face to provide the
sition surfaces along the perimeter of the floor tile, as well as structural members with a blunt edge configured to reduce
the various structural members defining the openings and abrasiveness of the floor tile.
contact Surface. The present invention still further features a method for
In accordance with the invention as embodied and broadly 40 enhancing the performance characteristics of a modular syn
described herein, the present invention features a modular thetic floor tile, the method comprising: (a) providing a plu
synthetic floor tile comprising: (a) an upper contact surface; rality of structural members configured to form a smooth,
(b) a plurality of openings formed in the upper contact Sur planar upper contact Surface having a plurality of openings;
face, each of the openings having a geometry defined by (b) optimizing a ratio of Surface area of the structural mem
structural members configured to intersect with one another 45 bers to an open area of the openings to satisfy a pre-deter
at various intersection points to form at least one acute angle mined threshold coefficient of friction of the contact surface;
as measured between imaginary axes extending through the and (c) optimizing a configuration of a transition Surface with
intersection points, the structural members having a smooth, respect to the Surface area to satisfy a pre-determined thresh
planar top surface forming the contact surface, and a face old of abrasiveness.
oriented transverse to the top surface; (c) a transition Surface 50
extending between the top surface and the face of the struc BRIEF DESCRIPTION OF THE DRAWINGS
tural members configured to provide a blunt edge between the
top surface and the face, and to reduce abrasiveness of the The present invention will become more fully apparent
floor tile; and (d) means for coupling the floor tile to at least from the following description and appended claims, taken in
one other floor tile. 55 conjunction with the accompanying drawings. Understand
The present invention also features a modular synthetic ing that these drawings merely depict exemplary embodi
floor tile comprising: (a) a perimeter; (b) an upper contact ments of the present invention they are, therefore, not to be
Surface contained, at least partially, within the perimeter; (c) considered limiting of its scope. It will be readily appreciated
a first series of structural members extending between the that the components of the present invention, as generally
perimeter; (d) a second series of structural members extend 60 described and illustrated in the figures herein, could be
ing between the perimeter, and intersecting the first series of arranged and designed in a wide variety of different configu
structural members in a manner So as to form a plurality of rations. Nonetheless, the invention will be described and
openings in the upper contact surface, each of the openings explained with additional specificity and detail through the
having a configuration selected from a diamond and dia use of the accompanying drawings in which:
mond-like geometry defined by the intersection of the first 65 FIG. 1-A illustrates a perspective view of a modular syn
and second series of structural members, the first and second thetic floor tile in accordance with one exemplary embodi
series of structural members comprising a smooth, planar top ment of the present invention;
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US 8,407,951 B2
5 6
FIG. 1-B illustrates a cut-away sectional view of the exem in the art to practice the invention, it should be understood that
plary floor tile of FIG. 1-A: other embodiments may be realized and that various changes
FIG. 2 illustrates a top view of the exemplary floor tile of to the invention may be made without departing from the
FIG. 1-A; spirit and scope of the present invention. Thus, the following
FIG. 3 illustrates a bottom view of the exemplary floor tile more detailed description of the embodiments of the present
of FIG. 1-A: invention is not intended to limit the scope of the invention, as
FIG. 4 illustrates a first side view of the exemplary floor tile claimed, but is presented for purposes of illustration only and
of FIG. 1-A: not limitation to describe the features and characteristics of
FIG. 5 illustrates a second side view of the exemplary floor the present invention, to set forth the best mode of operation
tile of FIG. 1-A: 10 of the invention, and to sufficiently enable one skilled in the
FIG. 6 illustrates a third side view of the exemplary floor art to practice the invention. Accordingly, the scope of the
tile of FIG. 1-A: present invention is to be defined solely by the appended
FIG. 7 illustrates a fourth side view of the exemplary floor claims.
tile of FIG. 1-A: The following detailed description and exemplary embodi
FIG. 8 illustrates a perspective view of a modular synthetic 15 ments of the invention will be best understood by reference to
floor tile in accordance with another exemplary embodiment the accompanying drawings, wherein the elements and fea
of the present invention; tures of the invention are designated by numerals throughout.
FIG. 9 illustrates a top view of the exemplary floor tile of The present invention describes a method and system for
FIG. 8: enhancing the performance characteristics of a synthetic
FIG. 10 illustrates bottom view of the exemplary floor tile flooring system comprising a plurality of individual modular
of FIG. 8: floor tiles. The present invention discusses various design
FIG. 11 illustrates a partial detailed perspective view of the factors or parameters that may be manipulated to effectively
exemplary floor tile of FIG. 8: enhance, or even optimize, the performance characteristics of
FIG. 12 illustrates a side view of the exemplary floor tile of individual modular floor tiles, and the resulting assembled
FIG. 8: 25 flooring system. Although a floor tile possesses many perfor
FIG. 13-A illustrates a partial sectional side view of the mance characteristics, those of coefficient of friction and
exemplary floor tile of FIG. 8: abrasiveness are the focus of the present invention.
FIG. 13-B illustrates a partial sectional side view of the Generally speaking, it is believed that the coefficient of
exemplary floor tile of FIG. 8: friction of a modular synthetic floor tile may be enhanced by
FIG. 14 illustrates a partial top view of an exemplary floor 30 balancing and manipulating various design considerations or
tile having a diamond shaped opening; parameters, namely the Surface area of the upper contact
FIG. 15 illustrates a partial top view of an exemplary floor surface, the size of some or all of the openings of the floor tile
tile having a diamond shaped opening; (e.g., the ratio of Surface area to opening or opening area), and
FIG. 16 illustrates a partial top view of an exemplary floor the geometry of Some or all of the openings in the contact
tile having a diamond-like opening; 35 surface of the floor tile. Other design parameters, such as
FIG. 17 illustrates a partial sectional side view of an exem material makeup, area also important considerations.
plary floor tile and an object acting on a contact Surface of the With respect to the surface area of the upper contact sur
floor tile; face, and particularly the various structural members making
FIG. 18 illustrates apartial top view of the floor tile of FIG. up or defining the upper contact surface, it has been found that
17; 40 the coefficient of friction or traction of a floor tile, and ulti
FIG. 19 illustrates a graph depicting the results of the mately an assembled flooring system, may be enhanced by
coefficient of friction test performed on a plurality of floor manipulating the ratio of Surface area to opening area (which
tiles; is directly related to or dependant on the size of the openings).
FIG. 20 illustrates a graph depicting the results of an abra A floor tile comprising a plurality of openings formed in its
siveness test performed on a plurality of floor tiles: 45 contact surface for one or more purposes (e.g., to facilitate
FIG. 21 illustrates a top view of a modular synthetic floor water drainage, etc.) will obviously sacrifice to some extent
tile in accordance with still another exemplary embodiment the quantity of Surface area compared to the quantity of open
of the present invention; ing area. However, the size of the openings and the thickness
FIG. 22 illustrates a top view of a modular synthetic floor of the top Surfaces of the structural members making up the
tile in accordance with still another exemplary embodiment 50 openings (which top Surfaces define the upper contact Sur
of the present invention; face, and particularly the Surface area of the upper contact
FIG. 23 illustrates a top view of a modular synthetic floor surface) may be manipulated to achieve a floor tile have more
tile in accordance with still another exemplary embodiment or less coefficient of friction.
of the present invention; and With respect to the size of the openings in the upper contact
FIG. 24 illustrates a top view of a modular synthetic floor 55 Surface, these also can be manipulated to enhance the coeffi
tile in accordance with still another exemplary embodiment cient of friction. It has been discovered that the openings can
of the present invention. be configured to receive and apply a compression force to
objects acting on or moving about the contact surface of the
DETAILED DESCRIPTION OF EXEMPLARY floor tile that are sufficiently pliable. Openings too small may
EMBODIMENTS 60 not adequately receive an object, while openings too large
may limit the area of the object being acted on by the open
The following detailed description of exemplary embodi ings.
ments of the invention makes reference to the accompanying Finally, with respect to the geometry of the openings in the
drawings, which form a part hereof and in which are shown, upper contact surface, it has been discovered that certain
by way of illustration, exemplary embodiments in which the 65 openings are able to enhance the coefficient of friction of a
invention may be practiced. While these exemplary embodi floor tile better than others. Specifically, openings having at
ments are described in sufficient detail to enable those skilled least one acute angle (as defined below) function to enhance
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7 8
the coefficient of friction by applying a compression force to bility, wearability, etc. As can be seen, this applies to both
Suitably pliable objects acting on or moving about the contact physical related characteristics (e.g., those types of charac
Surface. By providing at least one acute angle in Some orall of teristics that enable the flooring system to provide a good
the openings of a modular synthetic floor tile, the openings playing Surface, or that affect the performance of objects or
are able to essentially wedge a portion of the object in those individuals acting on or traveling about the playing Surface),
segments of the opening formed on the acute angle. By doing and safety related characteristics (e.g., those types of charac
So, one or more compression forces are induced and caused to teristics of the floor tile that have a tendency to minimize the
act on the object, which compression forces function to potential for injury). For example, traction may be described
increase the coefficient of friction. as a physical performance characteristic that contributes to
It is contemplated that all of these design parameters may 10 the level of play that is possible about the contact surface.
Abrasiveness may be termed a safety related performance
be carefully considered and balanced for a given floor tile. It characteristic although it is not necessarily an indicator of
is also contemplated that each of these design parameters may how well the flooring system is going to affect or enable
be optimized for a given floor tile design. Optimized does not sports or activity play and at what level. Nonetheless, the
necessarily mean maximized. Indeed, although it will most ability to minimize injury, and thus enable safe play, particu
likely always be desirable to maximize the coefficient of 15
larly in the event of a fall, is an important consideration.
friction of a particular floor tile, this may not necessarily The term “traction, as used herein, shall be understood to
mean that each of the above-identified design parameters is mean the measurement of coefficient of friction of the floor
maximized to achieve this. For a given floor tile, the coeffi ing system (or individual floor tiles) about its contact surface.
cient of friction may be best enhanced by some design param The terms 'abrasive' or "abrasiveness, as used herein,
eters giving way to Some extent to other design parameters. shall be understood to mean the tendency of the flooring
Thus each one is to be carefully considered for each floor tile system (or individual floor tiles) to abrade or chafe an the
design. In addition, there may be instances where the coeffi Surface of an object that drags or is dragged across its contact
cient of friction may not always be maximized. For example, Surface.
aesthetic constraints may trump the ability to maximize the The term “acute, as used herein, shall be understood to
coefficient of friction. In any case, it is contemplated that by 25 mean an angle or segment of structural members intersecting
manipulating the above-identified design parameters that the one another on an angle less than 90°. The reference to acute
coefficient of friction for any given floor tile may be does not necessarily mean an angle and does not necessarily
enhanced, or optimized, to some degree. mean a segment of an opening formed by two linear Support
To illustrate, it may not be possible, in some instances, to members. An opening may comprise an acute angle (even
though its defining structural members are nonlinear) as it is
maximize the ratio of Surface area to opening area for a 30
understood that an acute angle is measured between imagi
particular floor tile. However, this does not mean that the ratio nary axes extending through three or more intersection points
cannot nevertheless be optimized. By optimizing this ratio, of the structural members defining an opening.
taking into account all other design parameters, the overall The term "obtuse, as used herein, shall be understood to
coefficient of friction of the floor tile may be enhanced to mean an angle or segment of structural members intersecting
Some degree, even in light of other overriding factors. 35
one another on an angle greater than 90°. The reference to
It has also been discovered that the coefficient of friction obtuse does not necessarily mean an angle and does not
can be enhanced without the need for providing texture in the necessarily mean a segment of an opening formed by two
contact Surface, as exists in many prior related designs. linear Support members. An opening may comprise an obtuse
Indeed, the present invention advantageously provides a flat, angle (even though its defining structural members are non
planar contact Surface without texture to achieve an enhanced 40 linear) as it is understood that an obtuse angle is measured
coefficient of friction. As discussed above, in some cases between imaginary axes extending through three or more
texture can reduce the coefficient of friction of the floor tile, intersection points of the structural members defining an
thus making objects acting on the contact Surface more prone opening.
to slipping. By providing a flat, planar contact surface, the The term “transition surface, as used herein, shall be
entire Surface area is able to come into contact with an object. 45 understood to meana Surface or edge extending between atop
In a related aspect, it has been discovered that the coeffi Surface of a structural member or perimeter member, and a
cient of friction of a floor tile can be enhanced without the face or side of that member to provide a soft or blunt transition
need for additional raised or protruding members extending between the top surface and the face. Such a transition surface
upward from the contact Surface, as also is provided in many functions to reduce the abrasiveness of the flooring system. A
prior related designs. 50 transition Surface may comprise a linear segment, a round
Generally speaking, the abrasiveness of a floor tile, and segment having a radius or an arc to provide a rounded edge,
Subsequent assembled flooring system, may be reduced by or any combination of these.
reducing the tendency of the floor tile to abrade an object The term "diamond-like, as used herein, shall be under
acting on or moving about the contact Surface of the floor tile. stood to mean any closed geometric shape having at least one
By forming various transition surfaces between each of the 55 obtuse angle and at least one acute angle.
edges and top Surfaces of the structural members and the The term “opening area’’ or “area of the opening(s) as
perimeter, a softer, Smoother contact surface is created. In used herein, shall be understood to mean the calculated or
addition, the interface between adjacent tiles is also softened quantifiable area or size of the open space or Void in the
due to the transition Surface along the perimeter. opening as defined by the structural members making up the
60 opening and defining its boundaries. Commonly known area
Definitions calculations are intended to provide the area of the opening(s)
measured in any desirable units—unit.
The term “tile performance' or “performance characteris
tic, as used herein, shall be understood to mean certain Traction and Abrasiveness
measurable characteristics of a flooring system or the indi 65
vidual floor tiles making up the flooring system, such as grip One of the more important challenges in the construction
or traction, ball bounce, abrasiveness, shock absorption, dura of synthetic floor tiles and corresponding flooring systems is
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US 8,407,951 B2
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the need to provide a contact Surface having adequate traction normal force is less because less of the force of gravity is
or grip. Traction refers to the friction existing between a drive perpendicular to the face of the plane. Therefore, the normal
member and the surface it moves upon, where the friction is force, and ultimately the frictional force, may be determined
used to provide motion. In other words, traction may be using vector analysis, usually via a free body diagram.
thought of as the resistance to lateral motion when one Depending on the situation, the calculation of the normal
attempts to slide the surface of one object over another sur force may include forces other than gravity.
face. Traction is particularly important where the synthetic Material makeup also affects the coefficient of friction of
flooring system is to be used for one or more sports-related or an object. In most applications, there is a complicated set of
other similar activities. trade-offs in choosing materials. For example, soft rubbers
The level of traction a particular flooring system (or indi 10 often provide better traction, but also wear faster and have
vidual floor tile) provides may be described in terms of its higher losses when flexed—thus hurting efficiency.
measured coefficient of friction. As is will known, coefficient Another important challenge in the production of synthetic
of friction may be defined as a measure of the slipperiness flooring systems is the reduction of the abrasiveness of the
between two surfaces, wherein the larger the coefficient of contact surface. Abrasiveness may be thought of as the degree
friction, the less slippery the Surfaces are with respect to one 15 to which a surface tends to abrade the surface of an object
another. One factor affecting coefficient of friction (or trac being dragged over the Surface. A common test for abrasive
tion) is the magnitude of the normal force acting on one or ness of a Surface comprises dragging a friable block over the
both of the objects having the two surfaces, which normal Surface under a given load. This is done in all directions over
force may be thought of as the force pressing the two objects, the surface. The block is then removed and weighed to deter
and therefore the two surfaces, together. Another factor mine its change in weight from before the test. The change in
affecting coefficient of friction is the type of material from weight represents the amount of material that was lost or
which the Surfaces are formed. Indeed, some materials are scrapped from the block.
more slippery than others. To illustrate these two factors, The more abrasive a floor tile is the more it will have a
pulling a heavy wooden block (one having a large normal tendency to abrade the skin and clothes of an individual, and
force) across a surface requires more force than does pulling 25 thus cause injury and damage. Therefore, it is desirable to
a light block (one having a smaller normal force) across the reduce abrasiveness as much as possible. However, because
same Surface. And, pulling a wooden blockacross a Surface of traction is considered more desirable, abrasiveness has often
rubber (large coefficient of friction) requires more force than been sacrificed for an increase in traction (e.g., by providing
pulling the same block across a surface of ice (Small coeffi protrusions and/or texture about the contact surface). Unlike
cient of friction). 30 many prior art designs, the present invention advantageously
For a given pair of surfaces, there are two types of friction provides both an increase in traction and a reduction in abra
coefficient. The coefficient of static friction, u, applies when siveness.
the surfaces are at rest with respect to one another, while the
coefficient of kinetic friction, L, applies when one Surface is DESCRIPTION
sliding across the other. 35
The maximum possible friction force between two sur With reference to FIGS. 1-7, illustrated is a modular syn
faces before sliding begins is the product of the coefficient of thetic floor tile in accordance with one exemplary embodi
static friction and the normal force: F LN. It is important ment of the present invention. As shown, the floor tile 10
to realize that when sliding is not occurring, the friction force comprises an upper contact Surface 14, shown as having a
can have any value from Zero up to F. Any force Smaller 40 grid-type or lattice configuration, that functions as the pri
than Flattempting to slide one surface over the other will be mary support or activity surface of the floor tile 10. In other
opposed by a frictional force of equal magnitude and opposite words, the upper contact surface 14 is the primary Surface
in direction. Any force larger than F will overcome friction over which objects or people will travel, and that is the pri
and cause sliding to occur. mary interface Surface with Such objects or people. The upper
When one surface is sliding over the other, the friction 45 contact surface 14 thus inherently comprises a measurable
force between them is always the same, and is given by the degree or level of traction and abrasiveness that will contrib
product of the coefficient of kinetic friction and the normal ute to and affect the performance characteristics of the floor
force: FLN. The coefficient of static friction is larger than tile 10, or more specifically the performance of those objects
the coefficient of kinetic friction, meaning it takes more force and people acting on the floor tile 10. The level of traction and
to make Surfaces start sliding over each other than it does to 50 abrasiveness of the floor tile is discuss in greater detail below.
keep them sliding once started. The floor tile 10 further comprises a plurality of structural
These empirical relationships are only approximations. members that make up or define the grid-type upper contact
They do not hold exactly. For example, the friction between Surface 14, and that provide structural Support to the upper
Surfaces sliding over each other may depend to some extent contact Surface 14. In the exemplary embodiment shown, the
on the contact area, or on the sliding Velocity. The friction 55 floor tile 10 comprises a first series of rigid parallel structural
force is electromagnetic in origin, meaning atoms of one members 18 that, although parallel to one another, extend
surface function to “stick” to atoms of the other surface diagonally, or on an incline, with respect to the perimeter 26.
briefly before Snapping apart, thus causing atomic vibrations, The floor tile 10 further comprises a second series of rigid
and thus transforming the work needed to maintain the sliding parallel structural members 22 that also, although parallel to
into heat. However, despite the complexity of the fundamen 60 one another, extend diagonally, or on an incline, with respect
tal physics behind friction, the relationships are accurate to the perimeter 26. The first and second series of structural
enough to be useful in many applications. members 18 and 22, respectively, are oriented differently and
If an object is on a level surface and the force tending to are configured to intersect one another to form and define a
cause it to slide is horizontal, the normal force N between the plurality of openings 30, each opening 30 having a geometry
object and the Surface is just its weight, which is equal to its 65 defined by a portion of the structural members 18 and 22
mass multiplied by the acceleration due to earth's gravity, g. configured to intersect with one another at various intersec
If the object is on a tilted Surface Such as an inclined plane, the tion points to form at least one acute angle as measured
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11 12
between imaginary axes extending through the intersection or Support Surface, such as concrete or asphalt. As shown, the
points. In this case, the structural members 18 and 22 are bottom of the floor tile 10 comprises a plurality of vertical
configured to form openings 30 having a diamond shape, in support posts 54, which give strength to the floor tile 10 while
which the structural members that define each individual keeping its weight low. The Support posts 54 extend down
opening are configured to intersect or converge on one from the underside of the contact surface, and particularly the
another to form opposing acute angles and opposing obtuse structural members 18 and 22. The support posts 54 may be
angles, again as measured between imaginary axes extending located anywhere along the underside of the floor tile surface,
through the points of intersection of the structural members and the structural members, but are preferably configured to
18 and 22.
The structural members 18 further comprise a smooth, 10
extend from the points of intersection, each one or a select
planar top surface 34 forming at least a portion of the upper number, of the structural members, as shown. In addition, the
contact surface 14, and opposing sides or faces 38-a and 38-b Support posts 54 may be any length or offset lengths, and may
oriented transverse to the top surface 34 (see FIG.1-B). In the comprise the same or different material than that of the struc
tural members 18 and 22.
exemplary embodiment shown, the faces 38-a and 38-b are A plurality of coupling elements in the form of loop and pin
oriented in a perpendicular or orthogonal manner with respect 15
to the top surface 34, and intersect the top surface 34. connectors are disposed along the perimeter wall 46, with
Although not shown in detail, the structural members 22 loop connectors 60 disposed on two contiguous sides, and pin
comprise a similar configuration, each also having a top Sur connectors 64 disposed on opposing contiguous sides. The
face and opposing faces. loop and pin connectors 60 and 64, respectively, are config
As will be discussed below, the structural members used to ured to allow interconnection of the floor tile 10 with similar
form the floor tile and to define the contact surface in any adjacent floor tiles to form a flooring system, in a manner that
embodiment herein may comprise other configurations to is well known in the art. It is also contemplated that other
define a plurality of differently configured openings in the types of connectors or coupling means may be used other than
upper contact surface, or openings having a different geom those specifically shown and described herein.
etry. As discussed herein, the present invention provides a 25 With reference to FIGS. 8-13, illustrated is a modular syn
way to enhance traction of the contact Surface by providing thetic floor tile in accordance with another exemplary
openings that have at least one acute angle, as defined herein. embodiment of the present invention. This particularembodi
This does not necessarily mean however, that each and every ment is exemplary of the modular synthetic floor tile manu
opening in the contact Surface will comprise at least one acute factured and sold by Connor Sport Court International, Inc. of
angle. Indeed, an upper contact surface may have a plurality 30 Salt Lake City, Utah under the PowerGameTM trademark.
of openings, only some of which have at least one acute angle. This embodiment is similar to the one described above and
This may be dictated by the configuration of the structural illustrated in FIGS. 1-7, but comprises some differences,
members and the resulting particular geometry of the open namely a multiple-level (bi-level to be specific) surface con
ings in the contact Surface, as is discussed below and illus figuration. As such, the description above is incorporated
trated in FIGS. 21-24. 35 herein, where appropriate. As shown, the floor tile 110 com
Circumscribing the upper contact surface 14 and the gen prises an upper contact Surface 114, shown as having a grid
eral dimensions of the floor tile 10 is a perimeter 26, which type configuration, that functions as the primary Support or
functions as a boundary for the floor tile 10, as well as an activity surface of the floor tile 110. The upper contact surface
interface with adjacent floor tiles configured to be intercon 114 is similar in function as that described above.
nected with the floor tile 10. The perimeter 26 also comprises 40 The floor tile 110 further comprises a plurality of structural
a top surface 42 and a face or wall 46, which extends around members that make up or define the grid-type upper contact
the floor tile 10. The top surface 42 of the perimeter is gen Surface 114, and that provide structural Support to the upper
erally planar with the top surface of the various structural contact Surface 114. In the exemplary embodiment shown,
members 18 and 22. As such, the perimeter 26 and the struc the floor tile 110 comprises a first series of rigid parallel
tural members 18 and 22 each function to define at least a 45 structural members 118 and a second series of structural
portion of the contact surface 14. members 122 that are similar in configuration and function as
The floor tile 10 is square or approximately square in plan, those described above.
with a thickness T that is substantially less than the plan The first and second series of structural members 118 and
dimension L and L. Tile dimensions and material compo 122 are configured to form openings 130 within the contact
sition will depend upon the specific application to which the 50 Surface 114 having a diamond shape. As in the embodiment
tile will be applied. Sport uses, for example, frequently call discussed above, the structural members that define each
for floor tiles having a square configuration with side dimen individual opening are configured to intersect or converge on
sions (L and L) being either 9.8425 inches (metric tile) or one another to form opposing acute angles and opposing
12.00 inches. Obviously, other shapes and dimensions are obtuse angles, again as measured between imaginary axes
possible. The thickness T may range between 0.25 and 1 55 extending through the points of intersection of the structural
inches, although a thickness T between 0.5 and 0.75 inches is members 118 and 122.
preferred, and considered a good practical thickness for a The structural members 118 further comprise a smooth,
floor tile such as that depicted in FIG.1. Other thicknesses are planar top Surface 134 forming at least a portion of the upper
also possible. The floor tiles can be made of many suitable contact surface 114, and opposing sides or faces 138-a and
materials, including polyolefins, such as polypropylene, 60 138-b oriented transverse to the top surface 134 (see FIGS.
polyurethane and polyethylene, and other polymers, includ 13-A and 13-B). The top surface 134 may comprise different
ing nylon. Tile performance may dictate the type of material widths (as measured along a cross-section of the structural
used. For example, Some materials provide better traction member) that may also be optimized to contribute to the
than other materials, and such should be considered when overall enhancement of the coefficient of friction. In the
planning and installing a flooring system. 65 exemplary embodiment shown, the faces 138-a and 138-bare
The floor tile 10 further comprises a support structure (see oriented in a perpendicular or orthogonal manner with respect
FIG. 3) designed to support the floor tile 10 about a subfloor to the top surface 134, and intersect the top surface 134.
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Although not shown in detail, the structural members 122 age gaps 186 are defined by the relationship between the
comprise a similar configuration, each also having a top Sur structural members of the upper and lower surface levels 170
face and opposing faces. and 174 and any openings formed by these. The drainage gaps
Extending between the top surface 134 and each of the 186 can have a minimum dimension selected so as to resist the
faces 138-a and 138-b is a transition surface designed to entrance of debris, Such as leaves, tree seeds, etc., which
eliminate the sharp edge that would otherwise exist between could clog the drainage pathways below the top surface of the
the top Surface and the faces. In one exemplary embodiment, tile, yet still provide for adequate drainage of water.
the transition Surface may comprise a curved configuration, With reference to FIGS. 8-11, 13-A and 13-B, advanta
such as an arc or radius (see the transition surface 140 of FIG. geously, the first and second series of structural members 178
13-A as comprising a radius of 0.02 inches). The radius of a 10 and 182, respectively, of the lower surface level 174 each have
curved transition surface may be between 0.01 and 0.03 a top surface 180 and 184, respectively, that is below the top
inches, and is preferably 0.02 inches. In another aspect, the surfaces 134 and 136 of the first and second series of struc
transition Surface may comprise a linear configuration, Such tural members 118 and 122 of the upper surface level 170, as
as a chamfer, with the linear segment extending downward on well as the contact surface 114, so as to draw residual mois
an incline from the top surface 134 (see the transition surface 15 ture from the contact surface 114. Specifically, the surface
140 of FIG. 13-B as comprising a chamfer). The angle of tension of water droplets naturally tends to draw the droplets
incline of the linear segment may be anywhere from 5 to 85 down to the lower surface level 174, so that if drops hang in
degrees, as measured from the horizontal. Still further, the the drainage openings 186, they will tend to hang adjacent to
transition segment may comprise a combined linear and non the lower surface level 174, rather than the upper surface level
linear configuration. 170, thus reducing the persistence of moisture on the upper
In essence, the effect of the transition surface is to soften contact Surface 114, making the flooring system usable
the edge of the structural members, thus reducing the abra Sooner after wetting, and thus further enhancing the traction
siveness of the floor tile or the tendency for the floor tile to along the upper contact surface 114. The lower surface level
abrade an object drug over its surface. also functions to break the surface tension of water droplets,
Circumscribing the upper contact Surface 114 and the gen 25 thus facilitating the drawing of the water to the one or more
eral dimensions of the floor tile 110 is a perimeter 126, which lower surface levels.
comprises a similar configuration and function as the one In one embodiment, the top surfaces 180 and 184 of the
described above. Specifically, the perimeter 126 comprises a lower surface level 174 are disposed about 0.10 inches below
top surface 142 and a face or wall 146, which extends around the top surfaces 134 and 136 of the upper surface level 170.
the floor tile 110. Like the various structural members, the 30 The inventors have found this dimension to be a practical and
perimeter may also comprise a transition Surface having a functional dimension, but the tile is not limited to this. In the
curved or linear configuration that extends between the top embodiment depicted in the figures, the upper surface level
surface 143 and the face 146. In the embodiment shown, the 170 and lower surface level 174 have a substantially coplanar
perimeter comprises a transition Surface having a radius of underside 190, with the upper surface level 170 thus compris
0.02 inches. This further contributes to a reduction in overall 35 ing a thickness that is about twice that of the lower surface
abrasiveness of the tile, as well as softens the interface level 174.
between adjacent floor tiles. The floor tile 110 further comprises a support structure (see
The floor tile 110 is square or approximately square in plan, FIG. 10) extending down from the underside 190. As dis
with a thickness T that is substantially less than the plan cussed above, the Support structure is designed to Support the
dimension L and L. 40 floor tile 110 about a subfloor or support surface, such as
Unlike the floor tile 10 illustrated in FIGS. 1-7, the floor tile concrete or asphalt. The bottom or underside 190 of the floor
110 comprises a bi-level surface configuration comprised of tile 110 comprises a plurality of vertical support posts 154,
first and second surface levels. The first surface level com which give strength to the floor tile 110 while keeping its
prises an upper surface level configuration 170 (hereinafter weight low. The support posts 154 extend down from the
upper Surface level) and a lower Surface level configuration 45 underside of the contact surface, and particularly from the
174 (hereinafter lower surface level). The upper surface level structural members 118 and 122. The support posts 154 may
170 comprises and is defined by the first and second series of be located anywhere along the underside of the floor tile
structural members 118 and 122, and further defines the upper Surface, and the structural members, but are preferably con
contact Surface 114. figured to extend from the points of intersection, each one or
The lower surface level 174 also comprises first and second 50 a select number, of the structural members 118 and 122, as
series of structural members 178 and 182, each of which shown. In addition, the Support posts 154 may be any length
comprise a plurality of individual, parallel structural mem or offset lengths, and may comprise the same or different
bers. The first series of structural members 178 is oriented material than that of the structural members 118 and 122.
orthogonal or perpendicular to the second series of structural The floor tile 110 comprises a plurality of secondary Sup
members 182, and each of the first and series of structural 55 port posts 154 that extend down from the intersection of the
members 178 and 182 are oriented orthogonal or perpendicu first and second series of structural members 178 and 182 of
lar to respective segments of the perimeter 126. the lower surface level 174. The secondary support posts 156
The lower surface level 174 comprises a grid-like or lattice are shown as terminating at a different elevation from the
configuration that is oriented generally transverse to the support posts 154.
upper surface level 170, which also comprises a grid-like or 60 A plurality of coupling elements in the form of loop and pin
lattice configuration, so as to provide additional strength to connectors are disposed along the perimeter wall 146, with
the upper contact surface 114, as well as to provide additional loop connectors 160 disposed on two contiguous sides, and
benefits. pin connectors 164 disposed on opposing contiguous sides.
The upper and lower surface levels 170 and 174, respec With reference to FIG. 14, illustrated is a detailed top view
tively, are integrally formed with one another and provide a 65 of an opening in a contact Surface of a floor tile in accordance
grid extending within the perimeter 126 with drainage gaps with one exemplary embodiment of the present invention.
186 formed therethrough (see FIGS. 9 and 11), which drain The opening 200 is defined by a plurality of linear structural
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15 16
members, having a thickness t, shown as structural members about the contact surface. Indeed, the floor tile is configured
202, 206, 210, and 214. The structural members are config with an enhanced coefficient of friction, which is at least
ured to intersect one another at a plurality of intersection partially a result of the size and geometry of the openings in
points to define the size and geometry of the opening 200. the contact Surface. For example, an object, Such as a shoe
Specifically, structural members 202 and 206 are configured 5 being worn by an individual participating in one or more
to intersect one another at intersection point 218; structural sports or activities, acting on or moving about the contact
members 206 and 210 are configured to intersect one another Surface may be received within the openings, including the
at intersection point 222; structural members 210 and 214 are acute or wedged segment of the openings. In other words, at
configured to intersect one another at intersection point 226; least a portion of the object may be caused to extend over the
structural members 214 and 202 are configured to intersect 10
edges of the structural members of the contact surface and
one another at intersection point 230. into the openings in the floor tile. This is particularly the case
Furthermore, structural member 202 is configured to inter if the object is at least somewhat pliable.
sect structural member 206 to form an acute angle C. as As the object is caused to further move laterally across the
measured between an imaginary longitudinal axis 234 of
structural member 206 and an imaginary longitudinal axis 15 contact surface in a direction toward the acute angle (such as
238 of structural number 202; structural member 210 is con in the case of an individual initiating movement in a certain
figured to intersect structural member 214 to form an acute direction), the object will be further forced into the acute
angle C as measured between an imaginary longitudinal axis segment or wedge of the opening comprising the acute angle.
242 of structural member 210 and an imaginary longitudinal As this occurs, one or more compression forces are created by
axis 246 structural members 214; structural member 202 is the various structural members on the portion of the object
configured to intersect structural member 214 to form an extending below the contact Surface and into the openings,
obtuse angle B as measured between an imaginary longitu which compression force increases as the object is further
dinal axis 238 of structural number 202 and an imaginary wedged into the acute segment of the opening. As the object
longitudinal axis 246 of structural member 214; structural is wedged into the opening, and as the compression force on
member 206 is configured to intersect structural member 210 25 the portion of the object within the opening increases, the
to forman obtuse angle B as measured between an imaginary coefficient of friction is observably increased, which results
longitudinal axis 234 of structural member 206 and an imagi in increased traction about the contact Surface.
nary longitudinal axis 242 of structural member 210. In In operation, the compression force functions to increase
accordance with this configuration, opening 200 is formed the force necessary to remove the object from the opening.
and defined to comprise two opposing acute angles and two 30 Stated differently, in order to progress in its movement about
opposing obtuse angles, thus forming a diamond shaped the contact surface, the object must be removed or drawn
geometry. from the opening(s). In order to be removed or drawn from the
Depending on the particular design of the floor tile, the opening(s), any compression forces acting on the wedged
obtuse angles f and B may be between 95 and 175 degrees, portion of the object, as applied by the structural members
and preferably between 100 and 140 degrees. Likewise, the 35 defining the opening(s), must be overcome. This increase in
acute angles C. and C may be between 5 and 85 degrees, and force required to draw the object from the openings and to
preferably between 40 and 80 degrees. In the embodiment move the object about the contact surface enables the floor tile
shown in FIG. 14, the acute angles C. and C. are each 74 and the resulting flooring system to exhibit enhanced perfor
degrees, and the obtuse angles B and B are each 106 degrees. mance characteristics as the traction about the contact Surface
These angles correspond also to the openings in the exem 40 is increased.
plary floor tiles illustrated in FIGS. 1-13. It is noted that the compression forces that act on the object
The present invention is intended to set forth the signifi to increase traction are Small enough so as to not significantly
cance of one or more openings of a modular synthetic floor increase the drag on the object, which might otherwise result
tile comprising at least one acute angle, which significance is in a reduction of efficiency of the object as it moves or is
set forth in terms of the ability of Such an opening to enhance 45 caused to be moved about the contact surface. In other words,
a particular performance characteristic of the floor tile, an object moving about the contact surface will not encounter
namely its coefficient of friction or traction. By providing at any noticeable drag nor any reduction in efficiency. Quite the
least one acute angle, or at least one segment of structural contrary, it is believed that the increase in coefficient of fric
members that form an acute angle, assuming an appropriate tion or traction produced by the acute segments in the open
size, the opening will comprise a wedge or wedge-like con 50 ings of the floor tile will instead function to, at least partially
figuration that may receive a Suitably pliable object thereinas if not significantly, increase the efficiency of the objects
the object moves about the contact surface. Indeed, the open movements by reducing the amount of slide or slip about the
ing may be configured to receive the object as the object is contact surface. This perceived increase in efficiency far out
Subject to a load or force causing the object to press against weighs any negative effect that an object might experience as
the contact surface. Furthermore, any lateral movement of the 55 a result of a slight increase in drag.
object about the contact surface, while still subject to the To provide at least one acute angle, the opening will consist
downward pressing load or force, will cause the portion of the of one or more shapes or geometries having an acute angle.
object within the opening to press against the sides of the Some of the geometries contemplated comprise a diamond
opening, or rather the structural members defining the open shaped opening, a diamond-like shaped opening, and a trian
ing. If the lateral movement is such so as to cause the portion 60 gular opening. Each of these are made up primarily of linear
of the object within the opening to press into the wedge segments or sides. However, openings comprising various
formed by the acute angle, various compression forces will be nonlinear or curved segments or sides are also contemplated,
induced that act on the object. some of which are illustrated in FIGS. 16 and 23.
More specifically, each of the openings are configured to In order to be able to receive a portion of the object therein,
receive and at least partially wedge a portion of an object 65 the openings must be appropriately sized. Indeed, openings
acting on the contact surface to enhance the coefficient of too small will have the effect of reducing the amount of the
friction of the floor tile, and to provide increased traction object that may be received into the opening, as well as the
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extent to which the object extends into the opening. As such, member 306 is configured to intersect structural member 310
and as discussed above, the size of the opening for a given to forman obtuse angle? as measured between an imaginary
floor tile may be optimized. longitudinal axis 334 of structural member 306 and an imagi
The size of an opening may be measured in one of several nary longitudinal axis 342 of structural member 310. In
ways. For instance, each of the openings will comprise a accordance with this configuration, opening 300 is formed
perimeter defined by the various structural members making and defined to comprise two opposing acute angles and two
up the perimeter. A measurement of this perimeter, taken opposing obtuse angles, thus forming a diamond shaped
along all sides, will provide a general size of the opening. It is geometry.
contemplated that an optimal sized opening, measured in this As seen, this diamond shaped opening is more elongated
way, will comprise a perimeter measurement between 1.5 and 10
than the diamond shaped opening of FIG. 14. Indeed, in the
3 inches.
Another way the openings may be determined is by mea embodiment shown in FIG. 15, the acute angles C. and Care
suring their length and width, as taken from the two furthest each 45 degrees, and the obtuse angles B and B are each 135
points of the opening existing along X-axis and y-axis coor degrees. As such, it will take a greater amount of force to
dinates. It is contemplated that an optimal sized opening, 15 wedge an object acting on or moving about the contact Sur
measured in this way, will comprise a length 0.25 and 0.75 face of a floor tile comprising openings configured this way
inches and a width between 0.25 and 0.75 inches. the same distance into the opening, which will Subsequently
Still another measurement of the size of an opening may be result in higher compression forces on the object if indeed
in terms of its area, or rather its opening area as defined wedged to Such a distance. Higher compression forces will
herein. Indeed, the openings may comprise an area between result in greater coefficient of friction about the contact sur
50 mm and 625 mm. face. However, the object will be required to exert greater
The size of the openings is directly related to the ratio of forces about the opening to achieve the same degree of wedg
Surface area to opening area. Indeed, the size of the openings ing within the opening. This may or may not be desirable, but
may dictate the surface area provided by the top surfaces of illustrates the affect on coefficient of friction different shaped
the structural members, and thus the contact Surface. Con 25 openings may have.
versely, the surface area of the top surfaces of the structural With reference to FIG. 16, illustrated is a detailed top view
members, and thus the contact surface, may dictate the size of of an opening in a contact Surface of a floor tile in accordance
the openings. As can be seen, these two are inversely related. with another exemplary embodiment of the present invention.
An increase in one will decrease the other. As such, the ratio The opening 400 is similar to the openings 200 and 300
of these two design parameters is significant as the manipu 30 discussed above and shown in FIGS. 14 and 15, except that its
lation of this ratio provides another way to modify and structural members comprise curved or nonlinear segments
enhance the coefficient of friction of the floor tile. that intersect one another. As shown, the opening 400 is
With reference to FIG. 15, illustrated is a detailed top view defined by a plurality of curved structural members, having a
of an opening in a contact Surface of a floor tile in accordance thickness t, shown as structural members 402, 406, 410, and
with another exemplary embodiment of the present invention. 35 414. The structural members are configured to intersect one
This opening 300 is similar to the opening 200 discussed another at a plurality of intersection points to define the size
above and shown in FIG. 14, except that its acute and obtuse and geometry of the opening 400. The radius or curvature of
angles are different. More specifically, the opposing acute the curved segments of the structural members also function
angles are sharper, meaning the structural members defining to define the size and geometry of the opening 400 as these
the acute angles are formed on less of an angle. In addition, 40 may be modified. Specifically, structural members 402 and
the opposing obtuse angles are less sharp, meaning the struc 406 are configured to intersect one another at intersection
tural members defining the obtuse angles are formed on a point 418; structural members 406 and 410 are configured to
greater angle. As shown, the opening 300 is defined by a intersect one another at intersection point 422; structural
plurality of linear structural members, having a thickness t, members 410 and 414 are configured to intersect one another
shown as structural members 302, 306, 310, and 314. The 45 at intersection point 426; structural members 414 and 402 are
structural members are configured to intersect one another at configured to intersect one another at intersection point 430.
a plurality of intersection points to define the size and geom Furthermore, structural member 402 is configured to inter
etry of the opening 300. Specifically, structural members 302 sect structural member 406 to form an acute angle C. as
and 306 are configured to intersect one another at intersection measured between an imaginary axis 434 of structural mem
point 318; structural members 306 and 310 are configured to 50 ber 406 and an imaginary axis 438 of structural number 402;
intersect one another at intersection point 322; structural structural member 410 is configured to intersect structural
members 310 and 314 are configured to intersect one another member 414 to form an acute angle C as measured between
at intersection point 326; structural members 314 and 302 are animaginary axis 442 of structural member 410 and animagi
configured to intersect one another at intersection point 330. nary axis 446 structural members 414; structural member 402
Furthermore, structural member 302 is configured to inter 55 is configured to intersect structural member 414 to form an
sect structural member 306 to form an acute angle C. as obtuse angle f3 as measured between an imaginary axis 438
measured between an imaginary longitudinal axis 334 of of structural number 402 and an imaginary axis 446 of struc
structural member 306 and an imaginary longitudinal axis tural member 414; structural member 406 is configured to
338 of structural number 302; structural member 310 is con intersect structural member 410 to forman obtuse angle Bas
figured to intersect structural member 314 to form an acute 60 measured between an imaginary axis 434 of structural mem
angle C as measured between an imaginary longitudinal axis ber 406 and an imaginary axis 442 of structural member 410.
342 of structural member 310 and an imaginary longitudinal In accordance with this configuration, opening 400 is formed
axis 346 structural members 314; structural member 302 is and defined to comprise two opposing acute angles and two
configured to intersect structural member 314 to form an opposing obtuse angles. However, due to the curved nature of
obtuse angle B as measured between an imaginary longitu 65 the structural members forming or defining the opening, it can
dinal axis 338 of structural number 302 and an imaginary be said that the opening 400 comprises a diamond-like shaped
longitudinal axis 346 of structural member 314; structural geometry rather than a true diamond shape.
Case 2:18-cv-00778-DBP Document 2-2 Filed 10/04/18 Page 36 of 38

US 8,407,951 B2
19 20
FIG. 16 further illustrates another recognized concept of the size of the openings) may all be manipulated to enhance
the present invention. Unlike the linear wedges in the open the coefficient of friction of the floor tile.
ings 200 and 300 above, as created by the various linear
structural members, the opening 400 comprises a curved EXAMPLE
wedge, or curved acute angle. Thus, rather than providing a
constant increase in compression force as the object is further FIGS. 19 and 20 illustrate the results of a coefficient of
wedged, as is the case with openings 200 and 300, the opening friction test and an abrasiveness test performed by an inde
400 functions to increase the rate of change of the increase of pendent testing agency on the above-identified PowerGame
the compression force on the object as it moves further into 10
floor tile from Connor Sport Court International, Inc. as it
the wedge formed by the acute angle. Indeed, as the acute currently exits and as illustrated in FIGS. 8-13, as compared
angle progressively sharpens towards its apex, the force with the results from the same tests performed on several
needed to advance the object into the wedge of the opening other popular floor tiles existing in the marketplace, shown as
will necessarily continually increase. This continuing floor tiles A-F.
increase in force will result in continually greater compres 15
With reference to FIG. 19, and in accordance with ASTM
sion forces being induced and acting on the object by the C1028-06, the standard test method for determining the static
structural members of the opening. coefficient offriction of ceramic tile and other like surfaces by
In each of FIGS. 14-16, it is apparent that for any compres the horizontal dynamometer pull-meter method, it can be
sion forces to be induced on the object by the opening, there seen that the PowerGame floor tile scored a higher coefficient
must be sufficient forces acting on the object to first, be of friction index than any of the other tested floor tiles A-F.
received in the opening, and second, to cause a portion of the With reference to FIG. 20, and in accordance with ASTM
object to wedge into the acute angle of the opening. Thus, it F1015-03, the standard test method for relative abrasiveness
can be said that the coefficient of friction of the contact of synthetic turf playing Surfaces, it can be seen that the
surface will change with the amount and direction of force PowerGame floor tile scored a significantly lower abrasion
exerted on the contact surface by the object. Although this is 25 index than any of the other tested floor tiles A-F. This is due to
true for any floor tile, providing a plurality of openings having the several transition Surfaces existing on the edges of the
at least one acute angle can significantly increase or enhance structural members and the perimeter of the PowerGame floor
the coefficient of friction of a floor tile formed in accordance tile. In addition, this is a result of the lack of any nubs and/or
with the present invention over a prior related floor tile, texture on the contact surface of the PowerGame floor tile.
wherein the same object is caused to exert the same magni 30 It is noted that the coefficient of friction of the PowerGame
tude and direction of force. floor tile was higher than any other competing floor tile, while
FIGS. 17 and 18 illustrate an exemplary situation in which the abrasiveness of the PowerGame floor tile was the lowest.
an individual is participating about a flooring system com By optimizing the ratio of Surface area to opening area, by
prising a plurality of modular floor tiles formed in accordance optimizing opening geometry, by providing a smooth, planar
with the present invention. Specifically, FIGS. 17 and 18 35 contact Surface, and by providing adequate transition Sur
illustrate a portion of the sole 504 of a shoe (not shown) of an faces, the coefficient of friction was maximized, while the
individual as acting on and moving about the contact Surface abrasiveness was minimized.
514 of a present invention floor tile 510 during a sporting FIGS. 21-24 illustrate several different exemplary floor tile
event or other activity. The openings 530-a and 530-b com embodiments, each one comprising a plurality of openings
prise a diamond shaped geometry similar to the ones illus 40 having at least one acute angle. These figures are intended to
trated in FIGS. 1-13. illustrate that not all openings in a floor tile are required to
As one or more force normal Fact on the sole 504 of the comprise at least one acute angle, only some, in order to
shoe (assuming a suitable degree of pliability within the sole), provide an enhancement of the coefficient offriction of a floor
Such as that caused by the weight of the individual wearing tile. FIG. 21 illustrates an exemplary floor tile 610 as com
the shoe and/or any movements initiated by the individual, a 45 prising a plurality of openings 630 having a triangular shaped
portion of the sole 504 is caused to be received into the geometry. FIG. 22 illustrates an exemplary floor tile 710 as
openings 530-a and 530-b formed in the contact surface 514 comprising a plurality of openings 730 having a star shaped
of the floor tile 510, which portion of the sole 504 is identified geometry. A plurality of other openings 732 (hexagonal
as portion 506. The openings 530-a and 530-bare sized so as shaped) are also formed in the contact Surface as a result of the
to permit this. 50 recurring star openings. FIG.23 illustrates an exemplary floor
Furthermore, FIG. 18 illustrates the affect of any lateral tile 810 as comprising a plurality of openings 830 having a
forces F, acting on the sole 504 of the shoe. As shown, in the square-like geometry with curved structural members form
event one or more lateral forces F is caused to act on the sole ing acute angles. A plurality of other openings 832 (football
504, and therefore the portion 506 of the sole 504 received in shaped) are also formed in the contact Surface as a result of the
the opening 530, in the direction of one of the opposing acute 55 recurring square-like openings. FIG. 24 illustrates an exem
angle C. of the opening 530, this will cause the portion 506 of plary floor tile 910 as comprising a plurality of openings 930
the sole 504 to wedge within the acute angle C. defined by the having a square-like shaped geometry, with each side com
various structural members 518 and 522. As this happens, one prising two inwardly slanted linear segments. A plurality of
or more compression forces F are induced by the structural openings 932 are also formed in the contact surface as a result
members 518 and 522, which act on the portion 506 of the 60 of the recurring square-like openings.
sole 504 of the shoe within the opening 530 to essentially The foregoing detailed description describes the invention
squeeze the portion 506, as indicated by the several longitu with reference to specific exemplary embodiments. However,
dinal lines of the sole 504 that converge upon one another it will be appreciated that various modifications and changes
within the acute angle of the opening 530. As discussed can be made without departing from the scope of the present
above, this effectively functions to increase the coefficient of 65 invention as set forth in the appended claims. The detailed
friction about the contact surface 514. The degree of the acute description and accompanying drawings are to be regarded as
angles and the thickness of the structural members (and thus merely illustrative, rather than as restrictive, and all such
Case 2:18-cv-00778-DBP Document 2-2 Filed 10/04/18 Page 37 of 38

US 8,407,951 B2
21 22
modifications or changes, if any, are intended to fall within gular configuration, a triangular configuration having curved
the scope of the present invention as described and set forth sides, a rectangular configuration, and a rectangular configu
herein. ration having curved sides.
More specifically, while illustrative exemplary embodi 7. The modular synthetic floor tile of claim 6, wherein said
ments of the invention have been described herein, the present openings, in said diamond configuration and said diamond
invention is not limited to these embodiments, but includes configuration having curved sides, comprise opposing acute
any and all embodiments having modifications, omissions, angles and opposing obtuse angles as formed and defined by
combinations (e.g., of aspects across various embodiments), said structural members configured to intersect with one
adaptations and/or alterations as would be appreciated by 10
another at various intersection points, said opposing obtuse
those in the art based on the foregoing detailed description. and acute angles being measured between imaginary axes
The limitations in the claims are to be interpreted broadly extending through said intersection points.
based on the language employed in the claims and not limited 8. The modular synthetic floor tile of claim 1, wherein each
to examples described in the foregoing detailed description or of said plurality of openings individually comprise a diamond
during the prosecution of the application, which examples are 15
shaped geometry.
to be construed as non-exclusive. For example, in the present 9. The modular synthetic floor tile of claim 1, wherein said
disclosure, the term “preferably' is non-exclusive where it is acute angle of said openings is defined by curved structural
intended to mean "preferably, but not limited to.” Any steps members, wherein said curved structural members function
recited in any method or process claims may be executed in to increase the rate of change of an increase in compression
any order and are not limited to the order presented in the forces acting on an object as it is being wedged into said acute
claims. Means-plus-function or step-plus-function limita angle.
tions will only be employed where for a specific claim limi 10. The modular synthetic floor tile of claim 1, wherein
tation all of the following conditions are present in that limi said top surface of said structural members comprises a width
tation: a) “means for or “step for is expressly recited; and b) between 0.03 and 0.1 inches, taken along a cross-section of
a corresponding function is expressly recited. The structure, 25 said structural members.
material or acts that Support the means-plus function are 11. The modular synthetic floor tile of claim 1, wherein
expressly recited herein. Accordingly, the scope of the inven said top surface of said structural members comprises a
tion should be determined solely by the appended claims and Smooth, flat surface configuration.
their legal equivalents, rather than by the descriptions and 12. The modular synthetic floor tile of claim 1, wherein
examples given above. 30 said transition Surface comprises a curved configuration hav
ing a radius of curvature between 0.01 and 0.03 inches.
What is claimed and desired to be secured by Letters Patent 13. The modular synthetic floor tile of claim 1, wherein
1S said transition Surface comprises a linear configuration ori
1. A modular synthetic floor tile comprising: ented on an incline between 5 and 85 degrees, as measured
an upper contact surface; 35 from a horizontal axis.
a plurality of openings formed in said upper contact Sur 14. The modular synthetic floor tile of claim 1, wherein
face, each of said openings having a geometry defined said openings comprise a perimeter defined by said structural
by structural members configured to intersect with one members, and wherein said openings are sized so that said
another at various intersection points to form at least one perimeter, taken along all sides, measures between 1.5 and 3
acute angle as measured between imaginary axes 40 inches.
extending through said intersection points, said struc 15. The modular synthetic floor tile of claim 1, wherein
tural members having a smooth, planar top Surface form said openings are sized such that their width, as measured
ing said contact surface, and a face oriented transverse to from the two furthest points existing along an X-axis coordi
said top Surface; and nate, measures between 0.25 and 0.75 inches.
a transition Surface extending between said top Surface and 45 16. The modular synthetic floor tile of claim 1, wherein
said face of said structural members comprising a blunt said openings are sized Such that their length, as measured
edge between said top Surface and said face. from the two furthest points existing along a y-axis coordi
2. The modular synthetic floor tile of claim 1, wherein said nate, measures between 0.25 and 0.75 inches.
structural members are configured to form a wedge in said 17. The modular synthetic floor tile of claim 1, wherein
openings that is configured to receive and at least partially 50 said openings are sized to comprise an opening between 50
wedge a portion of an object acting on the contact Surface, and and 625 mm.
to induce a compression force on said portion of said object, 18. The modular synthetic floor tile of claim 1, further
to further increase traction about said contact Surface. comprising a perimeter defining the various sides of said floor
3. The modular synthetic floor tile of claim 1, wherein each tile, said perimeter comprising a blunt edge.
of said openings comprise a geometry further defined by 55 19. A modular synthetic floor tile comprising:
structural members configured to intersect with one another a perimeter;
at various intersection points to form at least one obtuse angle an upper contact Surface contained, at least partially, within
as measured between imaginary axes extending through said said perimeter;
intersection points. a first series of structural members extending between said
4. The modular synthetic floor tile of claim3, wherein said 60 perimeter,
obtuse angle is configured to be between 95 and 175 degrees. a second series of structural members extending between
5. The modular synthetic floor tile of claim 1, wherein said said perimeter, and intersecting said first series of struc
acute angle is configured to be between 5 and 85 degrees. tural members in a manner so as to form a plurality of
6. The modular synthetic floor tile of claim 1, wherein each openings in said upper contact Surface, each of said
of said plurality of openings individually comprise a geom 65 openings having a configuration selected from a dia
etry selected from the group consisting of a diamond configu mond geometry having at least one acute angle within
ration, a diamond configuration having curved sides, a trian the diamond geometry or a diamond geometry having
Case 2:18-cv-00778-DBP Document 2-2 Filed 10/04/18 Page 38 of 38

US 8,407,951 B2
23 24
curved sides defined by said intersection of said first and configuring said structural members to intersect one
second series of structural members; another at intersection points and to define a plurality of
wherein said first and second series of structural members openings each having at least one acute angle as mea
comprise a smooth, planar top surface, a face oriented Sured between imaginary axes extending through said
transverse to said top surface, and a transition Surface intersection points, said openings configured to receive
extending between said top surface and said face to and wedge at least a portion of an object acting on said
provide said structural members with a blunt edge con contact surface to provide increased traction about said
figured to reduce abrasiveness of said floor tile; and contact surface,
a device configured to couple said floor tile to at least one said structural members having a top Surface forming said
other floor tile. 10 contact Surface, and a face oriented transverse to said top
20. The modular synthetic floor tile of claim 19, wherein Surface; and
said openings, having said diamond geometries or said dia configuring said structural members with a transition Sur
mond geometry having curved sides, comprise opposing face extending between said top Surface and said face to
acute angles and opposing obtuse angles as formed and provide each of the openings formed by said structural
defined by said structural members configured to intersect 15 members with a blunt edge configured to reduce abra
with one another at various intersection points, said opposing siveness of said floor tile.
obtuse and acute angles being measured between imaginary 24. The method of claim 23, further comprising configur
axes extending through said intersection points. ing said structural members to define a plurality of openings
21. The modular synthetic floor tile of claim 20, wherein having a configuration selected from a diamond geometry
said acute angles are configured to receive and at least par with opposing acute angles and opposing obtuse angles as
tially wedge a portion of an object acting on said contact formed and defined by said structural members configured to
Surface, and to induce a compression force on said portion of intersect with one another at said intersection points, said
said object, to further increase traction about said contact opposing obtuse and acute angles being measured between
Surface. imaginary axes extending through said intersection points.
22. A modular synthetic floor tile comprising: 25 25. The method of claim 23, further comprising causing
an upper contact surface having a smooth, planar configu said structural members to exert a compression force on at
ration; and least a portion of an object as it is wedged into a portion of said
a plurality of diamond shaped openings formed in said opening formed on said acute angle.
contact Surface, each of said openings comprising at 26. The method of claim 23, further comprising sizing said
least two opposing acute angles, a perimeter, a face 30 openings such that their opening has an area between 50 and
extending down from said perimeter and said upper con 625 mm.
tact surface, and a blunt edge extending between said 27. The method of claim 23, wherein said top surface of
face and said perimeter and about said perimeter. said structural members comprises a width between 0.03 and
23. A method for enhancing the performance characteris 0.1 inches, taken alongacross-section of said structural mem
tics of a modular synthetic floor tile, said method comprising: 35 bers.
providing a plurality of structural members to form an
upper contact Surface;
Case 2:18-cv-00778-DBP Document 2-3 Filed 10/04/18 Page 1 of 9

EXHIBIT 3 
Case 2:18-cv-00778-DBP Document 2-3 Filed 10/04/18 Page 2 of 9
USOOD618368S

(12) Jenkins
Unitedet al.States Design Patent (10) Patent No.: US D618,368 S
(45) Date of Patent: ... *Jun. 22, 2010
(54) MODULAR SYNTHETIC FLOOR TILE (57) CLAM
(75) Inventors: Mark Jenkins, Salt Lake City, UT (US); We claim the ornamental design for a modular synthetic floor
Jeremiah Shapiro, West Valley City, UT tile, as shown and described.
(US); Cheryl Forster, Salt Lake City,
UT (US)
DESCRIPTION
(73) Assignee: Connor Sport Court International,
Inc., Salt Lake City, UT (US)
This application claims the benefit of United States patent
(*) Notice: This patent is subject to a terminal dis application Ser. No. 1 1/244,723, filed Oct. 5, 2005, and
claimer.
entitled, “Tile with Multiple-Level Surface.” is incorporated
(**) Term: 14 Years by reference in its entirety herein.
FIG. 1 illustrates a perspective view of a modular synthetic
(21) Appl. No. 29/263,675 floor tile in accordance with of the present invention, the floor
(22) Filed: Jul. 26, 2006 tile having a multiple-level Surface, and structural members
of the upper Surface and perimeter having rounded edges;
(51) LOC (9) Cl. .................................................. 25-O1 FIG. 2 illustrates a detailed perspective view of the modular
(52) U.S. Cl. ...................................... D25/156 synthetic floor tile of FIG.
(58) Field of Classification Search ................ D25/138, FIG.3 illustrates a top view of the modular synthetic floor tile
D25/152, 153,156, 155, 158; 52/375, 378, of FIG. 1;
52/434, 403.1, 179, 180, 177,799.12, 799.1,
52/31.1.1, 311.2, 311.3, 314; 428/121, 132, FIG. 4 illustrates a bottom view of the modular synthetic floor
428/133, 134, 135 tile of FIG. 1;
See application file for complete search history. FIG. 5 illustrates a first side view of the modular synthetic
(56) References Cited floor tile of FIG. 1;
U.S. PATENT DOCUMENTS FIG. 6 illustrates a second side view of the modular synthetic
floor tile of FIG. 1;
2,082.563 A 6, 1937 Bauer FIG. 7 illustrates a third side view of the modular synthetic
3,802,144. A 4/1974 Spica floor tile of FIG. 1;
3,909,996 A 10/1975 Ettlinger, Jr. et al.
4,167,599 A 9, 1979 Nissinen FIG. 8 illustrates a fourth side view of the modular synthetic
D255,744 S 7, 1980 Dekko floor tile of FIG. 1; and,
4,287,693. A 9, 1981 Collete
4,361,614 A 11/1982 Moffitt, Jr. FIG. 9 illustrates a sectional view, taken along lines 9 9 of
4,436,779 A 3, 1984 Menconi et al. FIG. 3, of the modular synthetic floor tile of FIG. 1, shown to
4,468,910 A 9, 1984 Morrison clarify the claimed design, and to illustrate the configuration
4497,858 A 2/1985 Dupont et al. of the upper Surface of the claimed design.
The broken lines shown in FIGS. 1-9 are for illustrative
(Continued) purposes only and form no part of the claimed design.
Primary Examiner Doris Clark
(74) Attorney, Agent, or Firm Thorpe North & Western LLP 1 Claim, 6 Drawing Sheets
Case 2:18-cv-00778-DBP Document 2-3 Filed 10/04/18 Page 3 of 9

US D618,368 S
Page 2

U.S. PATENT DOCUMENTS 6,047,663 A 4/2000 Moreau et al.


6,068,908 A 5, 2000 Kessler et al.
4,584.221 A 4, 1986 Kung 6,098,354 A 8, 2000 Skandis
4,590,731 A 5/1986 DeGooyer D435,122 S * 12/2000 Ross et al. ................. D25,156
4,596,729 A 6, 1986 Morrison D437.427 S * 2/2001 Shaffer ...................... D25,156
D286,575 S 11, 1986 Saunders 6,428,870 B1 8, 2002 Bohnhoff
4,728,468 A 3, 1988 Duke 6,451,400 B1* 9/2002 Brocket al. .................. 428/44
4,860,510 A 8, 1989 Kotler 6,467,224 B1 10/2002 Bertolini
D327,748 S 7/1992 Dorfman, Jr. 0,189,176 Al 12/2002 Stegner et al.
5,250,340 A 10/1993 Bohnhoff 6,751,912 B2 6/2004 Stegner et al.
5,323,575 A 6, 1994 Yeh 6,802,159 B1 * 10/2004 Kotler ..... 52/177
5,364,204 A 1 1/1994 MacLeod D522,149 S * 5/2006 Shin .......................... D25,156
D377,398 S 1/1997 Adam ....................... D25,158 7,114,298 B2 10/2006 Kotler
5,628, 160 A 5/1997 Kung 2002/007 1927 A1 6/2002 Kessler et al.
5,713, 175 A 2, 1998 Mitchell .................... 52/582.1 2005/0202208 A1 9/2005 Kelly
5,787,654 A 8, 1998 Drost 2006/0070314 A1 4/2006 Jenkins et al.
D415,581 S 10/1999 Bertolini
5.992,106 A 1 1/1999 Carling et al. * cited by examiner
Case 2:18-cv-00778-DBP Document 2-3 Filed 10/04/18 Page 4 of 9

U.S. Patent Jun. 22, 2010 Sheet 1 of 6 US D618,368 S


Case 2:18-cv-00778-DBP Document 2-3 Filed 10/04/18 Page 5 of 9

U.S. Patent Jun. 22, 2010 Sheet 2 of 6


Case 2:18-cv-00778-DBP Document 2-3 Filed 10/04/18 Page 6 of 9

U.S. Patent Jun. 22, 2010 Sheet 3 of 6 US D618,368 S

-^~
Case 2:18-cv-00778-DBP Document 2-3 Filed 10/04/18 Page 7 of 9
Case 2:18-cv-00778-DBP Document 2-3 Filed 10/04/18 Page 8 of 9

U.S. Patent Jun. 22, 2010 Sheet 5 of 6 US D618,368 S

-...-i-rf
run a it. li.-J. ItT. T. ...-ill
as M - us -a is n.. . sia . nin,
r . . r.. in . nin,. n,. in. nin..
-- -- - - - -- - - - - - - - ' a w - - - an "' u '' w a "' - no o - M

t : t : t : i
it if f_i if f__i if f_i if f_i if f_i if ...
FIG. 8
Case 2:18-cv-00778-DBP Document 2-3 Filed 10/04/18 Page 9 of 9

U.S. Patent Jun. 22, 2010 Sheet 6 of 6 US D618,368 S


Case 2:18-cv-00778-DBP Document 2-4 Filed 10/04/18 Page 1 of 6

EXHIBIT 4 
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Case 2:18-cv-00778-DBP Document 2-5 Filed 10/04/18 Page 1 of 6

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High quality basketb... Enlio outdoor P.P. int... High quality basketb... basketball court s
US $11-15 / Square ... US $9.5-13 / Square ... US $11-15 / Square ... US $18-22 / Squa
100 Square Meter/S... 100 Square Meter/S... 100 Square Meter/S... 1000 Square Mete

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https://enlio.en.alibaba.com/product/60187036207-803760695/basketball_floor_outdoor_sports_court_pp_interlocking_flooring.html?spm=a2700.icbuShop.prewdfa4c
Case 2:18-cv-00778-DBP Document 2-6 Filed 10/04/18 Page 1 of 3

EXHIBIT 6 
9/13/2018 Double la<x>yer
Case 2:18-cv-00778-DBP Document 2-6 I_Enlio
FiledSports
10/04/18 Page 2 of 3

Home   About Enlio

Badminton Table tennis Basketball Volleyball Tennis Multi-purpose Court Tiles Antislip Wet M

Double layer I |  Outdoor Kids Playground |  PFP A series |  Single Layer II |  Double layer II |  Double Layer Soft-connect
I |  Double Layer Soft-connection II |  Flat |  Single layer | 

Size: 30.1cm * 30.1cm *1.58cm(ITF Approved)

Usage: Futsal pitch Hockey Basketball Volleyball Multipurpose use

Service Life: 8 years

Order
Double
Layer I

Products Parameter Case Installation

WHY CHOOSE ENLIO?


http://www.cnenlio.com/CourtTiles/79.html 1/2
9/13/2018 Double la<x>yer
Case 2:18-cv-00778-DBP Document 2-6 I_Enlio
FiledSports
10/04/18 Page 3 of 3
Enlio provides all in one services. You can find all what you need in Enlio.

CERTIFICATION EVENT SPONSORSHIP QUALITY CONTROL IN ST

About Enilo Technology Project Gallery Customer care center


About us Characteristic
86 10 5166 0681 86 10 5166 0
Production capacity FAQs
Authenticate Authenticate
Enliosportfloors Info@enlio.c
Event Sponsorship Maintenance
Technology

Copyright(c) 2015 Shijiazhuang Enlio Sports Goods Co., Ltd. All reversed Design by [Donrry.com]

http://www.cnenlio.com/CourtTiles/79.html 2/2
Case 2:18-cv-00778-DBP Document 2-7 Filed 10/04/18 Page 1 of 3

EXHIBIT 7 
9/13/2018 Case 2:18-cv-00778-DBP Double Layer Soft-connection
Document 2-7 Filed II_Enlio Sports
10/04/18 Page 2 of 3

Home   About Enlio

Badminton Table tennis Basketball Volleyball Tennis Multi-purpose Court Tiles Antislip Wet M

Double Layer Soft-connection II |  Outdoor Kids Playground |  PFP A series |  Single Layer II |  Double layer I |  Double la
II |  Double Layer Soft-connection I |  Flat |  Single layer | 

Size: 34cm * 34cm *1.58cm

Usage: Futsal pitch Hockey Basketball Volleyball Multipurpose use

Service Life: 8 years

Order
Double
Layer
Soft-
connectio
II

Products Parameter Case Installation

http://www.cnenlio.com/CourtTiles/76.html 1/2
9/13/2018 Case 2:18-cv-00778-DBP Double Layer Soft-connection
Document 2-7 Filed II_Enlio Sports
10/04/18 Page 3 of 3

WHY CHOOSE ENLIO?


Enlio provides all in one services. You can find all what you need in Enlio.

CERTIFICATION EVENT SPONSORSHIP QUALITY CONTROL IN ST

About Enilo Technology Project Gallery Customer care center


About us Characteristic
86 10 5166 0681 86 10 5166 0
Production capacity FAQs
Authenticate Authenticate
Enliosportfloors Info@enlio.c
Event Sponsorship Maintenance
Technology

Copyright(c) 2015 Shijiazhuang Enlio Sports Goods Co., Ltd. All reversed Design by [Donrry.com]

http://www.cnenlio.com/CourtTiles/76.html 2/2
Case 2:18-cv-00778-DBP Document 2-8 Filed 10/04/18 Page 1 of 3

EXHIBIT 8 
Case 2:18-cv-00778-DBP Document 2-8 Filed 10/04/18 Page 2 of 3
Case 2:18-cv-00778-DBP Document 2-8 Filed 10/04/18 Page 3 of 3

HOMOLOGATION EQUIPMENT LIST


FIVB APPROVED FIVB Inspected VOLLEY- FIVB RECOMMENDED
VOLLEYBALL BALLS BALL BALLS SYNTHETIC SPORTS
FLOORS
MIKASA MIKASA - SV-2 School Volley
MVA 200
MIKASA - SV-3 School Volley GERFLOR TARAFLEX Sport M Perfor-
mance
MOLTEN
V5 M5000 MIKASA - SKV5 Kids Volleyball
GERFLOR TARAFLEX® Sport Evolution
GALA A.S. TARAFLEX® Sport M Comfort
BV 5591S FIVB APPROVED
SYNSHEEN & CO., LTD
POSTS, PADS, ANTENNAE, TARAFLEX® MULTI-USE 6.2: CLASS P1
Star Grand Champion VB 225-34 NETS, REFEREES’ CHAIRS TARAFLEX® Surface on a wooden sub-
floor
CAMBUCI SA Brazil
Penalty Pro 7.0 SENOH CORPORATION
CONNOR SPORTS COURTS
JINLING SPORTS EQUIPMENT CO., LTD Inddor Sport Court Response
MIKASA Outdoor: Sport Court PowerGame
MVA 300
JIANGSU QIANGHUAI SPORTING
GOODS CO. ENLIO SPORT COURT INTERNATIONAL
DECATHLON PVC Sports Flooring 7 mm
ALLSIX V900
MIKASA

FIVB APPROVED NATIONAL FEDERATIONS ARE


BEACH VOLLEYBALL BALLS REQUESTED TO SELECT MATERIAL
FROM THE LIST OF THE FIVB APPROVED
SPORTS MATERIAL As of June 6
MIKASA
VLS 300

MOLTEN
BV5000

DECATHLON
KIPSTA BV900
Case 2:18-cv-00778-DBP Document 2-9 Filed 10/04/18 Page 1 of 2
JS 44 (Rev. 06/17) 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


Connor Sport Court International, LLC Shijiazhuang Enlio Sports Good Co., Ltd.

(b) County of Residence of First Listed Plaintiff Salt Lake County of Residence of First Listed Defendant Hebei Province, China
(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.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Peter M. de Jonge Thorpe North Western, LLP (T) 801 566-6633
Jed H. Hansen 175 S. Main St., Suite 900
Kurtis M. Hendricks Salt Lake City, UT 84111

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 1 U.S. Government ’ 3 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 ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

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


Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 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 ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated ’ 460 Deportation
Student Loans ’ 340 Marine Injury Product New Drug Application ’ 470 Racketeer Influenced and
(Excludes Veterans) ’ 345 Marine Product Liability ’ 840 Trademark Corrupt Organizations
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ’ 480 Consumer Credit
of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 490 Cable/Sat TV
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) ’ 850 Securities/Commodities/
’ 190 Other Contract Product Liability ’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) Exchange
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 890 Other Statutory Actions
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 891 Agricultural Acts
’ 362 Personal Injury - Product Liability ’ 751 Family and Medical ’ 893 Environmental Matters
Medical Malpractice Leave Act ’ 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 790 Other Labor Litigation FEDERAL TAX SUITS Act
’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: ’ 791 Employee Retirement ’ 870 Taxes (U.S. Plaintiff ’ 896 Arbitration
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee Income Security Act or Defendant) ’ 899 Administrative Procedure
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third 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: ’ 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)
’ 1 Original ’ 2 Removed from ’ 3 Remanded from ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict ’ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. §§ 1 et seq.
VI. CAUSE OF ACTION Brief description of cause:
Patent infringement
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: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
10/04/2018 /s/ Peter M. de Jonge
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Print Save As... Reset


JS 44 Reverse (Rev. 06/17) Case 2:18-cv-00778-DBP Document 2-9 Filed 10/04/18 Page 2 of 2
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 purpose 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 there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.

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.

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