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1 Robert Fish, Esq. (SBN 149711) 2 3 4 Mei Tsang/Esq.

(SBN 237959)
mtsang(%fishiplaw.com
l aw. corn

Fish & Associates, PC

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7

Irvine, California 92614-4271 wne: 949-943-8300 Facsimile; 949-943-8358

2603 Main Street/Suite 1000

SCHUL'TZ GRIMES, INC.

for Plaintiff,

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10 11 12 SCHULTZ GRIMES, INC., 13 14
Plaintiff,
V.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION

Civil Action No.

COMPLAINT FOR PATENT INFRINGEMENT: WILLFUL INFRINGEMENT DEMAND FOR JURY TRIAL

15 HEELUXE, LLC; and DOES 1 through 10;" ""'"' 16 17


Defendants.

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Plaintiff, by and through its attorneys of record, alleges as follows:

PARTIES
1. Plaintiff SCHULTZ GRIMES, INC, (hereinafter "SCHULTZ
GRIMES") Is a corporation organized and existing under the laws of the State of California, with a place of business at 3720 Prospect Avenue, Yorba Linda, California 92886. 2. Upon information and belief, Defendant HEELUXE, LLC (hereinafter "HEELUXE"), is a corporation organized and existing under the laws of the State of California, with its principal place of business at 503 Miramonte Drive, Santa Barbara, California 93109.
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COMPLAINT AGAINST HEELUXE, LLC

3. The true names and capacities, whether individual, corporate, associate, representative or otherwise, of DOES 1 through 10, inclusive, are

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3

unknown to Plaintiff, who therefore sues them by such fictitious names. Plaintiff will seek leave to amend this complaint to show the true names and capacities of the Defendants when they are ascertained. Plaintiff is informed and believes, and thereupon alleges, that each of the Defendants named as a DOE, along with the
named Defendants, is responsible in some manner for the occurrences herein

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5

6 7
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alleged, and that Plaintiffs damages herein alleged were legally or proximately caused by said Defendants. Wherever it is alleged that any act or omission was

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10 also done or committed by any specifically named Defendant or by Defendants


generally. Plaintiff Intends thereby to allege, and does allege, that the same act or
omission was also done and committed by each and every Defendant named as a

13 DOE, and each named Defendant, both separately and in concert or conspiracy 14 with the named Defendants. 15
4. On information and belief, and at all times mentioned herein, each of

16 the Defendants named herein as DOES 1 through 10, inclusive, performed, 17 participated In or abetted in some manner the acts alleged herein; proximately 18 caused the damages alleged herein below; and are liable to Plaintiff for the 19 damages and relief sought herein. 20 21 22 24 25 26 27 28 JURISDICTION AND VENUE
5. This is an action for patent infringement arising under the patent laws of the United States, 35 U.S,C. 1, etseq. This Court has subject matter

23 Ijurisdlction over this action pursuant to 28 U.S.C. 1331 and 1338(a).


6. This Court has personal jurisdiction over HEELUXE because HEELUXE conducts business in this judicial district and in the State of California and has and continues to commit acts of patent infringement and/or has contributed to or induced acts of patent infringement by others in this Judicial district (and elsewhere in California and in the United States).
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COMPLAINT AGAINST HEELUXE, LLC

7. Venue is proper in this judicial district pursuant to 28 U.S. C.

2 3
4 5

1391(b), 1391(c) and 1400(b) because HEELUXE is subject to personal


jurisdiction in this judicial district; has regularly conducted business in thisjudicia district; and certain of the acts complained of herein occurred in this judicial
district.

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7

THE PATENT-IN-SUIT
8. SCHULTZ GRIMES is the owner of all right, title and interest in and to United States Patent No. 6315786 ("the '786 Patent"), entitled "Device for Treating Heel Pain," which was duly and legally issued on November 13, 2001, A true and correct copy of the '786 Patent is attached hereto as Exhibit A. The 786
Patent is hereinafter referred to as the "Patent-In-Suit." 9. The Patent-In-Suit has numerous claims drawn to devices for treating pain in a person's foot. These claims are directed to an orthotic device to be placed, I in an article of footwear.

8 9 10
11 12

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14 15 16

COUNT ONE INFRINGEMENT OF THE '786 PATENT AGAINST ALL DEFENDANTS


10. Plaintiff re-alleges and incorporates herein the allegations of paragraphs 1 -9 as if fully set forth herein. 11. The (786 Patent is valid and enforceable. 12. Upon information and belief, in violation of 35 U.S.C. 271, each of the Defendants has infringed, is currently infringing, and will continue to infringe, either directly or by infringement under the doctrine of equivalents, the '786 Patent, by making, using, offering for sale, selling and/or importing into the United States devices, and specifically, at least HEELUXE's high heel shoe insert under the brand Talus Heelbed (hereinafter "Accused Product"), which incorporates and infringes the subject matter protected by at least one of claims 1-4 of the '786
Patent.

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20 21 22 23 24 25 26 27 28

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COMPLAINT AGAINST HEELUXE, LLC

1 2

13. Upon information and belief, in violation of 35 U.S.C. 277, each of the Defendants also contributes to and/or induces infringement of one or more of the claims of the '786 Patent as set forth above. 14. As a direct and proximate result of each of the Defendants' acts of infringement as alleged herein, Plaintiff has and will continue to suffer damages in an amount subject to proof at trial, and thus Plaintiff is entitled to recover damages
adequate to compensate it for such infringement, but in no event less than a reasonable royalty.

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4 5

6
7 8

15. Unless each of the Defendants is enjoined by this Court from

10 continuing their infringement of the '786 Patent, Plaintiff will suffer additional 11 irreparable harm and impairment of the value of Its patent rights. Thus, Plaintiff is

12 13

entitled to an injunction against further infringement. 16. Upon information and belief, Defendant HEELUXE has had actual

14 notice of the existence of the '786 Patent at least as of the date ofHEELUXE's 15 receipt ofSCHULTZ GRIMES's cease and desist letter on or about November 20, 16 2012, and has had constructive notice of the existence of the C786 Patent at least as 17 18
ofthe date of issuance, November 13, 2001.

17. Upon information and belief, Defendant HEELUXE's infringement

19 has occurred with knowledge of the '786 Patent and is and has been in deliberate 20 21 22 23 24 25 26 27 28
and willful in violation of 35 U.S.C. 284 entitling Plaintiff to increased damages, and making this case exceptional within the meaning of 35 U.S.C. 285. 18. Plaintiff does not yet have sufficient knowledge or information to determine whether infringement by the DOE Defendants is willful, but will seek leave of Court to amend this Complaint to so allege if and when it obtains such
knowledge and information,

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COMPLAINT AGAINST HEELUXE, LLC

1 || PRAYER FOR RELIEF


2 11 WHEREFORE, Plaintiff SCHULTZ GRIMES, for the Patent-In-Suit, prays
3 11 for judgment and relief as follows: 4 || A) Judgment that the Patent-In-Suit is valid and enforceable; 5 || B) Judgment that each of the Defendants infringe the Patent-In-Sult and that 6 || each of the Defendants' infringement is, and has been, deliberate and

7 || willful;
8 || C) Judgment that each of the Defendants, their directors, officers, 9 || employees, attorneys, and agents, and all those persons acting in active
10 concert or in participation with them, and their successors and assigns, be

11 enjoined from further acts that infringe, contributorily infringe or induce 12 [[ infringement of the Patent-In-Suit pursuant to 35 U.S.C. 283;

13 || D) Judgment that each of the Defendants individually and collectively be


14 || ordered to pay damages adequate to compensate SCHULTZ GRIMES for
15 that Defendant s infringement of the Patent-In-Suit pursuant to 35 U,S.C.

16 || 284, together with interest, including pre-Judgment interest from the 17 || date infringement of the Patent-In-Suit began;

18 11 E) Judgment that the Defendants individually and collectively be ordered to


19 || pay all costs and expenses incurred by SCHULTZ GRIMES associated 20 11 with this action pursuant to 35 U.S.C. 284; 21 F) Judgment that the Defendants individually and collectively be ordered to 22 || pay treble damages pursuant to 35 U.S.C. 284 as a result of the willful 23 || and deliberate nature of their conduct; 24 11 G) Judgment that this case is exceptional, and that the Defendants

25 || individually and collectively be ordered to pay all ofSHULTZ GRIMES']


26 ] | attorney fees associated with this action pursuant to 35 U.S. C. 285; and

27 ||/// 28 ||///
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COMPLAINT AGAINST HEELUXE, LLC

H) Judgment that SCHULTZ GRIMES be granted such other and additional


relief as this Court may deem just and proper.

3
Respectfully submitted,

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7 8
Dated: October 21,2013

FISH & ASSOCIATES, PC


By:
Me! rl^sang,_ Es_q7

Attorneys" for Plaintiff


Schultz Grimes, Inc.

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COMPLAINT AGAINST HEELUXE, LLC

EXHIBIT A

US006315786B1

(12) United States Patent


Smuckler

(io) Patent No.: US 6,315,786 Bl


(45) Date of Patent: Nov. 13,2001

(54) DEVICE FOR TREATING HEEL PAIN


(75) Inventor: Arthur H. Smuckler, Niskayuna, NY

5,127,892 5454,173 5462,041

(US)

5484^09 5,203,793
5,359,791 5,388,351 5,400,526 5,611,153 5,776,090 5,799,659 5,865,779 5,887,591 5,893,221 6,021,585

(73) A&signee: Pnrtnership ofArthur H. Sumcldcr, James Grimes, Niko Et'stathiou and Charles A. Sarris, Niskayuna, NY (US) ( * ) Notice: Subject lu any disclaimer, the term of this
patent is extended or adjusted unddr 35

U.S.C. 154(b) by 0 days. (21) Appl. No.: 09/356,715

7/1992 Sawdon .................................. 482/79 10/1992 Aultman ................................. 36/154 11/1992 Simmons .............................. 602/65 2/1993 Brown . 4/1993 Lyden ....................................... 36/S8 11/1994 Pralil et al, ............................ 36/145 2/1995 Mitctiel) et al. ....................... 36/145 3/1995 Scssa .................................... 36/141 3/1997 FLshcr ct al. . 7/1998 Ucrgmann et al. . 9/199EJ Sfaiiu . 2/1999 GIea&on . 3/1999 Powel] et al. . 4/1999 Wuissman el al. .................... 36/91 2/2000 Cole ................................... 36/11.5

(22) Filed: Jul. 20,1999:


(51) Int. Cl.7 ..................................................... A61B 17/00

OTHER PUBLICATIONS
The Foot, Gray's Anatomy, pp. 199-201. Muscles and Fasciae of the Loot, Gray's Anatomy, pp, 442-451. * cited by examiner Primary Examiner Justiiic R. Yu (74) AHwney, Agent, or iFn'm Knobbc, Marlens, Olson &

(52) U.S. Cl. ................................ 606/201; 36/145; 36/154

(58) Field of Search .,...,....,..... 602/61, 66; 601/134,

601/23, 27, 28; 36/88, 91, 92, 141,145, 148, 149, 154, 180, 182, 153, 173, 171, 43, 146; 606/201, 204 (56) Rcf(tr(itic(>s Cited U.S. PAFENT DOCUMEN'1-S
1,497,243 * 6/1924 Martin .................................. 601/27 1,974,161 * 9/1934 Riley ...................................... 36/91
3,744,483 * 7/1973 Picolin ................................... 601/28

Bear LLP

(57)

ABSTRACT

An orthotic device for treating heel pain associated with


Plantar Fasciitis is disclosed, comprised of a flexible heel cup shoe insert with a bar-shaped member extending laterally across the butlom soli; portion of the device and located under the heel-arch connection of a person's foot when worn by the person in order to apply continuous accupressure to the calciincus-midfarsiil connection area and thus alleviate
pain.

3,885.555 * 5/1975 Nobbs .................................... 601/28 3,999.558 * 12/1976 Barnwell et ai, ..,..,........,.., 36/145 4,224,750 * 9/1980 Dclport .................................... 36/91

4,325.380 4/1982 Malkin .


4,329,981 * 5/1982 Uungl ..................................... 601/28 4,689,898 * 9/1987 Fahey ...................................... 36/43

5,036,851 8/1991 Cohen . 5,067,256 11/1991 Darby . 5,088,479 2/1992 Detoro ,

4 Claims, 4 Drawing Sheets

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indicated by many patient trials, often resulting in a completely pain-fr^e yxperience for many patients,

DEVICE FOR TREATING HEEL PAIN BACKGROUND OF THE INVENTION


L Field of the Invention
The present invt;ntk>n relates to a novel orlhotic device For use in relieving h&cl pain. In particular, the present invention relates tu an orthotic device involving the continuous placument of pressure (o a certain area of the tboi in order to alleviate pain resulting from Plantar Fascutis. -10

While standard orthotic inserts often comprise a flexible


heel cup, the present invention provides hee] pain relief associated with Plantar Fasciitis using a raised bar which extends above the surface nf such a standard orthotic insert. This "Fasciitis bar" extCDcls lalcrally across the sole portion of the cup, in a posiiiun located beneath the calcancousmidtarsal connection of the loot when the orthotic device is

2. Description of the Related Art


Plantar Fasciitis is the most common cause of lied pain,

worn. The flexible heel cup serves to locate the Fasciitis bar
in precisely the proper location lo apply moderate accnpressure force when the patient walks or stands. Made of a resilient, dense material, the Fasciitis bar provides sufBcient accupressure to the calcaneous-midtarsal connection to stretch the plantar fascial tissues and prevent coHapsc of the calcaneal bone, thus relieving pftin. The Fasciitis bar places the center of accupressure mid-way across the widlh of the patient's foot. This is distinct from the arch support portion of Htandard urlholics, which apply upward pressure against the inside of the patient s foot,

debilitating countless people of both active and sedentary


Iifestyles, The condition is caused by ovcrstrcssing and subsequent inflammation of ihc plantar fascia, which is the 15 dense, fibrous sheath of muscle ti&sue located longitudmally on the bottom of the foot, stretching from the calcaneus bone at the rear of the foot to the metafarsal heads leading to the toes in the front of the foot. Heel spurs, which consist of calcinaccous deposits that grow on the i'ronl of the calcaneus 20 and point into the plantar fascla, can exacerbate the pain to an unbearable extent. Patcnts'scoinplainls of heel pain often

further forward toward the ball of the foot, In fact, the


Fasciitis bar of the present invention is located to provide pressure between the heel and the arch of the foot, along tEie ucnlcrline of the fool.

originate in the first step they take out of the bed in the
morning, when the plantar tascia is stretched violently out of

the natural contraction that occurs during a sfatc of sleep. 25 This pain may ease gradually throughout the day, only to
relurn the next morning,

BRIEF DESCRIPTION OF THE DRAWINGS


FIG. 1 is a side elevation view looking toward the inside
of a luiimn left fool, including the major bones of the foot 30 and ankle; FIG. 2 is a top plan view of the orlhotic heel ctip of the present invention, including the Fasciitis bar; FIG. 3 is ;ID isumetric view of the ortholic heel cup with

Sufferers of heel pain due to Piimtar FasciJtis and/or heel


spur commonly seek (rcalmcnl thrutigh physiciil therapy, corticosteroid drugs, surgical procedures, and a myriad of orthotic devices, cushions, and gels. The complexity of

treating this ailment is supplemented by other biomechanical


faclors, such as pronalion (rolling in of the feet), supination

(rolling ovt of the feet), weakened ankles, extra body weight,


improper footwear, loss of the body's natural shock absorbers, flattened or dropped sirchcs, and weakened high
arches.

the Fasciitis bar;


FIG. 4 is a sectional view of the orthotic heel cup taken

The prior art includes several urtholie devices inkndccl (o treat heel pain of various types. Devices exist to hold,

along a line as shown in FIG. 3 which lies along the length of the orthotic device just inside the edge which underlies the inside (arch side) of the patient's foot;
FIG. 5Ais a scctiana] view of the orthotic heel cup taken

immobilize, and/or support the heel and/or leg of the user.


Patents have been issued for inventions thai involve

along a line as shown in FIG. 3 which lies along the length


of the orthotic device at the mid-point thereof which under-

L-shaped leg braces wilh various immubilixation features,


elastic footwraps which provide compressive forces on the bollum of the fool, and orthoiic insoles to be worn with shoes for arch support and heel cushioning. The existing devices claim to alleviate heel pain by cushioning a.nd cradling the heei, applying accupressure to various foot localions using gel plalfonns, and placiag a soitcr material surrounded by a more resilient one to treat pain originating from the calcancous. While (hcsc devices provide some

lies the middle of (he patients foot; FIG. 5B is a sectional view similar to that of FIG. 5A showing an alternate embodiment of the orthotic heel cup;
FIG. 6 is a sectional view of [he orthotic heel cup of FIG.

3 taken along a line as shown in FIG. 3 which lies along the length of the orthotic device just inside the edge which underlies the outside of the patient's foot;
FIG, 7 is aside elevation view of d human leFl. foot. similar

temporary relief, they have not typically resulted in a


pain-frcc experience for patients. There is, therefor, a need

to the viewofl'IG. 1, including the major bones of the foot


and ankle, along with a scelional view of the ortholic heel cup) in section, as shown in HG. 5A, and illustrating the

for a device and method of treatment which relieves the pain


associated with Plantar Fasciitis to a greater extent than is provided by cnrrenl trcalmCDl prolocols.

proper localion of the orihotic heel cup and iis Fasciitis bar; FIG. 8 is a perspective view of a second alternative embodiment of the orthotic device of the present invention;
and FIG. 9 is a view, similar (o (hat of FIG. 7, but showing the

SUMMARY OF THE INVENTION


The inventor's experiences as a podiatrist treating patients

led to the discovery that accupressure applied at fhe


cdfcaneuus-mkllar'ial connection un the boltom of the fool

60 second alternative embodiment of FIG. 8

temporarily alleviated the pain associated with Plantar Fasciitis. The calcaneous-midtarsal connection is the point on the bottom of the foot where Ihe heel meets ihe arch. Further, the inventor discovered that accupressure continually applied to this location, using a specially constructed nrthotic device, could provide the key tn pain relief, as

DETAILED DESCRIPTION OP THE PREFERRED EMBODIMENT


FIG. 1 diagrammutically illustrates a typical human foot 65 24 along with the lower end of the tibia U. This view shows
the inside, or arch side, of the foot in outline, along with an outline of the major bones which would be seen on that side

US 6,3:15,786 Bl
ofaskeletal foot. Below the tibia 11 is the talus 13, or "ankle bone". Positioned below and rearwardly of the talus 13 is the calcancus 26, or "hwl bone . Positioned modcratuly below and forward of the tahis 13 is the navicular 15. Immediately behind the navicular 15, and nol shown in the illustration of 5 inches. The length o the bar 12 may range from 0.5 to 2.5; inches, but is preferably centered about the centerline of the orthotic device. In the prefyrrud vmbodimi;nt shown in FIG.

5A, the Fasciitis bar 12 is generally symmetric from front"


to-rear in cross section, with the front and rear surfaces

I;IU, I, is the cuboid, which occupies a position similar to


that of (he navicular 15, but on the outside of the foot. The

area butweun the calcanciLS 26 and the niivicular 15 and


cubaicl is the calcaneus-midtar&al connection 28 where the

sloping in similar contour. In a first alternate embodiment shown in FIG. 5B, the front surface 46 of the Fasciitis bar 12 slopes more acutely from the peak 4S of the bar 12 lo
provide a more abrupt pressure differential along the Jcnglh of the patient's foot.

heel meets Ihc arch of the foot 24, 10


Forward ofthi; navicular 15 and cuboid are the cuneform

bones 17, Extending fonvardly from the cuncform bones 17


are the melatarsals 30 and the plialanges 32. Though not

FIG. 7 illustrates the orthotic device 10 properly sized and positioned in relation to a patient's foot 24, As shown, ihc raised portion or Ll'asciitis bar 12 is positioned by the heel
cup portion 20 directly beneath the calcaneus-midtarsal connection 2S where the heel mecls the arch of the foot 24,

shown, the plantar fascia joins the calcaneus 26 [o the M IP


joints 34 between the metiitarsals 30 and the phalanges 32, 15

generally along the arch 36 of the foot 24, Illustrated in FIGS. 2 through 6 is the orthotic device 10
ill accordance with the present inventjoti, provided to relieve pain in the heel of a person's loot 24 when worn. The orthodc device 10 is comprised of a cup-shaped heel portion

at the junction of Ihc navicnlar 15 and cuboid with the


calcaneus 28 (See FIG. 1). This placement provides moderate comfortable pressure cm this area to provide significant

heel pain relief. The bottom sole portion 18 may extend


20 longiludinally forward along the sole of the patient s fool 24

20 which is adapled to surround the heel and adjacent areas


of a person's foot 24 when worn, and to properly position the

orthotic device 10 beneath the patient s foot 24. The orthotic dcvici; 10, including (hi; hwl portion 20, is preferably formed as a single piece, and may comprise a material that can be manufactured in the illustrated configuration through
thcrmo-forming or injection molding. Such malcrials include bul are not limited to pLislics, gels, foams such as P-lite or polypropylene, visco-elaslic polyraer, SoEl-iOle, polyurethtinc, and combinations thereof. Regardless of (he material used, the preferred hardness is between 20 to SO duromytvrs. This hardness has been found to apply appropriate pressure to the patient's foot, without causing discomfort.

and against the plantar fascia 36 (HO. I) as far forward on the foot 24 as desired, possibly even underlying the metaiarsals30(FIG. 1). Although the preceding description illustrates the Fasciitis bar 12 as a part of a heel cup orlhotic device 10, FIGS. S and 9 illustrate a simpler form of the Fasciitis bar 50. In
(his form the Fafidili'i bar 50 is a sland-alonu member,

providing a raised portion 52 having a semi-cylindrical


shapy with a Hat bollom 58. The front portiun 54 and back portion 56 of the bar 50 are tapered for increased comfort. In this form of the invention, the Fasciitis bar 50 may include adliesive on its Jlat side 58 fur aUachmcnt lo a shoe or another ortiwtic device. Alternatively, the upper surface 52,

54, 56 may inclucln adhcsivc for attachment to the sole of a


patient's foot. In either of these cases, the bar 50 is adhesively attached so that it underlies the calcaneus-midtarsal connection 28 where the heel meuls Ihu arch of the loot 24.

The orthotic device 10 includes a sole portion 18, baviag a bottom surface 40, which cxlcncl.s throughout the length of
the orlhotic device 10 and underHes the center of the

patient s heel. Extending upwardly from this sole portion 18


is a rear wall portion 16, and side wall portions 38, which

While adhesive is described herein as the preferred method


of atlachmenl of this Fasciitis bar 50 to the sole of a person's

together form the heel cup portion 20. '-llie rim 22 of the rear wall portion 16 and sidcwall portions 38 is U-shapcd lo
surround the rear of a patient's heel in a manner common lo ortholics device of the prior art.

fool or Iheir shoe, strapping or clamping may also be used


to hold ihe device in the proper location.

What Js claimed Js;


1. An orthotic device, for treating Plantar Fasciitis in a person's foot, said orthotic device to be placed in an article of footwear comprising:

A raised bar-shaped portion 12, deemed the "Fasciitis 45


bar , uxlunds l;il(;rally ucross Lhe orLhoLic device 10 just

forward of the heel cup portion 20. The raised portion 12 preferably has a semi-cylindrical or pillow shape with
tapered sides and extends above the sole portion 18 as a side-lo-sidc bump. The Fiiscntis bar 12 is preferably formed 50

a heel portion sized 1 surround part of said heel of said


foot; and

a Fctisud portion positioned with respect to said hwl


portion so that, when said heel portion surrounds said

as one piece wilh the sole portion 18 and the heel cup portion
20, and is preferably constructed of the same material. As discussed above, such materiais include but are not limited to plastics, gels, foams such as P-Iitc or polypropylcnc, visco-elastic polymer, Soflsole sheets, polyurethane, and 55

part of said heel of said foot, said raised portion is


positioned to lie beneath and place localized pressure on the calcaneous-midtarsal connection of said foot, said raised portion sized so that, when said heel portion surrounds said part of said heel of said foot, and said

combinations thereof. Regardless of the hardness of the


remainder of the orthotlc device 10, the hardness of the

raised portion is positioned to lie beneath the


calcaneous-midtarsal connection of said foot, said

Fasciitis bar 12 is preferably between 20 and 80 clurometers


to provide substantial, comfortable pressure against the sole of a patient's foot. go As shown in the cross sections of FIGS. 4, 5A and 6,the

raised portion extends a greater distance in a direction


across thu width oC s;iid foot than it does along the

length of said foot wherein said orthotic device has a


material hardncss ranging from. 20 to 80-using Ihe duromcter method. .2. An orthotic device for. treating Plantar Pasciilis in a person's Cool, said orlholic device (o be placed in an article of footwear comprising: a heel portion siwd to surround part of snul heel of said foot; and

FasciiEis bar 12 extends laterally across the orthodc device 10, blending into the heel cup portion 20 at its extreme ends,
but forming a substantial protuberance along the centerline of the orlholic device illustraled in FIG, 5A. The preferred 65

thickness of the Fayciitis bar 12 at the lateral center porliun 48 shown in;FIG. 5Amay range from 0.0625 inches to 0.375

US 6,315,786 Bl
a raised portion positioned with respect to said heel portion so that when said heel portion surrounds said raised portion extends a greater distance in a direction

part of said hwl of sakl foot, said raised portion is positioned to lie beneath and place localized pleasure
on the calcaneous-midtarsal conneclion of said foot, 5

across the width of said foot than it does along the length uf said foot wherein saki raised portion has a pillow shape and wherein the length of said pillow
shaped portion is belweeu Oi5 and 2.5 inuhuy,

said raised portion sized so that, when said heel portion


surrounds said part of said heel of said foot, and said

4. An orthotic device; for treating Plantar Fasciitis in a


person's foot, said orthotic device to be placed in an article

raised portion is positioned to lie beneiith Ihe


calcaneous-midtarsal connection of said foot, said raised poilion extends a greater distance in a direction 10

of foolwciir comprising;
a heel portion sized to surround part of said heel of said

across the width of said foot than it does along the


length of said foot wherein said raised portion has a

fool; and
it raised portion positioned with ri^pect to said heel

pillow shape ;ind whureia the thickness of said pillow shaped portion is between 0.0625 inches and 0,375
inches. 15 !3. An orthotic device' for treating Pliintar Fasciitis in a Person s foot, said ortholic dcvicd to be placed in an article

portion so that, when said heel portion surrounds said part of said heel of said foot, said raised portion is posilioned lo lie beneath and place localized pressure
on the calcaneous-midtarsal connection of said foot, said raised portion sized so that, when said heel portion surrounds said part of said heel of said foot, and said

of footwear comprising: a heel portion sized to surround part of said heel of said fool; and 20
d raised porLion pusitionixi with respuul lo said heel portion so that, when said heel portion surrounds said part of said heel of said loot, said raised portion is positioned to lie beneath and place localized pressure on the calcaneous-midtarsals connection of said foot, said raised portion sized so that, when said lieel portion

raised portion is positioned to lie beneath the


calcancous-midtarsal connection of said foot said raised portion extends a greater distance in a direction

across the width of said foot than it does along the


length of said foot wherein said raised portion has a

pillow shape and wherein the slope of the side ot said pillow-shaped rdiscd portion furlhcsl from said heel portion is greater than the slope of the side of said
pillow-shape d raised portion closest to said heel por(ton.

surrounds said parL uf said hucl of said fuot, <ind said raised portion is positioned to lie beneath the
falcaneous-midlarsal connection of said fool, said