Varidesk v. Qidong Vision Mounts - Complaint

Case 3:18-cv-03263-B Document 1 Filed 12/12/18 Page 1 of 13 PageID 1
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
VARIDESK LLC, §
§
Plaintiff, §
§ CIVIL ACTION NO. __________
v. §
§ COMPLAINT FOR PATENT
QIDONG VISION MOUNTS § INFRINGEMENT
MANUFACTURING CO., LTD., §
NANTONG JON ERGONOMIC § JURY TRIAL DEMANDED
OFFICE CO., LTD., HANGZHOU §
GRANDIX ELECTRONICS CO., §
LTD., AND HANGZHOU KEXIANG §
TECHNOLOGY CO., LTD., §
§
Defendants. §
§
Plaintiff Varidesk LLC (“Varidesk”) files this complaint for utility and design patent
infringement against Qidong Vision Mounts Manufacturing Co., Ltd. (hereinafter “Vision
Mounts”), Nantong Jon Ergonomic Office Co., Ltd. (“Nantong Jon”), Hangzhou Grandix
Electronics Co., Ltd. (“Grandix”), and Hangzhou Kexiang Technology Co., Ltd. (“Kexiang”),
collectively “Defendants,” alleging on its own knowledge and on information and belief as
follows:
PARTIES
1. Varidesk is a Texas limited liability corporation having its headquarters at 1221
South Belt Line Road #500, Coppell, Texas 75019. Varidesk is a pioneer and leader in the field
of height-adjustable desk technology.
21809883-v1
2. Upon information and belief, Vision Mounts is a company organized under the
laws of the People’s Republic of China, with its principal place of business at No. 899 Lingfeng
Road, HaiHong Industry Park, Qidong, Jiangsu, China 226220.
3. Upon information and belief, Nantong Jon is a company organized under the laws
of the People’s Republic of China, with its principal place of business at Building D, Jingyang
Square, Chongchuan District, Nantong City, Jiangsu Province, China 226001.
4. Upon information and belief, Grandix is a company organized under the laws of
the People’s Republic of China, with its principal place of business and headquarters at 1-1804,
New Youth Plaza, Gongshu District, Hangzhou, Zhejian, China.
5. Upon information and belief, Kexiang is a company organized under the laws of
the People’s Republic of China, with its principal place of business and headquarters at Binjiang
Qu Changhe Jeidao Binhe Lu 1174, Hangzhou, China 310052.
JURISDICTION AND VENUE
6. This is an action for patent infringement arising under the patent laws of the
United States, Title 35 of the United States Code § 1, et seq.
7. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
§§ 1331 and 1338(a).
8. Defendants are subject to this Court’s specific and general personal jurisdiction
under due process and/or the Texas Long Arm Statute due at least to Defendants’ substantial
business in this forum, including: (i) at least a portion of the infringements alleged herein; and
(ii) regularly doing or soliciting business, engaging in other persistent courses of conduct, and/or
deriving substantial revenue from goods and services provided to individuals in Texas and in this
District.
2

9. Venue is appropriate in this District pursuant to 28 U.S.C. §§ 1391(b) and (c),
and/or 28 U.S.C. § 1400(b). Upon information and belief, Defendants have transacted business
in this District and have committed acts of patent infringement in this District.
VARIDESK’S PATENTS
10. Varidesk’s claims are based on Defendants’ unlawful and unauthorized direct and
indirect infringement of the following utility and design patents for height-adjustable desk
platforms and components thereof: U.S. Patent No. 9,113,703 (“the ’703 Patent”), U.S. Patent
No. 9,277,809 (“the ’809 Patent”), U.S. Patent No. 9,554,644 (“the ’644 Patent”), U.S. Patent
No. 9,924,793 (“the ’793 Patent”), and U.S. Patent No. D832,623 (“the ’623 Patent”),
collectively the “Asserted Patents.” Copies of the Asserted Patents are attached hereto as
Exhibits 1, 2, 3, 4 and 5.
11. Varidesk is the owner by assignment of the entire right, title, and interest to the
Asserted Patents, including the sole and exclusive right to prosecute this action, enforce the
Asserted Patents against infringers, and to collect damages on the Asserted Patents for all
relevant times.
DEFENDANTS’ INFRINGING ACTIVITIES
12. Upon information and belief, Defendants develop, manufacture, and/or sell
height-adjustable desk platforms and components thereof, which are sold in competition with
Plaintiff Varidesk.
13. Upon information and belief, Defendants have made, used, sold, offered for sale,
and/or imported into the United States at least the following models of infringing height-
adjustable desk platforms reflected in Defendant Vision Mounts’ product catalog: VM-LD02,
VM-LD04, VM-LD07, VM-SD07, VM-SD08, VM-LD08, and all sub-models thereof
3

(collectively, the “Accused Products”). An excerpt from Defendant Vision Mounts’ catalog
showing the Accused Products is attached as Exhibit 6.
14. Upon information and belief, either directly or through distributors and resellers,
Defendants make, use, offer to sell, sell, and/or import some or all of the Accused Products in the
United States.
15. In addition, upon information and belief, either directly or through distributors
and resellers, Defendants knowingly and intentionally make, use, offer to sell, and sell some or
all of the Accused Products to others for importation into the United States.
16. The Accused Products are sold within the United States under various brand
names, including Fezibo, Vivo, Songmics, Voyadesk, and SITA-Office.
17. Defendants offer their products for sale in the United States through websites
directed to U.S. consumers and at exhibitions in the United States. For example, Defendants
Vision Mounts, Nantong Jon, and Grandix market and sell their products through alibaba.com,
where they list the prices of the Accused Products in U.S. dollars and offer “Ocean Shipping
Service from China to U.S.” See Exhibits 7, 8, 9. Defendant Kexiang offers its products for sale
to U.S. consumers on Amazon.com. See Exhibit 10. In addition, certain Defendants, including
Defendant Vision Mounts, exhibit their products at trade shows in the United States, including
the CES Conference in Las Vegas, where upon information and belief Defendant Vision Mounts
plans to market and exhibit Accused Products in January 2019. See Exhibit 11. Defendant
Vision Mounts also touts on its website (www.v-mounts.com) that its products are “widely
exported” to the United States and lists North America as a “major market[ ]served” by
Defendant.
4

18. The Accused Products are currently the subject of an Investigation commenced by
the U.S. International Trade Commission (“ITC”) into violations of Section 337 of the Tariff Act
of 1930, as amended, 19 U.S.C. § 1337 (“ITC Investigation”), for infringement of the utility
patents asserted herein. (The design patent asserted herein, the ’623 Patent, is not asserted in or
otherwise part of the ITC Investigation.) The ITC’s Notice of Institution of Investigation is
attached hereto as Exhibit 12. The Defendants are named Respondents in the ITC Investigation.
19. The Defendants have had notice of Varidesk’s patent rights since at least the time
they learned of Varidesk’s ITC complaint, filed on June 22, 2018, yet continue to infringe
Varidesk’s patent rights through their continued sale, offer for sale, and importation of the
Accused Products.
20. Defendants’ conduct alleged herein constitutes knowing and intentional direct and
indirect infringement of the Asserted Patents.
COUNT I – INFRINGEMENT OF THE ’703 PATENT
21. Varidesk restates and incorporates by reference the paragraphs above as if stated
fully herein.
22. Upon information and belief, in violation of 35 U.S.C. § 271(a), Defendants have,
literally and under the doctrine of equivalents, directly infringed the ’703 Patent by, among other
things, making, using, offering for sale, and/or selling the Accused Products, and will continue to
do so unless such infringing activities are enjoined by this Court. A sample claim chart showing
infringement of the ’703 Patent by an Accused Product is attached as Exhibit 13.
23. Upon information and belief, in violation of 35 U.S.C. § 271(b), Defendants have
actively induced infringement of the ’703 Patent by knowingly and specifically intending that
5

others directly infringe the ’703 Patent, including by encouraging others to purchase the Accused
Products for importation and sale in the United States.
24. Varidesk has suffered, and continues to suffer, damages and irreparable harm as a
result of Defendants’ past and ongoing infringement.
25. Unless Defendants’ infringement is enjoined, Varidesk will continue to be
damaged and irreparably harmed.
26. Varidesk meets the criteria for, and is entitled to, a permanent injunction.
27. Defendants had knowledge of the ’703 Patent at least as of the date they were
notified of Varidesk’s complaint leading to the ITC Investigation.
28. Upon information and belief, Defendants’ ongoing infringement of the ’703
Patent has been willful and deliberate, making this an exceptional case and entitling Varidesk to
recover enhanced damages and attorneys’ fees pursuant to 35 U.S.C. §§ 284, 285.
COUNT II – INFRINGEMENT OF THE ’809 PATENT
fully herein.
6

COUNT III – INFRINGEMENT OF THE ’644 PATENT
fully herein.
7

COUNT IV – INFRINGEMENT OF THE ’793 PATENT
fully herein.
8

COUNT V – INFRINGEMENT OF THE ’623 PATENT
fully herein.
54. Upon information and belief, in violation of 35 U.S.C. § 271(a), Defendants have
directly infringed the ’623 Patent by, among other things, making, using, offering for sale, and/or
selling an Accused Product, model VM-LD02T (pictured below), that embodies, or is a colorable
imitation of, the innovative ornamental design covered by the ’623 Patent. In the eye of an
ordinary observer, the design of the Accused Product and the patented design are substantially
the same by comparison to the prior art as can be seen by a side-by-side comparison of the
Accused Product and patented design:
9

’623 Patent Accused Product (VM-LD02T)
result of Defendants’ past and ongoing infringement. Varidesk is entitled to all available
remedies, including Defendants’ total profits pursuant to 35 U.S.C. § 289.
10

59. Defendants had knowledge of the ’623 Patent at least as of the date they learned
of this complaint.
JURY DEMAND
Varidesk hereby requests a trial by jury on all issues so triable.
PRAYER FOR RELIEF
Varidesk requests that the Court find in its favor and against Defendants and grant
Varidesk the following relief:
a. Judgment be entered that Defendants have infringed one or more claims of the
Asserted Patents, literally and/or under the doctrine of equivalents;
b. Judgment be entered that Defendants’ infringement of the Asserted Patents was
willful;
c. An accounting be had for the damages resulting from Defendants’ infringement of
the Asserted Patents, including, without limitation, lost profits caused by Defendants’ infringing
activities and/or a reasonable royalty for the infringement pursuant to 35 U.S.C. §§ 284, 289, and
that the damages so ascertained be trebled pursuant to 35 U.S.C. § 284 and awarded together
with interests and costs;
d. An injunction be issued, restraining and enjoining Defendants and their respective
officers, directors, agents, servants, affiliates, employees, divisions, branches, subsidiaries,
parents, and all others acting in privity or in concert with them, from engaging in the commercial
11

manufacture, use, offer for sale, or sale within the United States, or importation into the United
States, of products infringing the Asserted Patents;
e. Judgment be entered that this is an exceptional case, and that Varidesk is entitled
to its reasonable attorneys’ fees and costs in accordance with 35 U.S.C. § 285; and
f. The Court award such other and further relief as the Court may deem just and
proper under the circumstances.
12

Dated: December 12, 2018 Respectfully submitted,
By: /s/_Michael C. Smith________.

Michael C. Smith
State Bar No. 18650410
Siebman, Forrest, Burg & Smith, LLP
113 E Austin
Marshall, Texas 75671
Telephone: (903) 938-8900
michaelsmith@siebman.com
Adam R. Hess
ARHess@venable.com
Andrew F. Pratt
AFPratt@venable.com
Martin L. Saad
MLSaad@venable.com
Tamatane J. Aga
TJAga@venable.com
VENABLE LLP
600 Massachusetts Avenue, NW
Washington, D.C. 20001
Telephone: (202) 344-4389
Facsimile: (202) 344-8300
Alper T. Ertas
ATErtas@venable.com
VENABLE LLP
101 California Street, Suite 3800
San Francisco, CA 94111
Telephone: (415) 343-3214
Facsimile: (415) 653-3755
Counsel for Plaintiff Varidesk LLC
13

Case 3:18-cv-03263-B Document 1-1 Filed 12/12/18 Page 1 of 25 PageID 14
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UNITED STATES DEPARTMENT OF COMMERCE
United States Patent and Trademark Office
MayO82018
THIS TO CERTIFY THAT ANNEXED HERETO

IS IS TRUE COPY FROM
THE RECORDS OF THIS OFFICE OF
U.S PATENT 9924793

ISSUE DATE March 27 2018
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and Director of the United State aent and Trademark Office
SWAIN/
Certifyin Officer
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12 United States Patent 10 Patent No US 9924793 B2

Flaherty et al 45 Date of Patent Mar 27 2018
54 ADJUSTABLE DESK PLATFORM 56 References Cited
71 Applicant Varidesk LLC Coppell TX US U.S PATENT DOCUMENTS
72 Inventors Daniel Flaherty Irving TX US 210031 11/1878 Hawthorn

David Patton Flower Mound 226053 3/1880 Finnegan A47B 21/0314
US Sheng Wang Taichung TW

108/138
Continued
73 Assignee Varidesk LLC Coppell TX US
FOREIGN PATENT DOCUMENTS
Notice Subject to any disclaimer the term of this
extended
AU 2014216002 Al 3/2015
patent is or adjusted under 35
CN 1231146 10/1999
U.S.C 154b by days
Continued
This patent is subject to terminal dis
claimer
OTHER PUBLICATIONS
21 Appl No 15/378736 Petition for Post Grant Review of Claims 21-23 25 and 33-36 of
TJ.S Pat No 9554644 under 35 U.S.C 321-28 and 37

22 Filed Dec 14 2016
C.F.R 42.200 Et Seq
65 Prior Publication Data Continued
US 2017/0095072 Al Apr 2017 Primary ExaminerJose Chen
Related U.S Application Data 74 Attorney Agent or Firm Venable LLP Steven
Schwarz
63 Continuation of application No 15/014730 filed on
Feb 2016 now Pat No 9554644 which is
57 ABSTRACT
Continued
An adjustable desk platform can include an upper platform
work surface base
51 list Cl defining substantially planar located
A47B 11/00 beneath the upper platform the base bottom

2006.01 defining
A47B 9/16 2006.01 surface without legs that is adapted to sit on an existing desk
first and second sets of arms coupling the platform to
Continued upper
the base wherein the first and second sets of arms are
52 U.S Cl
for movement of the upper platform
CPC adapted substantially in
A47B 9/16 2013.01 A47B 9/00
parallel with the base between fully raised position and
2013.01 A47B 9/18 2013.01 A47B 21/00
fully lowered position and user-operable locking mecha
2013.01
nism associated with the mecha
upper platform the locking
Continued nism adapted to releasably lock the upper platform in the
58 Field of Classification Search
fully raised position and in at least one intermediate position
CPC A47B A47B 21/03 14 A47B 21/00
1/03 between the raised
fully position and the fully lowered
A47B 21/02 A47B 21/03 A47B Other features and embodiments
position are discussed
2021/0321 A47B 2021/0364 A47B 9/16
Continued 50 Claims 24 Drawing Sheets
10
30
21
21 30-_3 71
70
32
23
Copy provided by USPTO from the PIRS Image Database on 05-08-2018

US 9924793 B2
Page
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U.S Patent Mar 27 2018 Sheet of 24 US 9924793 B2
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US 9924793 B2
ADJUSTABLE DESK PLATFORM planar work surface base located beneath the upper
the base bottom surface without
platform defining legs
CROSS .REFERENCE TO RELATED that is adapted to sit on an desk first and second sets
existing
APPLICATIONS of arms coupling the upper platform to the base wherein the
first and second sets of arms are adapted for movement of

This application is continuation of applicant co
the in with the base
pending U.S application Ser 15/014730 filed Feb No upper platform substantially parallel
between fully raised position and lowered position

2016 which is continuation of applicants co-pending U.S fully
application Ser No 14/714682 filed May 18 2015 U.S and user-operable locking mechanism associated with the
Pat No 9277809 which is

continuation-in-part of upper platform the locking mechanism adapted to releas
10
applicants U.S application Ser 14/183052 No filed on ably lock the upper platform in the fully raised position and
Feb 18 2014 U.S Pat No 9055810 which is con- in at least one intermediate position between the fully raised
tinuation-in-part of applicants U.S application Ser No position and the fully lowered position
14/013285 U.S Pat No 9113703 filed on Aug 29 to another embodiment the desk
According adjustable
2013 which is
continuation-in-part of applicants U.S
platform can include an upper platform defining substan
application Ser No 13/642 651 U.S Pat No
671 853 15
tially planar work surface base located beneath the upper

filed on Oct 22 2012 which in turn is the national stage of
the base bottom surface without
International Application No PCT/US2012/48775 filed on platform defining legs
Jul that is adapted to sit on an existing desk and first and second
30 2012 which in turn claims the priority of U.S
Provisional Application No 61/651101 filed on May 24 sets of arms coupling the upper platform to the base wherein
2012 The entire contents of the foregoing applications are 20 the first and second sets of arms are adapted for movement
incorporated herein by reference of the upper platform substantially in parallel with the base
between fully raised position and fully lowered position
TECHNICAL FIELD wherein the moves with to
upper platform laterally respect
the base when moved from the fully lowered position to the
This application relates generally to ergonomic workplace 25 raised position and the base includes
fully counterweight
environments and more particularly to an adjustable desk
adapted to offset weight of the upper platform when in the
platform or desk
raised position
another the
BACKGROUND According to embodiment adjustable desk
platform can include an upper platform defining substan
for of time during the work day 30 tially planar work surface base located beneath the upper
Sitting long periods is
not ones and wellness Medical platform the base defining bottom surface without legs
generally good for health
studies show that sitting increases the rate of all-cause that is adapted to sit on an existing desk first and second sets
mortality especially from cardiovascular disease diabetes of arms coupling the upper platform to the base wherein the
and obesity for example People who sit for most of the day first and second sets of arms are adapted for movement of
are 50 percent more likely to die of heart attacks Even if
you
35 the upper platform substantially in parallel with the base
exercise the longer you sit the greater the chances you will between fully raised position and fully lowered position
die Sitting shuts down the circulation of the fat-absorbing and biasing mechanism associated with at least one of the
enzyme lipase while standing up engages muscles and first and second sets of arms wherein moving the upper
promotes the distribution of lipase which prompts the body platform toward the fully raised position loads the biasing
to process fat and cholesterol independent of the amount of 40 mechanism
time spent exercising According to another embodiment the adjustable desk
There are desks available to be used while standing and platform can include an upper platform defining substan
even desks adapted for use while user is on treadmill tially planar work surface the upper platform having first
However standing for very long periods of time to work is and second hand apertures extending therethrough base
more tiring dramatically increases the risks of carotid 45 located beneath the upper platform the base defining
atherosclerosis because of the additional load on the circu- bottom surface without legs that is adapted to sit on an
latory system and increases the risks of varicose veins existing desk first and second sets of arms coupling the
Taking regular breaks from sitting for prolonged periods upper platform to the base wherein the first and second sets
of time can have several positive outcomes For example of arms are adapted for movement of the upper platform
standing can provide more energy during the work day In 50 substantially in parallel with the base between fully raised
addition because standing burns more calories than sitting position and fully lowered position and first and second
standing can also result in weight loss without changes in user-operable locking mechanisms associated with the upper
diet or exercise It is also harder to become more tired or lose platform each of the first and second locking mechanisms
focus when to lock the
standing adapted releasably upper platform in the fully
Because regular breaks from sitting are beneficial and 55 raised position wherein the first and second locking mecha
because many people during the work day want to remain nism each include user operable handle mounted to an
productive while taking breaks from sitting and because underside of the upper platform substantially adjacent to one
everyone will sit and stand for different lengths of time at of the hand apertures
different times during the day there exists need to create Other features and advantages will become apparent from
work environment that is ergonomic for someone standing 60 the following description taken in connection with the
as well as sitting and allows the transition to be easy quick accompanying drawings wherein by way of illustration and
and simple example embodiments of the invention are disclosed
SUMMARY BRIEF DESCRIPTION OF THE DRAWINGS

65
According to embodiments an adjustable desk platform The features and advantages of the invention will be
can include an upper platform defining substantially apparent from the following description as illustrated in the

US 9924793 B2
accompanying drawings wherein like reference numbers FIG 26 is similar to FIG 25 but shows the users hands
generally indicate identical functionally similar and/or moving the locking mechanism
structurally similar elements
FIG is perspective view of an embodiment of an DETAILED DESCRIPTION
adjustable desk platform

FIG is another perspective view of the adjustable desk Embodiments of the invention are discussed in detail
platform of FIG below In describing embodiments specific terminology is
of for the of
FIG is side view the adjustable desk platform of employed sake clarity However the invention is
FIG not intended to be limited to the specific terminology so

10
FIG is front view of the adjustable desk of selected While specific embodiments are discussed it
platform
FIG should be understood that this is done for illustration pur
FIG is perspective view of parts of an embodiment of poses only person skilled in the relevant art will recognize
locking mechanism of the desk of FIG that other components and configurations can be used with-
adjustable platform
out departing from the spirit and scope of the invention
FIG is an exploded view of the locking mechanism of Embodiments of the adjustable desk platform described
FIG herein can transition between lower operating position and
FIG is perspective view of an embodiment of an upper operating position quickly easily and simply This
biasing mechanism of the adjustable desk platfonn of FIG may be useful for example to provide height adjustability
to conventional fixed desktop workspaces

20 Alternatively
FIG is side view of an embodiment of the embodiments of the adjustable desk platform can include
locking
mechanism of the adjustable desk platform of FIG their own support legs
showing the handle in the locked position Referring to FIGS ito the adjustable desk platform can
FIG is side view of the locking mechanism of FIG generally include an upper platform 10 lower platform 20
handle in theun-locked position and and
showing the 25 left right pivot arm 30 which can connect
sets the
FIG 10 is side view of the adjustable desk platform of upper platform 10 and lower platform 20 According to
FIG showing an example of directional movement of the embodiments the upper platform 10 and/or the lower plat
upper platform relative to the lower platform and the pivot form 20 can include substantially planar top surface that
arms can serve as working surface for the user for example to
FIG 11 is side view of an embodiment of the biasing 30 support reading materials papers computers other elec
mechanism tronic devices and the like The adjustable desk platform
FIG 12 is perspective view of an embodiment of the can include one or more locking mechanisms 40 for
adjustable desk platform showing the tray example one associated with each of the left and right pivot
FIG 13 is bottom view of an embodiment of the arm sets 30 The adjustable desk platform can also include
adjustable desk platform showing the tray and counter 35 one or more biasing mechanisms 50 see FIG for
weights example each associated with the left and right pivot arm
FIG 14 is
perspective view of an embodiment of the sets 30 The adjustable desk platform can also include
adjustable desk platform including keyboard tray reinforcement member 60 visible in FIGS and
FIG 15 is an enlarged perspective view of the pivot arms Referring to FIG and FIGS to lower mounting
of an embodiment of the adjustable desk platform 40 brackets ii can be located on upper platform 10 for
FIG 16 is
perspective view of an embodiment of the example secured thereto or formed integrally therewith As
adjustable desk platform including legs shown in the figures two lower mounting brackets 11 can be
FIG 17 is partially exploded perspective view of the secured to the underside of the upper platform 10 at opposite
adjustable desk platform with legs of FIG 16 sides of the upper platform 10 As shown in FIG to FIG
FIG 18 is view of another embodiment of 45 lower 20 located below the 10
perspective platform is
upper platform
the adjustable desk platform shown in frilly lowered and the pivot arm sets selectively adjust the height of the
position upper platform 10 with respect the lower platform 20 for
FIG 19 is perspective view of the adjustable desk example with the upper platform 10 and the lower platform
platformof FIG 18 shown in fully raised position 20 remaining substantially parallel to one another during
FIG 20 is side view of the adjustable desk platform of 50 movement
FIG 18 shown in the fully lowered position Lower platform 20 can include two upper mounting
FIG 21 is side view of the adjustable desk platform of brackets 21 for example one located near each side of the
FIG 18 shown in the fully raised position lower platform 20 The can be
upper mounting brackets
FIG 22 is partially-exploded perspective view of formed integrally with the lower platform 20 or altema
another embodiment of the adjustable desk platform shown 55 tively can be secured thereto using fasteners or other means
in partially raised position known Lower platform 20 can also include one or
in the art
FIG 23 is
partially-exploded side view of the adjust- more counter weights 22 and housing 23 near each upper
able desk platform of FIG 22 shown in the partially raised mounting bracket 21
Referring to FIGS
position and the upper mounting brackets
FIG 24 is partially-exploded rear view of the adjustable 60 21 can be located on the top surface of the lower platform
desk platform of FIG 22 shown in the partially raised 20 for example at opposite sides thereof and the lower
position mounting brackets 11 can be located on the bottom surface
FIG 25 is side view of another embodiment of the of the upper platform 10 for example in registry with the
adjustable desk platform as seen from user standing behind upper mounting brackets 21 Each upper mounting bracket
the desk platform with the desk in partially raised position 65 21 can include an arc slot 211 shown in FIGS and One
The users hands are shown resting on the locking mecha- of the housings 23 can be located adjacent the outer side of
nism each of the upper mounting brackets 21 As shown in FIG

US 9924793 B2
one or more counter weights 22 can be located on the booster spring 53 and pivot point 54 One side of spring
bottom surface of lower platform 20 51 can be connected with the 52 and the other side
support
As shown in FIGS and each arm set 30 can form with the arm
pivot is pivot joint secondary 32 for
connected to the respective lower mounting bracket 11 on example by attaching to the boss 321 Each support 52 and
the 10 and to the booster 53 of biasing mechanism 50 can be connected
upper platform respective upper mounting spring
bracket 21 on the lower platform 20 As shown each pivot with lower platform 20 Arc slot 211 can be selectively
arm set 30 can include main pivot arm 31 and secondary connected with the respective arm 32 on the
secondary pivot
pivot arm 32 The pivot arms 31 32 can be pivotably other side of the respective upper mounting bracket 21 Pivot
connected to the lower mounting bracket 11 at one end and point 54 can be located against the bottom side of booster
to upper mounting bracket 21 at the other end using for 10 spring 53 Each biasing mechanism 50 can be located
example rivets fasteners or other structures known in the between the respective bracket 21 and
upper mounting
art The main pivot arm 31 and secondary pivot arm 32 can housing 23 thereby concealing the biasing mechanism 50
be connected to the lower mounting bracket 11 and upper As shown in FIG reinforcement member 60 may
mounting bracket 21 at different locations as shown in the extend between the left and right pivot arm sets 30 Accord-
figures The pivot arm sets 30 can be connected to the upper 15 ing to embodiment reinforcement member may include
an
mounting bracket 21 the side of the supporting rod 61 and separate reinforcement 62 how-
at opposite respective
housing 23 For example the pivot arm sets 30 can connect ever other single-member and multi-member embodiments
to the interior side of the
upper mounting brackets 21 while are possible According to an embodiment rod
supporting
the housings 23 can connect to the exterior sides of the upper 61 can be connected with the primary pivot ann 31 of each
mounting brackets 21 20 pivot arm set 30 and reinforcement 62 can be connected

Referring to FIGS and the upper end of each primary with the secondary pivot arm 32 of each pivot arm set 30
pivot arm 31 can include locking part 311 including According to embodiments the reinforcement member can
plurality of perforations 3111 The plurality of perforations fix the side-to-side distance between the pivot arms and add
3111 can include at least one perforation that is
selectively stability avoiding side-to-side movement when or
lifting
movable into alignment with hole iii in the 25 lowering upper platform 10 from lower
respective platform 20 and can
lower mounting bracket 11 Referring to FIGS and each make the adjustable platform smoothly
operate
secondary pivot arm 32 can include boss 321 that slides When in use the user can place the adjustable desk
within the arc slot 211 of the upper mounting platform on to desktop and items on
respective may place the upper
bracket 21 platform 10 as desired such as without corn-
limitation
Referring to FIGS and one or more locking sets 30 puter documents desk lamps instruments and supplies
40 can be located on the bottom of the upper platform 10 The user can adjust the height between the 10
upper platform
For example each locking set 40 can be fixed on the and the lower platform 20 according to their working
respective lower mounting bracket 11 however other loca- and/or other needs
posture
tions are possible Referring to FIG each locking set 42 FIG depicts the adjustable desk platform in fully
can include anchors 41 Each anchor 41 can selectively 35 raised position Referring to FIGS 8-10 and 12 in order
engage one of the perforations 3111 of locking part 311 and to lower the adjustable desk platform the user can pull
can also hole of lower mounting handle which
engage through the 111 42 in turn displaces the first linkage 431
bracket 11 thereby fixing the main pivot arm 31 in position second linkage 432 and third linkage 433 This can in turn
with respect to the respective lower mounting bracket 11 retract the anchor 41 and cause the anchor to withdrawal
Furthermore as shown in FIGS and each locking set 40 40 from the perforations 3111 of the primary arm 31 As
pivot
can include handle 42 and linkage mechanism 43 result the arm 31 is released from
pivot substantially
Referring to FIGS and each linkage set 43 can fixed position allowing primary pivot arm 31 and secondary
include first linkage 431 second linkage 432 and third pivot arm 32 to move consequently allowing the upper
linkage 433 which according to an embodiment are piv- platform 10 to move with respect to the lower platform 20
otably connected to one another in sequence Each first 45 Accordingly the distance between 10 and
upper platform
linkage 431 can be located underneath the bottom of the lower platform 20 can be reduced for example to the fully
upper platform 10 and can have pivot joint with handle 42 lowered position shown in FIG 11 or to some position
Each third linkage 433 can be connected with the respective between the fully raised position and the lowered
fully
anchor 41 for example by rivets pins or other structures position This allows the distance between the upper plat
extending through the third linkage 433 and anchors 41 as 50 form 10 and lower platform 20 to be easily set and adjusted
shown in FIGS and 10 Each locking set 40 can contain As shown In FIGS and 8-11 when the user moves the
spring 44 adapting piece 45 and housing 46 Each platform 10 and lower platform 20 to desired height
upper
piece 45 of set 40 can be secured on the relative to each other the can
adapting locking user release the handles of
bottom of upper platform 10 and can include pivot joint locking sets 40 As result the retraction force of springs
with second linkage 432 One end of spring 44 can be 55 44 of each locking set 40 can move the second 432
linkage
connected with adapting piece 45 and the other end of spring causing first linkage 431 and third linkage 433 to move
44 can be connected with second linkage 432 in proximity sequentially anchors 41 to lock through the
thereby causing
to the first linkage 431 Each locking set 40 can include hole 111 of the lower mounting bracket and the correspond-
housing 46 that can cover at least the second linkage 432 ing perforations 3111 on primary pivot arm 31 This in turn
third linkage 433 spring 44 adapting piece 45 and anchor 60 locks the position of the upper platform 10 relative to the
41 The housing 46 can be connected to the underside of the lower platform 20
upper platform 10 As shown in FIGS 10 and 11 as the primary and
As shown in FIGS and each biasing mechanism 50 secondary pivot arms 31 32 pivot with to the
respect
can be located on lower platform 20 and can be connected respective upper mounting bracket 21 the boss 321 slides
with pivot arm sets 30 to assist the upper platform 10 in 65 within arc slot 211 of the upper mounting bracket 21 and
raising/lowering with respect to the lower platform 20 Each accordingly stretches or relaxes the compression spring 51
biasing mechanism 50 can include spring 51 support 52 of the corresponding biasing mechanism 50 to
Referring

US 9924793 B2
FIG 11 since pivot point 54 leans against the bottom side tively the joint components 72 can be drilled in the housing
of booster spring 53 when upper platform 10 and lower 23 of lower platform 20 The joint components are not
platform 20 are moved toward the fully lowered position limited to the embodiments shown and other connectors
boss 321 can press laterally against the booster springs 53 known in the art can be used as alternatives
thereby causing booster spring 53 to bend Thus in embodi- When desired the keyboard tray 70 can be attached to
ments the booster springs 53 can provide additional upward lower platform 20 and items can be placed on it such as
bias when the upper platform 10 is in or near the fully keyboard According to 70 can be located
embodiments tray
lowered position at an adjustable distance from the lower platform 20
As shown in FIGS when the user desires to Referring to an alternative embodiment shown in FIG 14
increase the distance between the lower platform 20 and the 10 the keyboard 70A can be attached
tray to the bottom side of
upper platform 10 the user can pull the handles of the the upper platform 10 For example joint component 72A
locking sets 40 to impact locking set 40 springs 44 and can connect the tray portion 71A to the underside of the
anchors 41 causing anchors 41 to retract from the perfora- lower platform10 When in use keyboard tray 70A may
tion 3111 and hole 111 releasing the primary and secondary move up and down with upper platform 10 thereby making
pivot arms 31 32 so the spacing between the upper platform 15 it more convenient to access items placed on keyboard tray
10 and the lower platform 20 can be increased 70 such as keyboard
As shown in FIGS 10 and 11 lowering the upper Referring to FIG 15 the main pivot arm 31 and/or
platform 10 causes the pivot arm sets 30 to pivot with secondary pivot arm 32 can be cladded with 80
protector
respect to the upper mounting brackets 21 The resultant According to an embodiment the protector 80 is made with
rotation of the secondary pivot arms 32 causes the respective 20 EVA foam ethylene-vinyl acetate copolymer however
bosses 321 to slide within the respective arc slots 211 other materials are possible Protector 80 can help prevent
thereby stretching the respective compression springs 51 of jammed fingers due to an reaching between
operator pivot
the biasing mechanisms 50 providing measure of resis- arm 30 and upper mounting brackets 21
sets
Referring to FIGS 16 and 17 embodiments of

tance lowering of the 10 When the
against upper platform the adjust-
distance between the upper platform 10 and the lower 25 able desk platform can include legs that the adjust-
support
platform 20 is gradually increased from the fully lowered able desk platform above the ground For example the
position bosses 321 slowly pull away from the respective adjustable desk platform can include four 90 extending
legs
booster springs 53 and allows the booster springs 53 to from its as shown however more or less than four
corners
retract to their natural unbent state legs are possible The legs 90 can be fixed in length or
Increasing the weight on upper platform 10 e.g by 30 alternatively can be adjustable in length using structures
placing an item on the upper platform 10 can increase the known in the art For example according to embodiments
difficulty of raising the upper platform 10 from the lower the legsmay telescope to adjust their length For example
platform 20 Due to the configuration of the biasing mecha- as shown in FIG 16 each leg 90 can include first portion
nism 50 booster spring 53 and pivot 54 when upper
point 90A and second portion 90B that telescopes within the first
platform 10 is raised from the lower platform 20 the elastic 35 portion 9OAto adjust the leg length Conventional structures
force of booster spring 53 and spring 51 can influence the can be utilized to lock the position of the second 90B
portion
boss 321 of each secondary pivot arm 32 causing secondary with respect to the first portion 90A One of ordinary skill in
pivot arm 32 to generate an upward liffing force reducing the art will understand based on this disclosure that other
the amount of effort required from the user to raise the upper configurations of telescoping 90 can be
legs provided
platform 10 40 Moreover one of ordinary skill in the art will understand
When lifting upper platform 10 the overall center of based on this disclosure that other configuration of legs
gravity of the adjustable desk platform can shift between besides telescoping legs can be used to provide adjustable
lower platform 20 and upper platform 10 especially when leg lengths
various items are placed on top of upper platform 10 The legs 90 whether fixed or adjustable in length can
Because items located on the upper platform create addi- 45 allow the adjustable desk platform to be self-supported
tional weight the overall center of gravity of the adjustable above the ground Casters rollers wheels or other stnic
desk platform will quickly shift to the upper platform 10 tures not shown can be provided at the bottom of the legs
and potentially make the adjustable desk platform unstable 90 to facilitate movement of the adjustable desk platform
Accordingly the counterweights 22 can increase the Except for the provision of legs and the related structures
weight of lower platform 20 thereby helping to counterbal- 50 embodiments of the adjustable desk platform shown in
ance the weight of the upper platform 10 when in the raised FIGS 16 and 17 can be substantially the same as described
position and/or when weighted with items in connection with FIGS 1-15
According to embodiments the housings 23 of upper Referring to FIG 17 the adjustable desk platform can
platform 10 and the housings 46 of locking set 40 can help include frame member 91 that attaches for example to the
the users fingers or other foreign matter from being

protect 55 upper mounting brackets 21 lower platform not shown or
caught in the locking sets 40 the pivot arm sets 30 and/or other part of the adjustable desk platform For example
inside of the biasing mechanisms 50 Housings 23 and fasteners such as bolts or rivets welding bonding or other
housings 46 can also add to the aesthetic appearance of the attachment techniques used The
can be legs 90 can in turn
adjustable desk platform be attached to the frame member 91 for example using
Referring to FIGS and the adjustable desk platform 60 fasteners such as bolts or rivets welding bonding or other
can include keyboard tray 70 The keyboard tray 70 can be attachment techniques As shown in FIG 17 an embodi
connected with lower platform 20 Keyboard ment can end caps 92 extend
detachably include that into open ends of
tray 70 includes tray portion 71 and one more releasable
or the frame member 91 however other configurations are
joint components 72 According to an embodiment two possible Referring back to FIG 16 embodiments can
joint components 72 can be connected on opposed sides of 65 include cover portion 93 that extends over and conceals all
tray portion 71 The joint components 72 can be slidably or portion of the frame member 91 thereby improving the
mounted on the lower platform 20 Additionally or alterna- safety and/or of the adjustable desk platform
appearance

US 9924793 B2
10
Although not shown lateral supports can extend between other techniques known in the art Alternatively all or part
one more the legs 90
of of the members 106 108 can be integral e.g
pairs support
Referring FIGS 18-21 another embodiment of the

to monolithic with the upper platform 10 and/or keyboard tray
adjustable desk platform is shown The embodiment of 70A According to the embodiment shown the support
FIGS 18-21 is substantially the same as shown and members 106 108 can have cutouts e.g forming an
described in connection with FIGS 1-15 For example the X-shape in order to decrease weight and material however
adjustable desk platform of FIGS 18-21 can include the other configurations are possible
same or similar pivot mm sets 30 sets 40 biasing
locking Referring to FIGS 22-24 another embodiment of the
mechanisms 50 reinforcement members 60 counter- adjustable desk platform is shown The embodiment of
weight legs and/or other features of previously-described to FIGS 22-24 is substantially the same as shown and
embodiments Accordingly only additions or differences described in connection with FIGS 18-21 For example the
from previous embodiments are described below adjustable desk platform of FIGS 22-24 can include the
Generally similar to the embodiment of FIG 14 the same or similar pivot arm sets 30 lockingsets 40 biasing
adjustable desk platform of FIGS 18-21 can include mechanisms 50 reinforcement members 60 counter-
tray 70A suspended below the upper platform 10 weight legs and/or other
keyboard ts features of previously-described
The keyboard tray 70A can be adapted to support computer embodiments Accordingly only additions or differences
keyboard mouse tablet computer or other device For from previous embodiments are described below
example the keyboard tray 70A can be substantially planar According to an aspect of the embodiment of FIGS
and can have size equal to or greater than conventional 22-24 the adjustable desk platform can include plate 110
computer keyboard According to an embodiment the sur- 20 that serves as common mounting point for various com
face area of the keyboard tray 70A is between about one half ponents such as the upper platform 10 the pivot ann sets 30
and about one quarter of the surface area of the upper the locking sets 40 the keyboard tray 70A etc and related
platform According to an embodiment the surface area of instead of mounting these parts to
components Accordingly
the keyboard tray IOA is about one third of the surface area the upper platform 10 itself they can mount to the plate 110
of the upper platform 10 In order to provide sufficient space 25 to which the upper platform 10 can also be mounted This
for the keyboard tray 70A according to embodiments the configuration can facilitate easier assembly and/or transpor
pivot arm sets 30 can be lengthened as compared to embodi- Cation of the adjustable desk platform as the upper platform
ments without the keyboard tray for example to increase 10 may no longer need to provide mounting support for the
distance between the upper platform 10 and lower platform various components Additionally or alternatively the plate
20 For example the pivot arms sets 30 may be increased 30 110 can facilitate replacement of the upperplatform lOin the
lengthwise by between about and about as compared event the upper platform 10 becomes damaged According
to embodiments without the tray more specifically by about to embodiments the plate 110 can be formed from metal
to about such as steel however other materials including wood

As best seen in FiGS 18 and 19 the keyboard tray 70A plastics and composites are also possible
can be generally T-shaped in that it can define relatively 35 Referring to FIG 22 according to embodiments the
narrow portion 100 joined to relatively wide portion 102 support members 106 108 for the keyboard tray 70A can be
to define shape The narrow portion 100 and wide secured to the plate 110 for example to the underside
portion 102 are shown separated by an imaginary dashed thereof by rivets screws welding bonding or other fas
line in FIG 18 for illustration purposes only The edge of the tening techniques known in the art Referring to FIG 23 the
upper platform 10 adjacent the keyboard tray 70A can also 40 pivot arm sets 30 can additionally or alternatively be secured
define recess 104 such as generally shaped recess to the plate 110 e.g by the respective mounting brackets
The width of the recess 104 can be the same or similar to the located on the underside of the plate 110 for example by
width of the narrow portion 100 of the keyboard tray 70A rivets screws welding bonding or other fastening tech-
As result the narrow portion 100 of the keyboard tray 70A niques known in the art As best shown FIG 24 the
in
in registry with the recess

can be positioned generally 104 45 locking sets 40 and/or related components e.g handles 42
for example for ergonomic reasons can additionally or alternatively be secured to the plate 110
Referring to FiGS 18 and 21 first and second support using similar fastening techniques The upper platform 10
members 106 108 can connect the keyboard tray 70A to the can in turn attach to the plate 110 for example using screws
upper platform 10 According to embodiments the first and extending through the plate and into the upper platform 10
second support members 106 108 can be located adjacent 50 from below Alternatively bonding staples or other fasten-
opposite sides of the generally U-shaped recess 104 Addi- ing techniques known in the art can be used to attach the
tionally or alternatively the first and second support mem- upper platform 10 to the plate 110
hers 106 108 can be located adjacent opposite ends of the In the embodiment of FIGS 22-24 as well as prior
narrow portion 100 of the T-shaped keyboard tray 70A embodiments upper platform 10 and/or keyboard
the tray
According embodiment the narrow portion 100 of the

to this 55 70A can be formed of substrate such as wood e.g particle
keyboard tray 70A can fit the keyboard and the wide portion board plastic composite or other material decorative
102 of the keyboard tray 70A can provide additional support layer can be applied over the substrate for example such as
for the users hands or wrists however other uses are by painting powder coating or wrapping in film such as
possible One of ordinary skill in the art will understand nylon film One of ordinary skill in the art will appreciate
based on this disclosure that the upper platform 10 and 60 based on this disclosure however that other techniques can
keyboard tray 70A are not limited to the specific shapes and be employed to provide decorative and/or protective finish
appearances shown in FIGS 18-21 to the upper platform 10 and/or keyboard tray 70A
Still referring to FIGS 18 and 21 the support members Although the keyboard tray 70A is shown substantially
108 can metal brackets such fixed in position in FIGS 22-24 embodi
106 comprise as stamped and proceeding
metal brackets that are connected to the keyboard tray 70A 65 meats alternative embodiments can include keyboard
and to the upper platform 10 on opposite ends for example tray 70A that is adjustable in position For example accord-
using fasteners such as screws nails rivets or bonding or big to embodiments the keyboard tray 70A can adjust
Copy provided by USPTO from the FIRS image Database on 05-08-2018

US 9924793 B2
11 12
up/down left/right forward/rearward and/or can pivot therefore to be understood that within the scope of the
about various axes with to the 10 and

respect upper platform claims their equivalents the invention may be practiced
One of ordinary skill in the art will appreciate based on this otherwise than as described
specifically
disclosure that various adjustment and/or pivoting structures The invention claimed is
can be utilized to provide the aforementioned movements to An adjustable desk platform comprising
the keyboard tray 70A an upper platform defining substantially planar work
Referring to FIGS 22 and 23 an elastic member 120 such surface
as spring can be secured between the arms of each pivot base located beneath the the base
upper platform
arm set 30 For example the elastic member 120 can be defining bottom that is adapted to sit on an existing
secured at each end to one of the arms using known 10 desk
fastening techniques such as screws bolts rivets bonding first and second sets of anus coupling the upper platform
welding members 120 and/or pivot arm sets
etc The elastic to the base wherein the first and second of arms are
sets
30 can be configured for the elastic members 120 to relax as adapted for movement of the upper platform substan
the upper platform 10 is moved upward toward the fully tially in parallel with the base between raised position
raised position thus offsetting some of the force required for 15 and lowered position
user to raise the upper 10 According to other
platform reinforcement member extending between the first set of
embodiments the elastic member 120 can comprise multiple arms and the second set of arms
springs or other elastic devices keyboard tray suspended below the upper platform
FIGS 24 and 25 depict another embodiment of the wherein the keyboard defines first and second
tray
adjustable desk platform that includes hand apertures 130 20 lateral edges
extending through the upper platform 10 in the vicinity of first bracket extending between the
support upper plat
the handles 42 of the locking mechanisms 40 Each of the form and the first lateral edge of the keyboard tray
apertures 130 can be shaped and configured to permit second bracket extending between the upper
support
passage of all or portion of the users hand therethrough platform and the second lateral edge of the keyboard
For example each aperture 130 can be shaped and config- 25 tray wherein the surface area of the keyboard is
tray
ured for passage of least the four fingers of the users hand than of upper platform and
at less the surface area the
as shown According to embodiments the apertures 130 locking mechanism adapted to releasably lock the upper
can be substantially oval-shaped or can have the shape of an platform in the raised position and in at least one
elongated slot however other embodiments are possible intermediate position between the raised position and
Each aperture 130 can be located next to or substantially 30 the lowered position the locking mechanism compris
next to the respective handle 42 such that when user ing
extends his fingers into the aperture 130 from above his or first member biased into locked position to immo
her fingertips can touch and manipulate the handle 42 bilize the first set of arms
According to embodiments the lateral centerpoint of each first handle extending under the platform the
upper
aperture 130 can be offset from the lateral center of the 35 first handle user-operable to move member
the first
handle 42 e.g an unlocked

respective the central pivot point in the into position to permit movement of the
embodiment shown by lateral distance W3 of between first set of arms and
about and about inches however other embodiments are first
linkage extending between the first handle and
possible FIG 25 depicts the handles 42 after the user as the first member
moved them from the locked position toward the unlocked 40 The adjustable desk platform of claim wherein the
position locking mechanism further comprises

The arrangement of the apertures and handle 42 can be second member biased into locked position to immo
used any of on the embodiments of adjustable desk plat- bilize the second set of arms
forms described herein The arrangement of apertures 130 second handle under the the
extending upper platform
and handles 42 can be useful in embodiments having wide 45 second handle user-operable to move the second mem
upper platform 10 for example and without limitation those ber into an unlocked position to permit movement of
with width Wi of about 48 inches or greater For example the second set of arms and
with embodiments having an upper platform 10 of this size second linkage between the second handle
extending
it may be difficult or uncomfortable for the user to reach and the second member
around the lateral ends of the platform to reach the handles 50 The adjustable desk platform of claim wherein the
42 e.g due to limited wingspan Accordingly the aper- member comprises

first first anchor and the second
lures 130 can allow the handles 42 to be separated by member comprises second anchor
comfortable width W2 of between about 18 and about 36 The adjustable desk platform of claim further com
inches for example between about 28 and 32 inches while prising
the upper platform 10 has larger overall width Wi 55 first mounting bracket extending under the upper plat
The embodiments illustrated and discussed in this speci- form wherein the first set of arms is connected to the
fication are intended only to teach those skilled in the art the first
mounting bracket and
best way known to the inventors to make and use the second mounting bracket extending under the upper
invention Nothing in this specification should be considered platform wherein the second set of arms is connected
as limiting the scope of the present invention For example 60 to the second mounting bracket
of features with The desk platform of claim
the arrangement respect to the upper plat- adjustable further com
form and the lower platform such as e.g the locking prising
mechanism can be reversed All examples presented are first elastic member connected to the first set of arms the
representative and non-limiting The above-described first elastic member adapted to bias the upper platform
embodiments of the invention may be modified or varied 65 toward the raised position
without departing from the invention as appreciated by The adjustable desk platform of claim further corn
those skilled in the art in light of the above teachings It is pri sing

US 9924793 B2
13 14
second elastic member connected to the second set of second mounting bracket extending under the upper
arms the second elastic member adapted to bias the platform wherein the second set of arms is connected
upper platform toward the raised position to the second mounting bracket
The adjustable desk platform of claim wherein the 14 The adjustable desk platform of claim 12 further
keyboard tray is
generally T-shaped comprising reinforcement member extending between the
The adjustable desk platform of claim wherein the first set of arms and the second set of arms
first member comprises first anchor 15 The adjustable desk platform of claim 12 further
The adjustable desk platform of claim wherein comprising keyboard tray suspended below the upper
the upper platform defines bottom surface platform
10
the first handle is located underneath the upper platform 16 The adjustable desk platform of claim 15 wherein the
and includes first end pivotally connected to the keyboard tray is

generally T-shaped
bottom surface of the upper platform and second end 17 The adjustable desk platform of claim 12 further
opposite the first

end and comprising keyboard tray suspended below the upper
the second end of the first handle is pivotable by user platform wherein the keyboard tray is detachably connected
about the first end of the first handle toward the bottom with the upper platform
surface of the upper platform to move the first member 18 The adjustable desk of claim 12 wherein
platform
into the unlocked position and to permit movement of the upper platform defines bottom surface
the first set of arms the first handle is located underneath the upper platform
10 The adjustable desk platform of claim the locking 20 and includes first end connected to the
pivotally
mechanism further comprising bottom of
surface the upper platform and second end
second member biased into locked position to immo- opposite the first
end
bilize the second set of arms and the second end of the first handle is
pivotable by user
second handle extending under the upper platform the about the first end of the first handle toward the bottom
second handle user-operable to move the second mem- 25
surface of the upper platform to move the first member
ber into an unlocked position to permit movement of into the unlocked position and to permit movement of
the second set of arms the set of
first
arms
wherein the second handle is located underneath the upper the second handle is located underneath the upper plat
platform and includes first end pivotally connected to form and includes first end pivotally connected to the
30
the bottom surface of the upper platform and second bottom surface of the upper platform and second end
end opposite the first end and the second end of the opposite the first end and
second handle is pivotable by user about the first end the second end of the second handle is pivotable by user
of the second handle toward the bottom surface of the about the first end of the second handle toward the
upper platform to move the second member into the bottom surface of the upper platform to move the
unlocked position and to permit movement of the second member into the unlocked position and to
second set of arms permit movement of the second set of arms

11 The adjustable desk platform of claim 10 wherein 19 The adjustable desk platform of claim 18 wherein
the upper platform includes first and second lateral ends the upper platform includes first and second lateral ends
the first handle is located between the first set of arms and 40 the first handle is located between the first set of arms and
the first lateral end of the upper platform and the first lateral end of the upper platform and
the second handle is located between the second set of the second handle is located between the second set of
arms and the second lateral end of the upper platform arms and the second lateral end of the upper platform
12 An adjustable desk platform comprising 20 An adjustable desk platform comprising
an upper platform defining work surface 45 an upper platform defining work surface
base located beneath the upper platform the base base located beneath the platform the base
upper
defining bottom that is adapted to sit on an existing defining bottom that is adapted to sit on an existing
desk desk
first and second sets of arms coupling the upper platform first and second sets of arms coupling the upper platform
to the base wherein the first and second sets of arms are 50 to the base wherein the first and second sets of arms are
adapted for movement of the

upper platform substan- movement of
adapted for upper platform substan
the
tially in parallel with the base between raised position tially in parallel with the base between raised position
and lowered position and and lowered position and
locking mechanism adapted to retain the upper platform locking mechanism adapted to retain the upper platform
in the raised position and in at least one intermediate 55 in the raised position and in at least one intermediate
position between the raised position and the lowered position between the raised position and the lowered
the mechanism the mechanism
position locking including first position locking including fust
handle extending under

upper platform and the handle extending under the platform the first
upper
second handle extending under the upper platform the handle user-operable to permit movement of the upper
first handle and the second handle user-operable to to platform with to the base and
respect
unlock the first and second locking mechanisms keyboard suspended below the
tray upper platform
respectively wherein
13 The adjustable desk platform of claim 12 further the upper platform defines recess having first and second
comprising lateral sides and third side substantially transverse to
first mounting bracket extending under the

upper plat- 65 the first and second lateral sides and
form wherein the first set of arms is connected to the the keyboard tray defines first and second lateral edges
first mounting bracket and the adjustable desk platform further comprising

US 9924793 B2
15 16
first
support bracket extending between the upper 30 The adjustable desk platform of claim 29 further
platform and the first lateral edge of the keyboard comprising
tray and second member adapted to releasably lock the second
second support bracket extending between the upper set of arms in position with respect to the second
platform and the second lateral edge of the keyboard mounting bracket and second handle connected to
tray the lower surface of the upper platform the second
21 The adjustable desk platform of claim 20 wherein the handle user-operable to unlock the second set of arms
keyboard tray is
generally T-shaped to
permit movement of the upper platform between the
22 An adjustable desk platform comprising raised and the lowered positions

10
an upper platform defining substantially planar work wherein the second handle is located underneath the upper
surface and lower surface opposite the work surface platform and includes first end pivotally connected to
first and second mounting brackets extending below the the lower surface of the upper platform and second
upper platform the first and second mounting brackets end opposite the first end and the second end of the
laterally spaced apart from one another second handle is pivotable by user about the first end
15
base located beneath the upper platform the base of the second handle toward the lower surface of the
defining bottom that is adapted to sit on an existing upper platform to move the second member into the
desk unlocked position and to permit movement of the
first and second sets of arms connecting the base to the second set of arms
first and second mounting brackets the first and second 20 31 The adjustable desk platform of claim 30 wherein
arms adapted to move the upper platform substantially the upper platform includes first and second lateral ends
in parallel with the base between raised position and the first handle is located between the first set of arms and
lowered position and the first lateral end of the upper platform and
first member adapted to releasably lock the first set of the second handle is located between the second set of
arms in position with respect to the first mounting 25 arms and the second lateral end of the upper platform
bracket first handle connected to the lower surface of 32 An adjustable desk platform comprising
the upper platform the first handle user-operable to an upper platform defining substantially planar work
unlock the first set of arms to permit movement of the surface and lower surface opposite the work surface
upper platform between the raised and the lowered first and second mounting brackets extending below the
positions and extending between

first
linkage the first 30 lower surface of the upper platform the first and second
handle and the first member mounting brackets laterally spaced apart from one
23 The adjustable desk platform of claim 22 wherein the another
first member comprises an anchor resiliently biased toward base located beneath the upper platform the base having
position that locks the first set of arms into position with bottom that is adapted to sit on an existing desk
to the first
mounting bracket 35 first and second sets of arms connecting the base to the
respect
24 The adjustable desk platform of claim 22 further first and second mounting brackets respectively the
comprising keyboard tray attached to the

upper platform first and second sets of arms adapted to move the
upper
25 The adjustable desk platform of claim 22 further platform substantially in parallel with the base between
comprising raised position and lowered position and
first spring wherein movement of the upper platform 40 first

locking mechanism associated with the first set of
toward the fully lowered position extends the first arms and adapted to releasably lock the first set of arms
spring in position with respect to the first mounting bracket

26 The adjustable desk platform of claim 25 further the first locking mechanism comprising first member
comprising biased into position that locks the first set of arms into
second spring wherein movement of the upper platfonn 45 position and first handle mounted to the lower
toward the fully lowered position extends the second surface of the upper platform the first handle user
spring operable to unlock the first set of arms
27 The adjustable desk platform of claim 22 further 33 The adjustable desk platform of claim 32 further
comprising comprising second locking mechanism associated with the
keyboard tray suspended below the upper platform and 50 second set of arms and adapted to releasably lock the first set
first bracket extending between the keyboard tray and of arms in position with respect to the second mounting
the upper platform bracket
28 The adjustable desk platform of claim 22 further 34 The adjustable desk platform of claim 32 wherein the
comprising firstmember comprises first anchor resiliently biased
second member adapted to releasably lock the second 55 toward position that locks the first set of arms into position
set of arms in position with respect to the second with respect to the first mounting bracket
mounting bracket 35 The adjustable desk platform of claim 34 further
29 The adjustable desk platform of claim 22 wherein comprising

the first handle is located underneath the upper platform first
linkage extending between the first handle and the
and includes first end pivotally connected to the lower 60 first member
surface of the upper platform and second end oppo- 36 The adjustable desk platform of claim 32 wherein the
site the first end and first locking mechanism comprises
the second end of the first handle is

pivotable by user plurality of perforations located in the first set of arms
about the first end of the first handle toward the lower locking set fixed with respect to the upper platform the
surface of upper platform to move the first member

the 65
locking set including the first member comprising
position and to permit movement of
into the unlocked first anchor that is
adapted to selectively engage at least
the first set of arms one of the plurality of perforations and

US 9924793 B2
17 18
linkage connecting the first anchor and the first
handle second locking mechanism adapted to releasably lock
wherein the first handle is adapted to selectively move the second set of arms in position with respect to the
the first anchor out of engagement with the at least one upper platform the second locking mechanism includ
of the plurality of perforations ing second handle located underneath the upper
37 The adjustable desk platform of claim 32 wherein the platform and second member biased into locked
first handle is located underneath the upper platform and position to immobilize the second set of arms the
includes first end pivotally connected to the lower surface second handle including first end pivotally connected
of the platform and second end the the lower surface of the
upper platform and second
first
upper opposite to
end and end opposite the first end

10
wherein the second end of the first handle is pivotable by wherein the second end of the second handle is
pivotable
user about the first end of the first handle toward the by user about the first end of the second handle
lower surface of the upper platform to move the first toward the lower surface of the upper platform to move
member into the unlocked position the second member into an unlocked position to permit
38 The adjustable desk platform of claim 37 further movement of the second set of arms with to the
respect
comprising second locking mechanism adapted to releas- upper platform
ably lock the second set of arms in position with respect to 43 The adjustable desk platform of claim 42 wherein
the second mounting bracket the second locking mechanism the upper platform includes first and second lateral ends
comprising second handle mounted to the lower surface of the first handle is located between the first set of arms and
the upper platform the second handle user-operable to 20 the first lateral end of the upper platform and
unlock the second set of arms the second handle is located between the second set of
wherein the second handle is located underneath the arms and the second lateral end of the
upper upper platform
platform and includes first end pivotally connected to 44 The adjustable desk platform of claim 40 further
the lower surface of the upper platform and second comprising keyboard tray suspended below the upper
end opposite the first end and the second end of the 25 platform
second handle is pivotable by user about the first end 45 An adjustable desk platform comprising
of the second handle toward the lower surface of the an upper platform defining work surface and lower
upper platform to move the second member into the surface opposite the work surface
unlocked position base located beneath the upper platform the base
39 The adjustable desk platform of claim
38 wherein 30 defining bottom that is adapted to sit on an existing
the upper platform includes first and second lateral ends desk
the first handle is located between the first set of arms and first and second sets of arms coupling the upper platform
the first lateral end of the upper platform and to the base wherein the first and second setsof arms are
the second handle is located between the second set of adapted for movement of the upper platform substan
arms and the second lateral end of the upper platform 35 tially in parallel with the base between raised position
40 An adjustable desk platform comprising and lowered position
an upper platform defining work surface and lower first handle located below the and
upper platform
surface opposite the work surface user-operable to move between locked position to
base located beneath the upper platform the base immobilize the first set of arms relative to the upper
defining bottom that is adapted to sit on an existing 40 platform and an unlocked position to permit movement
desk of the first set of arms relative to the upper platform
first and second sets of arms coupling the upper platform wherein the first handle is located between the first set of
to the base wherein the first and second sets of arms are arms and first edge of the upper platform and is
adapted for movement of the upper platform substan- pivotally connected to the lower surface of the
upper
tially in parallel with the base between raised position 45 platform wherein the first handle is pivotable toward
and lowered position and the lower surface of the upper platform by user having
first locking mechanism adapted to releasably lock the thumb from first hand located on the work surface
first set of arms in position with respect to the upper and one or more fingers from the first hand located on
platform the first locking mechanism including first the first handle
handle located underneath the upper platform and first 50 46 The adjustable desk platform of claim 45 further
member biased into locked position to immobilize the comprising

first set of arms the first handle including first end second handle located below the upper platform and
pivotally connected to the lower surface of the upper user-operable to move between locked position to
platform and second end opposite the first end immobilize the second set of arms relative to the upper
wherein the second end of the first handle is pivotable by 55 platform and an unlocked position to permit movement
user about the first end of the first handle toward the of the second set of arms relative to the upper platform
lower surface of the upper platform to move the first wherein the second handle is located between the second
member into an unlocked position to permit movement set of anns and second edge of the upper platform and
of the first set of arms with respect to the upper is pivotally connected to the lower surface of the upper
platform so platform wherein the second handle is

pivotable
41 The adjustable desk platform of claim 40 wherein toward the lower surface of the upper platform by
the upper platform includes first and second lateral ends user having thumb from second hand located on the
and work surface and one or more fingers from the second
the first handle is located between the first set of arms and hand located on the second handle
the first lateral end of the upper platform 65 47 The adjustable desk platform of claim 46 wherein the
42 The adjustable desk platform of claim 40 further first and second edges are located at opposite sides of the
comprising upper platform

US 9924793 B2
19 20
48 The adjustable desk platform of claim 46 wherein the
first and second handles pivot away from each other

49 The adjustable desk platform of claim 46 wherein the
first and second handles are spaced laterally from each other
50 The adjustable desk platform of claim 45 further
comprising keyboard tray suspended below the upper

platform wherein at least portion of the keyboard tray is
located laterally between side portions of the base when the
upper platform is in the lowered position
10

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PTO-1683
Rev 7-96
USOOD832623S
(12 ) Flaherty
UnitedetStates
al.
Design Patent ( 10) Patent No.: US D832 ,623 S
(45) Date of Patent: * * Nov. 6 , 2018
(54 ) DESK 3,474,743 A * 10 /1969 Blevins ................. DO5B10875/ 129
/02
(71) Applicant: Varidesk , LLC , Coppell, TX (US) D267,374 S * 12/ 1982 Karson D6 /675
4 ,515,086 A * 5 / 1985 Kwiecinski ........ A47B 21/0314
(72 ) Inventors: Daniel G . Flaherty, Irving, TX (US); 108 / 104
D280 ,478 S * 9 /1985 Stephens .. D6 /641
David Patton , Flower Mound , TX (US ) D286 , 353 S * 10 / 1986 Robolin .. D6 /641
D288, 876 S * 3/ 1987 Goetz D6 /675
(73 ) Assignee: Varidesk , LLC , Coppell, TX (US) 4 ,781,126 A * 11/ 1988 Lochridge . ............ A47B 21/03
108 / 39
(* * ) Term : 15 Years D303 , 187 S * 9/1989 Mickelsen ................... D19/113
(Continued )
(21 ) Appl. No.: 29 /603,055
(22 ) Filed : May 5, 2017 OTHER PUBLICATIONS
Quayle Action issued Jul. 5 , 2017 in Design U .S . Appl. No.
Related U .S . Application Data 29/533, 490 .
(63) Continuation of application No. 29/512 ,926 , filed on (Continued )
Dec. 23 , 2014 , now Pat. No. Des. 785 ,989. Primary Examiner — John Windmuller
(51) LOC (11) CI. ... **.. ......................... 06 -03 Assistant Examiner — Steven J Czyz
(52) U .S . CI. (74 ) Attorney, Agent, or Firm — Venable LLP ; Michele
USPC .... ............. D6 /655 V . Frank ; Elizabeth C . Gitlin
( 58 ) Field of Classification Search
USPC ........... D6 /641 , 642, 696 , 696 . 3 , 696 .5 , 697 , (57) CLAIM
D6 /697 . 1, 698 , 704 , 705. 1 , 707 . 15 , 685 ,
D6 /686 , 655, 662, 653. 1, 653 . 14 The ornamental design for a desk , as shown and described.
CPC ........... A47B 1 /03 ; A47B 23 /002; A47B 5 /06 ; DESCRIPTION
A47B 21/00 ; A47B 1/00 ; A47B 1/ 04 ;
A47B 21 /06 ; A47B 17 /00 ; A47B 11 /00 ;
A47B 21/ 0314 ; A47B 2021/0321 FIG . 1 is a front-right perspective of a desk according to the
See application file for complete search history. claimed design shown in a lowered position ;
FIG . 2 is a front view of the desk of FIG . 1;
(56 ) References Cited FIG . 3 is a rear view of the desk of FIG . 1 ;
FIG . 4 is a left side view of the desk of FIG . 1 ;
U .S . PATENT DOCUMENTS FIG . 5 is a right side view of the desk of FIG . 1 ;
FIG . 6 is a top view of the desk of FIG . 1 ; and ,
1 ,824 ,822 A * 9/ 1931 Kradolfer .............. A47B 21/02 FIG . 7 is a front-right perspective of the desk of FIG . 1
108/ 97 shown in a raised position .
2 ,545 ,515 A * 3/ 1951 Mast ...................... A47B 9 /00 The features shown in broken lines represent portions of the
108 / 138
D166 ,377 S * 4 / 1952 Curtis et al. ................ D6 /678 .2 desk which form no part of the claimed design .
2 , 766 ,088 A * 10 / 1956 Jackson ..... .. .. ... ..... A47B 9 / 18
108 /138 1 Claim , 7 Drawing Sheets
. .
.--
- --
-
US D832 ,623 S
Page 2
(56 ) References Cited 2004/0040480 A1 * 3/2004 Hwang ..... A47B 3 /02

108 / 145
U . S . PATENT DOCUMENTS 2005/0039643 Al * 2/ 2005 Dailey ................. A61B 6 /0407
108 / 132
4 ,926 ,760 A * 5/ 1990 Sack .......... B65G 1/07
108 / 145
2005/0045072 A1* 3/2005 Rossini ............. A47B10821/50/0314
.01
D311, 291 S * 10 / 1990 Ugalde ... D18/59 2005/ 0284341 A1 * 12 / 2005 Klassy ................... A47B 21/00
D312 , 122 S * 11/ 1990 Veillette · D23 /249 108 /50 .02
D323 ,436 S * 1/ 1992 Harrison
D323 ,437 S * 1 / 1992 Hashimoto ................ . D6 /641
.. D6 /655 . 14 2006 /0096505 A1* 5/2006 Sykes .... A47B 21/ 02
108 /50 .01
D342, 242 S * 12 / 1993 Hassel ................. ........ D14 /461
D344 ,864 S * 3 / 1994 Leonard .... ... D6 /641
2007 /0163475 Al* 7/2007 Murphy ...... A47B108 /9147
/00
D365, 465 S * 12 / 1995 Kniefel . . D6 /641 2008/ 0072803 A1* 3/200818 Korber ................... A47B 21/00
5 ,490 ,466 A * 2/ 1996 Diffrient ...... ..... A47B 21/0314 108 / 50 .01
108/ 138 2008 /0149000 A1* 6 /2008 Normand ................. A47B 9/ 14
D372 ,817 S * 8 / 1996 Stevens .... D6 /698 108 / 4
5 ,549 ,052 A * 8/ 1996 Hoffman A47B 9 /00 2008/0203865 Al* 8/2008 Chouinard ............. A47B 21/02
108 / 138 312 / 223 . 3
D382, 941 S * 8 / 1997 Nortier D23 /249 2010/0031855 Al* 2/2010 Zhu ...................... A47B 23 /042
D395 , 969 S * 7 / 1998 Barlow -Lawson ....... D6 / 707 .15 108 /4
5 ,823, 120 A * 10 / 1998 Holmquist ............... A47B 9 /02 2011/0247532 A1* TV10/2011
2011 Jones
Jones .... ... .. ...... . A47B 9 /02
108/ 145 108 / 147
D424 ,828 S * 5 /2000 Ko .... D6 /653 . 1
2013/0139736 A1* 6 /2013 Flaherty ..... A47B108 /9106
/ 18
D428, 279 S * 7 / 2000
Olson D6 /707.15
D435, 368 S * 12 /2000
Tzeng ............ .. ... .. . D6 /654
D436 , 268 S * 1 /2001
Ko ............................ D6 /653.21 2013/0167757 A1 * 7/2013 Tsai A47B 9 /04
D447,646 S * 9 /2001
Chang ............ ........... D6 /653 . 12 108 / 2
D464,212 S * 10 / 2002 Chen .... D6 /653 . 1 2013/0340655 A1* 12 /2013 Flaherty A47B 9 / 18
108/ 96
D486 ,669 S * 2 /2004 Wang .......................... D6 /653 . 1
D499 ,576 S * 12 /2004 Long . ... .. ........ .. ... .. D6 /653 . 17 2014 /0020606 A1* 1/2014 Benden ................ A47B 13 / 00
D530 ,939 S * 10 /2006 Nakamura ............... D6 /654 .21 108/ 50 . 14
7 , 201, 108 B2 * 4 / 2007 Eusebi A47B 9 /00 2014/0048671 A1 * 2/2014 Tsai ................. A47B 27 / 18
108 /71 248 /371
D583 ,587 S * 12 /2008 Lai .................. ........ D6/655 . 19 2014 /0123883 A1* 5/2014 Jennings ........... A47B 21/ 02
D586 ,155 S * 2 /2009 Lenterman ................. D6 /654 108 / 96
7 ,594 ,475 B1 * 9 /2009 Huang A47B 9 /08 2014 /0158026 A16 /2014 Flaherty
108 / 10 2015 /0272316 A1 * 10 /2015 Flaherty .. .. .. A47B 9 / 16
D602 ,290 S * 10 / 2009 Erickson ... D6 /704 108 / 116
7 ,654 ,208 B2 * 2/ 2010 Patten .................. A47B 46 /005 2015 /0289641 A1* 10 /2015 Ergun ............... .... A47B 9 / 16
108 / 138 108/ 42
D612 ,643 S * 3 / 2010 Rossini . D6 / 707 . 15 2015 /0296976 A1* 10 /2015 Janowski ............. A47B 23 /002
D614 ,736 S * 4 / 2010 Freiler . ........ .. ... .. ...... .. D23 / 260 108 /43
8 ,065 ,966 B1 * 11 /2011 Bacon ...................... A47B 9 / 16
108 / 145
2016/0037907 A1 * 2/2016 Ergun ...... .......... A47B108 /9147
/12
D652, 229 S * 1/ 2012 Madison ... D6 /655 2016 /0073779 Al * 3/2016 Ringlein ............ A47B 87 /002
D676 , 527 S * 2/ 2013 Xue D23/ 248 108 / 28
D680,621 S * 4 /2013 Foster ................. D23 /233
D681,782 S * 5 / 2013 Bohm .. . . . . . . . . . . . . . . . . . . . .. 123 / 233
D681, 979 S * 5 / 2013 Keen ........... . .. . .. . .. . ... D6 /691 OTHER PUBLICATIONS
D691, 223 S * 10 / 2013 Hao ........ D21/694
8 ,671, 853
B2 3/ 2014 Flaherty Examination Report dated Aug. 20, 2015 in Australian Patent
D716 , 074S * 10 / 2014 Kitajima D6 /654 . 21 Application No. 363053.
D729, 352 S * 5 /2015 Ball ........... ............. E03B 9 /025 Examination Report dated Oct. 14 , 2015 in Australian Design
D23 /259 Registration No . 363977.
D730 ,668 S * 6 /2015 Fletcher .... . D6 / 341
D733,476 S * 7 /2015 Papic D6 /655 . 16 Notice of Allowance issued Aug. 5, 2016 in Design U .S . Appl. No.
D733 , 845 S * 71 /ZVI
2015 Ball . . . . . . . . . . . . . . . . . . . . . . . . . . . D23 / 259
Dan 29 /512 ,918 .
D734,413 S * 7 / 2015 Bettin ..... D21 /694 Notice of Allowance dated Aug. 8 , 2016 in Design U .S . Appl . No.
9 , 113 , 703 B2 8 / 2015 Flaherty 29 /512 , 877.
D737, 942 S * 9 / 2015 Ball .. . D23 /259 Notice of Allowance dated Nov. 3 , 2016 in Design U .S . Appl. No.
D764 ,026 S * 8 /2016 Mills .. . .. . . ... D23 / 233 29 /512 ,873 .
D771,981 S * 11/2016 Flaherty .................... D6 /655
D771, 982 S * 11/2016 Flaherty ....... ... D6 /655 Notice of Allowance dated Nov. 8, 2016 in Design U .S . Appl. No .
D781,617 S * 3/2017 Flaherty .. D6 /655 29/512, 858 .
D781,618 S * 3 / 2017 Flaherty D6 /655 Office Action dated Aug . 17, 2016 in Design U . S. Appl. No.
D781,619 S * 3 / 2017 Flaherty ... ... D6 /655 29 /512 , 891.
D784 ,050 S * 4 / 2017 Flaherty D6 /655 Office Action dated Aug. 5 , 2016 in Design U .S . Appl. No . 29 /512, 890 .
D785, 375 S * 5 / 2017 Flaherty ......................... D6 /647 The 'Desktop Riser ’, published on http ://standingdeskgeek .com
D785 ,386 S * 5 / 2017 Flaherty ................... 06 / 707 . 15 varidesk -pro -plus-review / Internet site on Nov . 20 , 2014.
D785, 989 S * 5 / 2017 Flaherty D6 /696
D788, 887 S * 6 / 2017 Ball D23 / 259 The ‘Desktop Riser ’, published on Twitter at https://twitter. com /
2003 /0116066 A1 * 6 / 2003 Ken ........ . A47B 9 /08 pookimum on Nov . 12, 2014 .
108 /147 The ‘ Desktop Riser ’, published on YouTube at: https ://www .youtube .
2003/0140822 A1* 7/2003 Seiler .............. A47B 21/00 com /watch ? v = WB0el5rQvio on Oct. 9 , 2014 .
108/6 The ‘ Pro Plus 48 Height-Adjustable Standing Desk ’, published on
2003/ 0230222 A1* 12/ 2003 Liu ..... A47B 21 /03 YouTube at: https://www .youtube.com /watch ? v _ XKrVByT6pq8 on
108 /50.01 Oct. 31, 2014
US D832 ,623 S
Page 3
( 56 ) References Cited
OTHER PUBLICATIONS
The ' Varidesk Pro Plus 48 Standing Desk ’, published on YouTube
at: https://www .youtube.com /watch ? v _ YLOWdR51XfA on Nov . 7 ,
2014 .
The ' Varidesk Pro Plus 48 is massive ', published on Twitter at:
http ://twitter.com /johnbristowe/ status/ 545773679653552129 on Dec .
18 , 2014 .
The 'Varidesk Pro Plus 48 ', published on YouTube at : https://www .
youtube. com /watch ? v = UNPGsnQPxAA on Dec. 22 , 2014 .
* cited by examiner
U . S . Patent Nov. 6 , 2018 Sheet 1 of 7 US D832,623 S
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Vm-ld07 B-02 New Arrival Sit Standing Desktop Laptop Moun... Page 1 of 8
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VM-LD07 B-02 New arrival Sit Standing Desktop Laptop Mount Qidong Vision
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US $130-150 / Pieces | 50 Piece/Pieces (Min. Order)
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Employees: 201 - 300 People No.of R&D Engineer: 11 - 20 People Export Mode: Using an agent Have Own Export
Factory Size: 5,000-10,000 square meters Production Certification: 9 License VM-LD02-A3 B-02
No. of Production Lines: 7 Trademark: 1 Export Percentage: 78.60% Height adjustable sit
No. of Employees inTrade Department: 6-10 US $105 - 125 / Piece
People 50 Pieces
VM-XP601 F-06
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US $1 - 20 / Piece
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Aluminum Tilt Swivel
19 inch LCD TV Mount
Quick Details
US $5 - 20 / Piece
Brand Name: Vision Mounts Model Number: VM-LD07 50 Pieces
Place of Origin: Jiangsu, China (Mainland) Max load: 20kg/44lbs
Usage: work station Type: Laptop desk Electrical Vertical Sit-
Delivery time: 15-35 days MOQ: 50pcs for neutral box, 100… stand Desktop VM-
US $130 - 150 / Piece
50 Pieces
Supply Ability
Supply Ability: 100000 Piece/Pieces per Month VM-LD07T F-06 height
adjustable desk frame
US $105 - 110 / Piece
Packaging & Delivery 50 Pieces
Packaging Details neutral gift box or customer's packaging

Port Shanghai/Ningbo/Shenzhen ergonomic Height
adjustable laptop table
Lead Time : 15~35 days after the receipt of pre-payment
US $130 - 150 / Piece
50 Pieces
Features of New arrival Sit Standing Desktop Laptop Mount Corner design office
*One touch sit and stand function sit stand laptop desk
*Durable gas spring for easy adjustment US $120 - 140 / Piece

50 Pieces
*Straight height adjustment for easy use
https://www.alibaba.com/product-detail/VM-LD07-B-02-New-... 12/11/2018
*Keyboard tray can be used at any comfortable position Ergonomic Desktop Sit
*Keyboard tray can be raised to the same level of desktop Stand Workstation for
US $77 - 84 / Piece
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Details of New arrival Sit Stand Desktop Laptop Mount
Specifications Packing information
load 20kg Neutral gift box
Qty/Carton 1pcs
Carton Size(cm) 105x67.5x23cm Contact

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GW(kgs) 25kgs
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Desktop (JN-LD02 A1)
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50 - 171 Sets >=172 Sets
US $130.00 US $78.00 2 YRS CN
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Employees: 201 - 300 People No.of R&D Engineer: 21 - 30 No. of In-line QC/QA: 015 Export Mode: Have Own Export
Factory Size: 5,000-10,000 square People License
meters Production Certification: 2 Export Percentage: 95.00%
No. of Production Lines: 3 No. of Employees inTrade
Department: 6-10 People
200
Set
PRODUCT DISPLAY SPECIFICATIONS PACKING RELATED PRODUCTS OUR COMPANY CERTIFICATES FAQ 50 Sets
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Set
50 Sets
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Pieces
Type: Office Furniture Specific Use: Office Desks 50
General Use: Commercial Furniture Material: Metal
Metal Type: Iron Appearance: Modern
Size: 920*560 mm Place of Origin: Jiangsu, China (Mainland)
Sets
Brand Name: JEO Model Number: JN-LD02 A1
50 Sets
Product Name: Mordern Office Height Adj… Lifting type: Gas spring
Height range: 165-415mm Load capacity: 4-15kg
Keyboard Tray load: 0-2kg Color: White/Black
Piece
50
Supply Ability
Supply Ability: 100000 Set/Sets per Month
Set
Packaging & Delivery 50 Sets
https://jonoffice.en.alibaba.com/product/60730216312-0/High_... 12/11/2018
Packaging Details JN-LD02A2 office adjustable stand up desk
Packing size:105*67.5*23 cm 2018 New Design
N.W.: 21.9 kg Height Adjustable Sit
G.W.: 24.7 kg US $80.0 - 130.0 /
40HQ Loading: 420pcs Piece
50 Pieces
Port Shanghai
Lead Time : 35-45 days after deposit
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00:00 00:33
PRODUCT DISPLAY
High Quality Ergonomic Height Adjustable Sit Standing Desk Riser Desktop (JN-
LD02 A1)
High Quality Ergonomic Height Adjustable Sit Standing Desk Riser Desktop
(JN-LD02 A1)
*Weight for this desk is 25 kg, performs good in stability and adjustment
compared with other products (15 kgs) in market.
*Material for desk leg is cold-rolled steel, the sturdy structure with no wiggling
when height adjusted.
*Innovative one touch height lock mechanism
*Double gas spring provides smooth height adjustment, easily and smoothly for
a girl to operate.
Contact
*Space well management both above and under the desktop Supplier
*Size: S/M/L available

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*Both Gas spring / Electric version available
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OUR COMPANY Browsing

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Nantong Jon Ergonomic Office

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Nantong Jon Ergonomic Office corporation, is a main manufacturer specialized

in designing and producing a comprehensive line of ergonomic sit stand desks, Trade
Manager
standing desks, adjustable table,monitor mounts, TV brackets, TV carts, etc for
applications in home or office. Dedicate to providing integrated office system.
Why Jon Ergonomic Office corporation?

* The direct-to-factory business model offers dual benefits of increased margin
and reduced lead time of a factory.
* We have a 40-persons R&D team, including engineers in Consumer
Electronics and ergonomic furniture fields. To support our customers, we
develop and launch more than 50 new models annually, keeping them having
strong competitive capability & always at the forefront of the market trends.
* We have implemented the total quality assurance system from raw material
inspection, production processing control, to final inspection and packing. We
are committed to delivering the highest quality products that are easy to install
and maintain with a competitive cost saving solutions. Benefits from
guaranteed quality: Old customer retention rate-90%.
* Supermatic workshop and over 330 workers which ensure the lead time about
35-45 days.
* Support OEM/ODM & Customized.
Modern Office Height Adjustable Sit Standing Desk Riser (JN-LD02 A2)
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Q1. Can I have a sample order?

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A: Yes, we welcome sample order to test and check quality. Mixed samples are Supplier
acceptable.
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Q2. What about the lead time of office adjustable stand up desk?
A:Sample needs 3-5 days, mass production time needs 35-45 days
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Q3. Do you have any MOQ limit for office adjustable stand up desk order?
A: Low MOQ, but we will take $250 operation charge for order amount under Message
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$5000 (except sample order)
Trade
Q4. How do you ship the goods and how long does it take to arrive? Manager
A: We usually ship by DHL, UPS, FedEx or TNT. It usually takes 3-5 days to arrive.
Airline and sea shipping also optional.
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50 Pieces 50 Pieces 50 Pieces 50 Sets
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Desks Converter Standup Workstation Fits Big Monitors 36" Wide
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1 Piece
Key Company Capacity
Production Capacity > Research & Design > Trade Capacity > 20
Employees: 101 - 200 People No.of R&D Engineer: 5 - 10 People Export Mode: Have Own Export License
Factory Size: 10,000-30,000 square meters Production Certification: 3 Export Percentage: 91% - 100%
No. of Production Lines: 3 Patent: 1 No. of Employees inTrade Department: 11-20
Trademark: 1 People
1 Piece
Similar Products Product Description Packaging Certifications Company Information Exhibition Our Services 1 Piece
FAQ --computer desk
1 Piece
Overview
Quick Details
Type: Office Furniture Specific Use: Office Desks 1 Piece
General Use: Commercial Furniture Material: MDF & STEEL, MDF,steel,G…
Appearance: Modern Place of Origin: Zhejiang, China (Mainland)
Brand Name: OEM Model Number: MF-007B
Item Name: Height-Adjustable Work Ta… Color: Black
1 Piece
Usage: office/Home/schlool Product size: 36.2*22*6.5-16.3inches
Brown Box: 40*25.20*10inches Package: Brwon Box
Use: Universal HS CODE: 9403100000
1000
Supply Ability
Supply Ability: 100000 Piece/Pieces per Month
Packaging & Delivery
https://grandix.en.alibaba.com/product/60576241067-80562719... 12/11/2018
Packaging Details Height-Adjustable Custom-Made Standing Work Tables Up Sit Stand Desks Converter Standup Workstation Fits Big Monitors 36" Wide
*Brown Package for each one
*Pcs/Carton: 1PCS.
*Brown box :40*25.20*10inches ,53/48lbs
Port NINGBO/SHANGHAI
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The product with a larger work-surface and higher weight capacity to more easily accommodate
your work set-up. The freestanding mount is compatible with almost any fixed-height desk, and the Message
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smooth gas spring adjustment allows you to quickly go from sitting to standing, enjoying all the
health and productivity benefits of changing positions throughout the day. Trade
Manager
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Product Description
Height-Adjustable Standing Work Tables Up Sit Stand Desks

Converter Standup Workstation Fits Big Monitors 36" Wide
Product size:36.20*22*6.5-16inches
Material:Steel +MDF + Gas spring
Holds monitor screen size up to 30”
Weight load: 8.8-33lbs(4-15kgs), keyboard load:4.4lbs(2kgs|)
8height adjustment
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Feature:
1, Sit and stand using experience
2, Sturdy structure with no wiggling when height adjusted and used
3, Durable double gas spring provides smooth height adjustment
4, Innovative one touch height lock mechanism
5, Can be used as monitor riser at lowest position
6, Space well management both above and under the desktop
Packaging
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Certifications
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Company Information
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Exhibition
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FAQ --computer desk
Q1: Is there any patent issue on this product ?

A1.: This product don't have patent issue ,you can sell in United States ,Europe,Canada,south America
and son on .
Q2. Is the package fit for sell by e-commerce?
A2 : Yes ,large foam inside and 5plyers master carton
Q3: Can I get an sample to test? how long it will takes?

A3: Yes, samples preparing for this sit to stand desk needs 3 days and the delievery time is 5-7days.So
totally is 8-10 days.
Q4. Can I put my company logo and model number on package?
A4: Of course you can.
Usual package is Brown Box without logo.
Offering carton with customized LOGO for free if the Quantity more than50 pcs.
Q5: Can I change the size/material as i prefer?
A5: Yes, Size and material can be changed as required
Q6: Are you a manufacturer or a trading company?

A6: We are a manufacturer.
Q7: Payment?
A7: 30%deposit,the rest against BL copy.
Q8:Date of delivery for mass order?
A8: 35days after receipt the pre-payment.
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SITA-OFFICE Standing
Desk Height Adjustable
Qty: 1
Sit Stand Up Desk Riser
Stand Fits Dual Monitors
Adjustable Standing Desk
Converter Topper Black
36'' x 31'' (Black) (1 Sets)
by SITA-OFFICE
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Color: 1 Sets 36'' X 31''
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$156.99
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• SIT TO STAND - Adjustable

workstation allows you to find that
necessary healthy balance between
sitting and standing up throughout
the day Extra Wide
• SUPER LARGE SURFACE - 36" x 31" Standing Desk
tabletop. Easy to fit TWO monitors or For Dual Monitors
a laptop and one monitor with Mount-It 48 Inch Wide Standing Desk
enough space for pens, papers, coffee Converter - Extra Wide for Dual Monito...
cup, etc. Furthermore, it has dual tier 172
(Large separate keyboard tray) $239.99
• SMOOTH AND STABLE MOVEMENT -
Sita Office's gas spring hovering
system allows the workstation to Ad feedback
smoothly adjust for sitting or
standing with just a light squeeze of
the handles.
• A COMFORTABLE EXPERIENCE -
Experience just the perfect height you
have always imagined; With a wide
range of height adjustment of up to
18 inches, say goodbye to the neck
pain, fatigue and other discomforts of
having to always look up or look
down
https://www.amazon.com/SITA-OFFICE-Standing-Adjustable-... 12/11/2018
• VERTICAL TRANSITION - Vertical
promotion and demotion of the
workstation by its support. No need
to adjust your surrounding space to
accommodate its movement.
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 This item: SITA-OFFICE Standing Desk Height Adjustable Sit Stand Up Desk Riser Stand Fits Dual Monitors… $164.99
 AmazonBasics Premium Anti-Fatigue Standing Comfort Mat for Home and Office - 20x36-Inches, Black $29.99
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Product description
Color:1 Sets 36'' X 31''
OFFICE PRODUCT SUPPLIER- SITA-OFFICE is a professional office product supplier, has been supplying
many top 500 companies in Europe and America for more than 20 years
Specificationss
Desktop length: 36 inches
Desktop width: 31 inches
Keyboard desktop length: 36inches
Keyboard desktop width: 13 inches
Desktop adjustment:From 6 inches (Min height) to 20 inches (Max height)
Desktop weight: 51.4 lbs
Desktop maximum load: 45 lbs
Product information
Color:1 Sets 36'' X 31''
Technical Details Additional Information
Brand Name SITA-OFFICE ASIN B076JGCVSP
Item Weight 58.2 pounds Customer Reviews Be the first to review this item
0.0 out of 5 stars
Package Dimensions 39.8 x 27.9 x 8.7 inches
Best Sellers Rank #159,902 in Office Products (See
Item model number 0P0031 top 100)
#216 in Office Products > Office
Color 1 Sets 36'' X 31'' Furniture & Accessories > Desks
& Workstations > Desks > Office
Manufacturer Part Number 0P002900-17-00
Desks
Shipping Weight 58.2 pounds (View shipping rates

and policies)
Date First Available July 12, 2018
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U.S. Patent No. 9,113,703

Claim ‘703 Patent Claim Text Representative Product: VM-LD07
1 An adjustable desk platform Each Accused Product is a height adjustable desk platform.
comprising:
1[a] an upper platform defining a first Each Accused Product includes an upper platform defining a
substantially planar work surface, first substantially planar work surface, and a lower surface
and a lower surface opposite the opposite the work surface.
work surface;
1[b] first and second lower mounting Each Accused Product includes first and second lower
brackets extending below the upper mounting brackets extending below the upper platform, the
platform, the first and second lower first and second lower mounting brackets laterally spaced
mounting brackets laterally spaced apart from one another.
apart from one another;
1
1[c] a base located beneath the upper Each Accused Product includes a base located beneath the
platform, the base defining a bottom upper platform, the base defining a bottom surface without
surface without legs that is adapted legs that is adapted to sit on an existing desk.
to sit on an existing desk;
1[d] first and second upper mounting Each Accused Product includes first and second upper
brackets extending upward from the mounting brackets extending upward from the base, the first
base, the first and second upper and second upper mounting brackets laterally spaced apart
mounting brackets laterally spaced from one another.
apart from one another;
2
1[e] first and second sets of arms Each Accused Product includes first and second sets of arms
connecting the first and second lower connecting the first and second lower mounting brackets to
mounting brackets to the first and the first and second upper mounting brackets, respectively,
second upper mounting brackets, the first and second sets of arms adapted to move the upper
respectively, the first and second platform substantially in parallel with the base between a fully
sets of arms adapted to move the raised position and a fully lowered position.
upper platform substantially in
parallel with the base between a fully
raised position and a fully lowered
position; and
3
1[f] a first locking mechanism associated Each Accused Product includes a first locking mechanism
with the first set of arms, the first associated with the first set of arms, the first locking
locking mechanism comprising a mechanism comprising a first anchor coupled to the first
first anchor coupled to the first lower lower mounting bracket, the first anchor adapted to releasably
mounting bracket, the first anchor lock the first set of arms in position with respect to the first
adapted to releasably lock the first lower mounting bracket, and a first handle connected to the
set of arms in position with respect lower surface of the upper platform, the first handle user-
to the first lower mounting bracket, operable to unlock the first set of arms to permit movement of
and a first handle connected to the the upper platform between the fully raised and the fully
lower surface of the upper platform, lowered positions.
the first handle user-operable to
unlock the first set of arms to permit
movement of the upper platform
between the fully raised and the fully
lowered positions.
4
comprising:
22[a] an upper platform defining a Each Accused Product includes an upper platform defining a
substantially planar work substantially planar work surface, and a lower surface
surface, and a lower surface opposite the work surface.
opposite the work surface;
22[b] first and second mounting Each Accused Product includes first and second mounting
brackets extending below the brackets extending below the lower surface of the upper
lower surface of the upper platform, the first and second mounting brackets laterally
platform, the first and second spaced apart from one another.
mounting brackets laterally
spaced apart from one another;
1
22[c] a base located beneath the Each Accused Product includes a base located beneath the
upper platform, the base upper platform, the base having a bottom that is adapted to
having a bottom that is sit on an existing desk.
adapted to sit on an existing
desk;
22[d] first and second sets of arms Each Accused Product includes first and second sets of arms
connecting the base to the first connecting the base to the first and second mounting
and second mounting brackets, brackets, respectively, the first and second sets of arms
respectively, the first and adapted to move the upper platform substantially in parallel
second sets of arms adapted to
move the upper platform
substantially in parallel with the
2
base between a raised position with the base between a raised position and a lowered
and a lowered position; and position.
22[e] a first locking mechanism Each Accused Product includes a first locking mechanism
associated with the first set of associated with the first set of arms, the first locking
arms, the first locking mechanism comprising a first anchor coupled to the first
mechanism comprising a first mounting bracket, the first anchor adapted to releasably lock
anchor coupled to the first the first set of arms in position with respect to the first
mounting bracket, the first mounting bracket, and a first handle mounted to the lower
anchor adapted to releasably surface of the upper platform, the first handle user-operable
lock the first set of arms in to unlock the first set of arms.
position with respect to the first
mounting bracket, and a first
3
handle mounted to the lower

surface of the upper platform,
the first handle user-operable
to unlock the first set of arms.
4
comprising:
33[a] an upper platform defining a work Each Accused Product includes an upper platform defining a
surface; work surface.
33[b] a base located beneath the upper Each Accused Product includes a base located beneath the
platform, the base defining a upper platform, the base defining a bottom that is adapted to
bottom that is adapted to sit on an sit on an existing desk.
existing desk;
1
33[c] first and second sets of arms Each Accused Product includes first and second sets of arms
coupling the upper platform to the coupling the upper platform to the base, wherein the first and
base, wherein the first and second second sets of arms are adapted for movement of the upper
sets of arms are adapted for platform substantially in parallel with the base between a raised
movement of the upper platform position and a lowered position.
base between a raised position
and a lowered position;
2
33[d] a locking mechanism adapted to Each Accused Product includes a locking mechanism adapted to
retain the upper platform in the retain the upper platform in the raised position and in at least
raised position and in at least one one intermediate position between the raised position and the
intermediate position between the lowered position, the locking mechanism including first and
raised position and the lowered second handles extending below the upper platform, the first
position, the locking mechanism and second handles user-operable to permit movement of the
including first and second handles upper platform with respect to the base.
extending below the upper
platform, the first and second
handles user-operable to permit
movement of the upper platform
with respect to the base.
3
4
45 An adjustable desk platform Each Accused Product is an adjustable desk platform.

comprising:
45[a] an upper platform defining a work Each Accused Product includes an upper platform defining a
surface and a lower surface work surface and a lower surface opposite the work surface.
opposite the work surface;
45[b] a base located beneath the upper Each Accused Product includes a base located beneath the
platform, the base defining a upper platform, the base defining a bottom that is adapted to
bottom that is adapted to sit on an sit on an existing desk.
existing desk;
1
45[c] first and second sets of arms Each Accused Product includes first and second sets of arms
coupling the upper platform to the coupling the upper platform to the base, wherein the first and
base, wherein the first and second second sets of arms are adapted for movement of the upper
sets of arms are adapted for platform substantially in parallel with the base between a raised
movement of the upper platform position and a lowered position.
base between a raised position
and a lowered position;
45[d] a first handle located below the Each Accused Product includes a first handle located below the
upper platform and user-operable upper platform and user-operable to move between a locked
to move between a locked position position to immobilize the first set of arms relative to the upper
to immobilize the first set of arms platform and an unlocked position to permit movement of the
relative to the upper platform and first set of arms relative to the upper platform.
an unlocked position to permit
movement of the first set of arms
relative to the upper platform,
2
45[e] wherein the first handle is located Each Accused Product includes wherein the first handle is
between the first set of arms and a located between the first set of arms and a first edge of the
first edge of the upper platform upper platform and is pivotally connected to the lower surface
and is pivotally connected to the of the upper platform, wherein the first handle is pivotable
lower surface of the upper toward the lower surface of the upper platform by a user having
platform, wherein the first handle a thumb from a first hand located on the work surface and one
is pivotable toward the lower or more fingers from the first hand located on the first handle.
surface of the upper platform by a
user having a thumb from a first
hand located on the work surface
and one or more fingers from the
first hand located on the first
handle.

Varidesk v. Qidong Vision Mounts - Complaint

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Varidesk v. Qidong Vision Mounts - Complaint

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Case 3:18-cv-03263-B Document 1 Filed 12/12/18 Page 1 of 13 PageID 1

IN THE UNITED STATES DISTRICT COURT

1. Varidesk is a Texas limited liability corporation having its headquarters at 1221

of height-adjustable desk technology.

Road, HaiHong Industry Park, Qidong, Jiangsu, China 226220.

Square, Chongchuan District, Nantong City, Jiangsu Province, China 226001.

New Youth Plaza, Gongshu District, Hangzhou, Zhejian, China.

Qu Changhe Jeidao Binhe Lu 1174, Hangzhou, China 310052.

JURISDICTION AND VENUE

United States, Title 35 of the United States Code § 1, et seq.

§§ 1331 and 1338(a).

9. Venue is appropriate in this District pursuant to 28 U.S.C. §§ 1391(b) and (c),

DEFENDANTS’ INFRINGING ACTIVITIES

VM-LD04, VM-LD07, VM-SD07, VM-SD08, VM-LD08, and all sub-models thereof

showing the Accused Products is attached as Exhibit 6.

names, including Fezibo, Vivo, Songmics, Voyadesk, and SITA-Office.

indirect infringement of the Asserted Patents.

COUNT I – INFRINGEMENT OF THE ’703 PATENT

infringement of the ’703 Patent by an Accused Product is attached as Exhibit 13.

Products for importation and sale in the United States.

result of Defendants’ past and ongoing infringement.

25. Unless Defendants’ infringement is enjoined, Varidesk will continue to be

damaged and irreparably harmed.

notified of Varidesk’s complaint leading to the ITC Investigation.

COUNT II – INFRINGEMENT OF THE ’809 PATENT

infringement of the ’809 Patent by an Accused Product is attached as Exhibit 14.

Products for importation and sale in the United States.

result of Defendants’ past and ongoing infringement.

33. Unless Defendants’ infringement is enjoined, Varidesk will continue to be

damaged and irreparably harmed.

notified of Varidesk’s complaint leading to the ITC Investigation.

COUNT III – INFRINGEMENT OF THE ’644 PATENT

infringement of the ’644 Patent by an Accused Product is attached as Exhibit 15.

Products for importation and sale in the United States.

result of Defendants’ past and ongoing infringement.

41. Unless Defendants’ infringement is enjoined, Varidesk will continue to be

damaged and irreparably harmed.

notified of Varidesk’s complaint leading to the ITC Investigation.

COUNT IV – INFRINGEMENT OF THE ’793 PATENT

infringement of the ’793 Patent by an Accused Product is attached as Exhibit 16.

Products for importation and sale in the United States.

result of Defendants’ past and ongoing infringement.

49. Unless Defendants’ infringement is enjoined, Varidesk will continue to be

damaged and irreparably harmed.

notified of Varidesk’s complaint leading to the ITC Investigation.

COUNT V – INFRINGEMENT OF THE ’623 PATENT

Accused Product and patented design:

’623 Patent Accused Product (VM-LD02T)

Products for importation and sale in the United States.

remedies, including Defendants’ total profits pursuant to 35 U.S.C. § 289.

57. Unless Defendants’ infringement is enjoined, Varidesk will continue to be

damaged and irreparably harmed.

Varidesk hereby requests a trial by jury on all issues so triable.

PRAYER FOR RELIEF

Varidesk the following relief:

Asserted Patents, literally and/or under the doctrine of equivalents;

b. Judgment be entered that Defendants’ infringement of the Asserted Patents was

c. An accounting be had for the damages resulting from Defendants’ infringement of

with interests and costs;

d. An injunction be issued, restraining and enjoining Defendants and their respective

officers, directors, agents, servants, affiliates, employees, divisions, branches, subsidiaries,

States, of products infringing the Asserted Patents;

proper under the circumstances.

Dated: December 12, 2018 Respectfully submitted,