IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION


FRENCHPORTE IP, LLC, and )
FRENCHPORTE, LLC, )
)
Plaintiffs, )
) Civil Action No. 1:13-cv-01329
v. ) JURY TRIAL DEMANDED
)
MARTIN DOOR MANUFACTURING, )
INC. and DIRECTBUY, INC. )
)
Defendants. )

FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT

Plaintiffs FrenchPorte IP, LLC and FrenchPorte, LLC (“FrenchPorte”) files this
Complaint against Defendants Martin Door Manufacturing, Inc. (“Martin”) and
DirectBuy, Inc. (“DirectBuy”), based upon actual knowledge as to itself and its own
actions, and on information and belief as to all other persons and events, as follows:
Parties
1. FrenchPorte is a Maryland LLC with its principal place of business in
Chevy Chase, MD. FrenchPorte is the assignee and owns all right, title, and interest to
U.S. Pat. No. 6,948,547, 7,857,032, D505,495, D452,979, D464,142, D464,143,
D464,736, D486,241, and D486,585, referred to below as the '547 Patent, the '032 Patent,
the '495 Patent, the '979 Patent, the '142 Patent, the '143 Patent, the '736 Patent, the '241
Patent, and the '585 Patent, respectively, and collectively as the FrenchPorte Patents.
2. Martin is a California corporation, with its principal place of business at
2828 S 900 W Salt Lake City, Utah. Martin engages in the development, manufacture
and distribution of garage doors. Martin may be served with process by service on its
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registered agent for service, CT Corporation System at 818 W Seventh Street, Los
Angeles, CA 90017.
3. DirectBuy is an Indiana corporation with its principal place of business at
8450 Broadway, Merrillville, IN and with three show rooms in the Commonwealth of
Virginia, all located in the Eastern District of Virginia: DirectBuy of Hampton Roads,
DirectBuy of Richmond, and DirectBuy of Woodbridge. DirectBuy may be served with
process by service on its registered agent for service, Corporation Service Company, 251
E Ohio St. Suite 500, Indianapolis, IN, 46204.
Jurisdiction and Venue
4. This claim arises under the United States patent laws, 35 U.S.C. § 1, et
seq. This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and
1338(a).
5. Martin has transacted business in the Commonwealth of Virginia,
including the Eastern District of Virginia, and has caused tortious injury in this
Commonwealth and District by an act or omission outside this Commonwealth and
derived substantial revenue from goods used or consumed in this Commonwealth and
District, by (a) establishing a network of authorized dealers, including AAC, Inc. of
Vienna, Virginia, and Shore Doors of Stevensville, Maryland with the intent and for the
purpose of selling Martin garage doors to persons in this Commonwealth and District,
and by (b) selling Martin garage doors that infringe one or more FrenchPorte Patents to
persons in this Commonwealth and District through its "DESIGN ONLINE" website tool
and its authorized Martin Dealers and through DirectBuy to persons in this
Commonwealth and District.
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6. Martin has offered for sale and sold residential aluminum doors in the
Commonwealth of Virginia which infringe the FrenchPorte patents as described below,
including the Eastern District of Virginia, ever since their launch in late 2007. Martin has
sold approximately 20 residential aluminum garage doors in the Commonwealth of
Virginia for between $60,000 to $200,000 depending primarily on whether the doors sold
were single or double doors. The precise numbers of doors sold by Martin in the
Commonwealth of Virginia and the Eastern District of Virginia, their actual size, and
their exact selling price(s), will be determined after FrenchPorte is afforded a reasonable
opportunity for further investigation and discovery.
7. DirectBuy has transacted business in the Commonwealth of Virginia,
including the Eastern District of Virginia, and has caused tortious injury in this
Commonwealth and District by an act or omission outside this Commonwealth and
derived substantial revenue from goods used or consumed in this Commonwealth and
District, by (a) establishing a network of DirectBuy stores in this Commonwealth and in
this District, including DirectBuy of Hampton Roads, DirectBuy of Richmond, and
DirectBuy of Woodbridge, in part with the intent and for the purpose of selling Martin
garage doors to persons in this Commonwealth and District, and by (b) selling Martin
garage doors that infringe the '032 Patent to persons in this Commonwealth and District
through directbuy.com and through its DirectBuy stores in Virginia to persons in this
Commonwealth and District.
8. The precise numbers of doors sold by DirectBuy in the Commonwealth of
Virginia and the Eastern District of Virginia, their actual size, and their exact selling
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price(s), will be determined after FrenchPorte is afforded a reasonable opportunity for
further investigation and discovery.
9. Venue is proper in this District and Division, under 28 U.S.C. §§ 1391 and
1400. Martin and DirectBuy reside within this District.
Factual Background
10. The FrenchPorte Patents are directed to overhead garage doors that look
just like French doors. An example from FrenchPorte’s website is reproduced below:

(Ex. B at 1).
11. While this garage appears to have three sets of French doors, in fact, as an
interior shot of the rightmost door of this same garage shows, the FrenchPorte garage
doors roll up into the ceiling on tracks just like a standard garage door:

(Ex. C at 1).

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12. Accordingly a FrenchPorte garage is difficult to recognize as a garage at
all as the following picture illustrates:

(Ex. D at 1).
13. While this picture appears at first glance to be a series of French doors
leading onto a patio, in fact it is actually the front of a four-car garage, which becomes
clear when one of the FrenchPorte garage doors is raised into the ceiling on its tracks:

(Ex. E at 1).
14. The FrenchPorte garage doors are the inventions of Ms. Jennifer Maher, a
well-regarded make-up artist who has made up the faces of Cokie Roberts, Leonardo de
Caprio and Bill Clinton prior to their appearances on ABC News. (Ex. F at 1).
15. Ms. Maher got the idea for FrenchPorte garage doors while house-hunting
in the late 1990s, where she found standard garage doors looked “like big ugly boxes just
plopped on the front of homes.” (Ex. G at 1). The problem bothered her for months.
Then, one day, Ms. Maher visited a development of new houses, where the model home’s
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garage had been set up as a temporary office, and the garage door had been replaced with
French doors. (Ex. F at 1). When Ms. Maher inquired if she could buy a house with these
doors, the builder told her “that the situation was only temporary and that they would be
reinstalling that ugly garage door as soon as the house was sold.” (Ex. F at 1).
16. Ms. Maher was not deterred, however. As she recalls thinking at the time,
“how hard would it be . . . to make a garage door that was attractive – one that looked
like a French door but still operated as an overhead door?” (Ex. G at 1). Ms. Maher
quickly found out the answer to her question: much harder than she initially thought.
17. The first problem Ms. Maher ran into is that while she found conventional
garage doors “ugly”, the “mostly male garage-door dealers” who dominated the industry
didn’t see them that way. (Ex. G at 1). Moreover, these same dealers were concerned
about the cost of a garage door that looked like a French door. A conventional garage
door cost $1000, and garage door dealers knew how to sell garage doors at that price.
(Ex. H at 2). But they worried that a garage door that looked like a French door would be
significantly more expensive, and possibly cost multiples of a conventional garage door.
So they wanted to know: How much more would it cost? And would anyone pay that
much for a garage door? Until Ms. Maher could answer those questions, she knew her
idea was going nowhere.
18. Accordingly, Ms. Maher investigated the matter and, needless to say, her
investigations took some time. Ms. Maher is a make-up artist, not an engineer and
indeed, before her work on the FrenchPorte garage door, she’d never worked with an
engineer before in her life. So while she retained patent counsel and filed a number of
patent applications on her designs starting in January 2000, she still needed to know:
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could it be done? Could she design a garage door that not only looked beautiful on
paper, but also could be built and sold for a price people were willing to pay?
19. To answer these questions, some 21 months after Ms. Maher filed her first
design patent application, Ms. Maher entered into an NDA with Innovative Design
Solutions, Inc. (“IDS”) (Ex. I at 1). She commissioned IDS to make a prototype of
“FRENCH PORT DOORS” to be constructed out of “wood or other material” with panes
of “polycarbonate or other material inserted and arranged in a way to give the appearance
of French Doors in place of the garage door while retaining the ability to function in the
same way as a standard garage door.” (Ex. I at 1). As that makes clear, at that time it
was still not clear what materials would be used to make even this one of a kind
prototype, let alone what could be used in a manufactured version of the FrenchPorte
doors. (Ex. I at 1).
20. It took nearly six months of work, but by late January 2002, Ms. Maher
and IDS working closely together had produced a full scale prototype of a FrenchPorte
garage door. (See Ex. J and K). Two months later, Ms. Maher filed her first utility patent
application on the FrenchPorte doors, leading ultimately to the issuance of the '547 patent
based on the United States Patent and Trademark Office’s expert assessment that Ms.
Maher had invented a truly new, non-obvious garage door. (Ex. L at 1).
Response to the FrenchPorte Door
21. Although most garage door dealers remained very skeptical even after Ms.
Maher produced her prototype, she took heart from the fact that at least “their wives
‘immediately got it’.” (Ex. G at 1). Still, she knew she needed more than just a
prototype: she needed a manufacturer and market recognition to show that she was right.
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The only way to prove that people would pay for a FrenchPorte door was to launch the
door as a commercial product, have it succeed on a small scale, and then attract a larger
manufacturer who would partner with FrenchPorte to market the door properly. Ms.
Maher’s husband, Ken Maher, believed in the project and, to help Ms. Maher realize her
vision, succeeded Ms. Maher as FrenchPorte’s CEO at this time, adding his business
expertise from running a successful mortgage business to Ms. Maher’s design talents.
22. In the summer of 2003, FrenchPorte hired Alto Garage Door
Manufacturing to develop and manufacture FrenchPorte Garage Doors. (Ex. M at 1).
These manufactured FrenchPorte doors were shown for the first time at the International
Builder’s Show in Las Vegas, Nevada in January 2004, and over a thousand attendees
expressed interest in the door. (Ex. M at 1). FrenchPorte also caught the attention of
HGTV at the show, who interviewed Ms. Maher (Ex. M at 1) and named the FrenchPorte
door one of HGTV’s “100 Best Innovative Ideas” that year. (Ex. F at 1; Ex. H at 1).
Once the HGTV segment of Ms. Maher and her door aired on HGTV, inquiries from
potential customers started rolling in as to how to obtain the door and at what price. (See
Ex. M at 1). What FrenchPorte learned was that, with FrenchPorte’s sole manufacturer
being based in the United States, the price unfortunately was still more than most
customers were willing to pay. (See Ex. M at 1-2).
23. By mid 2005, however, FrenchPorte reached a manufacturing agreement
with Hangzhou Legend Autodoor Factory in China, which considerably lowered the cost
of the FrenchPorte doors. (Ex. M at 2). FrenchPorte also entered into a distribution
agreement with A-Tech in August 2005, a large garage door distributor located in
Palmer, Pennsylvania. (Ex. M at 2.) A-Tech had a network of approximately 1,500
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dealers in the east. (Ex. M at 2). Wholesale revenue climbed to $350,000 in 2006. (Ex.
G at 1). FrenchPorte continued to invest heavily in innovation, leading that same year to
the invention by Ms. Maher and Mr. Ni of Hangzhou in China of a pinch-resistant
apparatus that prevented fingers from being injured in FrenchPorte’s doors. (Ex. N at 1).
FrenchPorte Initiates a Promising Relationship with Martin Door
24. Even with these successes, however, given A-tech’s East Coast focus,
FrenchPorte saw the need to partner with additional companies to strengthen their mid-
western and western network, as well as to potentially gain access to just in time
manufacturing facilities in the United States to lower inventory requirements.
FrenchPorte accordingly reached out to Martin Door of Salt Lake City, Utah, a then 70-
year old, well-established garage door manufacturer and distributor with deep roots in the
Midwest and West, which sold its doors in over 80 countries as well as to hundreds of
Martin dealers in the U.S. (Ex. O at 1-2).
25. After initial overtures, on May 2, 2006, FrenchPorte Vice President Roger
Davis, FrenchPorte Consultant Sam Bunch, and FrenchPorte Distributor A-Tech’s COO,
Scott Schmidt, met in Salt Lake City with David Martin, Chairman and CEO of Martin
Door, along with David Haslam, Martin Door’s Director of Sales and Marketing, and
Robert Scott, Martin Door’s Chief Engineer. (Ex. P at 1).
26. At that meeting, FrenchPorte was given a tour of Martin’s 500,000 square
foot facility which was “impressive and very clean and well organized.” (Ex. P at 1).
After the tour, FrenchPorte “displayed our pinch resistance extrusion design and door
sample.” (Ex. P at 1). The “Martin group of David Martin, David Haslam and Robert
Scott reviewed the pinch resistance operation of the door.” (Ex. P. at 1). They “all
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seemed genuinely interested with the sample.” (Ex. P at 1). After the meeting adjourned
to a conference room, questions arose as to “whether the Martin hinge and roller carriage
would work.” (Ex. P at 2). At that point, “David Martin suggested that we disassemble
our sample and see how a reversed Martin hinge would work.” (Ex. P at 2). “John
McLaughlin, a Sales Manager with Martin assisted in the effort.” (Ex. P at 2). A
detailed manufacturing and engineering analysis was conducted following the
disassembly, (Ex. P at 2-3), and at the conclusion “[a]ll parties agreed that numbers
would need to be crunched to determine if this would be feasible.” (Ex. P at 3).
However, “Martin’s engineer was very positive that it would work,” but “[t]he question
remains as to whether the price point would still make the door sellable.” (Ex. P at 3).
27. Further discussions were held regarding testing to show that FrenchPorte
doors would comply with Florida regulations requiring doors to withstand 150 mph
winds, a “very severe test.” (Ex. P. at 3). FrenchPorte agreed that “Martin would take
the 3 samples from A-Tech . . . after the show in Las Vegas to begin cycle testing.” (Ex.
P at 3). Martin “agreed to collaborate with FrenchPorte in the elevation and extrusion
modification to the door.” (Ex. P at 4). David “Martin executed a confidentiality
agreement when presented by FrenchPorte.” (Ex. P at 4). FrenchPorte “agreed to
provide Martin with shop drawings and possibly a CAD file of the drawings as soon as
possible . . . .” (Ex. P. at 4). However, both parties agreed that the Florida test could “be
accomplished with tweaking the exiting [sic – existing] design.” (Ex. P at 4).
28. Martin then “expressed interest in possibly replacing their existing
Silverline Door Model with FrenchPorte.” (Ex. P at 4). This was very attractive to
FrenchPorte, of course, because after all if “Martin manufacturers [sic] the door, the
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design, style, color and consumer choices could be endless.” (Ex. P. at 4). As for
Martin’s perspective, “[b]ecause of the uniqueness of the door design, David Halsom [sic
– Haslam] believes Atlanta (Home Depot) would be doing back flips for the opportunity
to supply this door at their stores.” (Ex. P. at 4).
29. The parties then turned to a detailed discussion of patents. At the outset
“David Martin educated us as too [sic] Martin’s some 60 patents.” (Ex. P at 4). He said
“every door manufacture [sic] has and is infringing on his patents.” (Ex. P at 4). He
“used an example over an infringement by Overhead Door.” (Ex. P at 4). The “cost to
litigate would be prohibitive for the return.” (Ex. P at 4). He “could not even get
Overhead Door to pay $1.00 a door for Martin’s door seal design.” (Ex. P at 4).
30. He also “informed us that four known companies in China is [sic] actually
using Martin’s name and his picture to promote a knock-off all of their design without
their permission.” (Ex. P at 4). When “consulting with the authority, they informed him
that it was a loosing [sic] battle.” (Ex. P at 4). His “other example was of 1,000 plus
companies copying NOKIA phones and NOKIA not being able to do anything about it.”
(Ex. P at 4).
31. As Roger Davis then observed, “[t]he idea being made that a patent is
important in this country if put to market quickly, because a good design patent can be
slightly modified and may not be ruled an infringement.” (Ex. P at 4). “However,
FrenchPorte’s utility patent would make it very difficult for infringement.” (Ex. P at 4).
32. Following the meeting, A-Tech’s COO “thought our visit was very
successful.” (Ex. P at 5). Dialogue “had been accomplished and the pinch resistance
design was well received by Martin Door.” (Ex. P at 5). The collaboration “between
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Martin, A-tech and FrenchPorte could provide a very unique opportunity for all parties.”
(Ex. P at 5).
The Collaboration with Martin Fails and
Martin Launches the Avignon French Door

33. Despite its promising beginning and significant efforts by all parties to
follow through on the many fronts identified in the high-level May 2, 2006 discussion of
collaboration, over time Martin became less and less responsive, until by 2007 Martin
was no longer even returning phone calls from FrenchPorte’s CEO, Ken Maher.
34. Still, notwithstanding the disappointing and never-explained end of their
potential collaboration with Martin, 2007 overall proved to be otherwise an excellent year
for FrenchPorte, with wholesale revenue tripling from 2006 to over $1 million. (Ex. G at
1). FrenchPorte opened its first showroom to the public that same year, and was having
successful discussions with other large garage door manufacturers. (Ex. M at 2). After
years of hard work by the Mahers and millions of dollars of their own savings invested in
the venture, FrenchPorte looked finally poised to attract a larger manufacturer.
35. In 2009, however, it finally became clear why Martin had ceased
collaborating with FrenchPorte. That year, Martin, launched the “Avignon Garage
Door,” which “features a French-style” (hereinafter Martin’s Avignon French doors) in
late 2009:
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(Ex. Q at 1). Martin in fact featured this door on the front page of its August 2009,
“Martinews” newsletter, distributed to “86 Countries of the World,” under the head-line
“Avignon . . La Belle!”, the latter being French for “the beautiful.” (Ex. Q at 1). Martin
also helpfully noted that “[t]he Avignon is named after a city in southern France famous
for being the home of seven Catholic popes in the period from 1305 to 1378.” (Ex. Q at
2).
36. Martin further praised the design, quoting David Haslam saying “It’s a
new look and a new approach for the garage door market.” (Ex. Q at 2). And indeed it
was, as David Haslam knew full well by learning of this new design and new approach at
the May 2, 2006 meeting with FrenchPorte. (Ex. P at 1). Needless to say, Martinews
made no mention that this “new look and . . . new approach” was presented to them by
FrenchPorte in good faith years earlier. (Ex. P at 1).
37. Still, Martin apparently became somewhat concerned that the Avignon
brand might be too similar to FrenchPorte and thus re-branded the door “the Athena,”
ironically according to Wikipedia the Greek goddess of “wisdom . . . law and justice, just
warfare . . . strength, strategy, the arts, crafts and skill.” Notwithstanding the rebranding,
the identical Avignon French door design is sold to this day:
August 2009
Beautiful New Designs
ISO 9001
Quality
Standard
MARTIN DOOR MFG.
ISO 9001 A8949 R
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GARAGE DOORS
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MARTINEWS


Martinews is Distributed to 86 Countries of the World Martinews is Distributed to 86 Countries of the World
MARTIN DOOR MFG., SLC, UT 1-800-388-9310 801-973-9310 www.martindoor.com © Copyright 2009 AD-NR50-42 MARTIN DOOR MFG., SLC, UT 1-800-388-9310 801-973-9310 www.martindoor.com © Copyright 2009 AD-NR50-42
Martin Door Manufacturing has added
two new garage door styles, to its
expanding list of garage door options.
The company will begin the Avignon (ä-
ven-yô) Garage Door, which features a
French-style, and also a unique flushline-
style door, known as the Kensington
Garage Door, effective immediately. Both
doors will be offered with a powder coat
finish only.
The Avignon comes in a variety of glass
options and is a sectional garage door,
designed to look like a swinging door.
The Kensington is a hybrid garage door

continued on page 2...
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14

(Ex. R at 2). The term “Martin’s Avignon French doors” accordingly will be used herein
to refer both to the original Avignon door as well as all of the garage door designs
currently sold by Martin under the Athena brand.
38. Martin’s Avignon French doors infringe FrenchPorte’s '547 Patent, as can
be seen by comparing Claim 1 of FrenchPorte’s '547 patent to the models of Martin’s
Avignon French door described in Exhibit R, Martin’s online catalog for these garage
doors.
39. Claim 1 of the '547 Patent first requires that the garage door be “[a]n
overhead garage door adapted to be suspended horizontally when open and incorporating
decorative elements of a house façade, the door having a front side, a rear side and a
height, the front side forming an exterior façade having the appearance of a plurality of
adjacent doorways . . .” (Ex. L at col. 6, ll. 39-44). All of Martin’s Avignon French doors
are overhead garage doors that are adapted to be suspended horizontally when open. (See
Ex. S at 1, 2). Martin’s Avignon French doors also “incorporate[e] decorative elements
of a house façade” as, indeed even Martin admits by touting them as both “beautiful” and
by noting they are “a sectional garage door, designed to look like a swinging door.” (Ex.
Q at 1). Finally, Martin’s Avignon French doors, like all doors, have “a front side, a rear
side and a height”, and their front side forms “an exterior façade having the appearance of
a plurality of adjacent doorways.” (Ex. Q at 1). Here again, Martin promoted these doors
upon their launch as “a sectional garage door, designed to look like a swinging door.”
10/16/13 3:06 PM Martin Garage Doors | Garage Doors
Page 2 of 3 http://www.martindoor.com/residential/garage-doors/david-o-martin-collection/athena/
Ponel 5tyles
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(Ex. Q at 1). Martin’s Avignon French doors therefore meet all of these requirements of
Claim 1.
40. Claim 1 of the '547 Patent next requires that the garage door have at least
“three longitudinal sections arranged in a stack . . . .” (Ex. L at col. 6, ll. 46). All models
of Martin’s Avignon French doors are made up of at least three longitudinal sections
arranged in a stack. (See Ex. S at 2). Martin’s Avignon French doors therefore also meet
these additional requirements of Claim 1.
41. Claim 1 of the '547 Patent next requires a “first”, “second” and “third”
array of “impact resistant, light-transmitting . . . panels formed in the three longitudinal
sections, the . . . array extending vertically more than half the height of the door, the . . .
array including a [1st][3rd][5th] vertical stack of light-transmitting panels and a
[2nd][4th][6th] vertical stack of light-transmitting panels, the [1st][3rd][5th] vertical
stack being horizontally spaced apart from the [2nd][4th][6th] vertical stack by a
[1st][2nd][3rd] gap.” (Ex. L at col. 6, ll. 47-67, col. 7, ll. 1-3). That is, the garage door
must have at least the following “impact resistant, light-transmitting . . . panels”:

Figure 1
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42. Claim 1 further requires a “first” and “second” vertical column “formed
by portions of the three longitudinal sections disposed within a . . . horizontal space
between the [1st][2nd] array and the [2nd][3rd] array, the . . . vertical column being wider
than the . . . gaps.” (Ex. L at col. 7, ll. 4-14). This leads to the additional “vertical
column” requirements set forth in Figure 2 below:

Figure 2
43. As can be seen, the first and second vertical columns depicted in Figure 2
are, as required by '547 Patent claim 1, disposed in a “horizontal space” between the first,
second and third arrays (themselves “including” at least the six requisite vertical stacks of
light-transmitting panels), and both of these vertical columns are “wider”, as required,
than all three of the requisite gaps. (See Figure 2).
44. The Martin Avignon French doors likewise have light-transmitting
panel[s] that make up the requisite six vertical stacks in three longitudinal sections, which
make up more than half the height of the door, and then form three gaps and two
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columns, where the two columns are larger than all of the three gaps. (Ex. Q at 1). For
example, the original Avignon door meets these requirements of Claim 1 of the '547
Patent as can be seen from the diagram below:

Figure 3
45. Indeed, six of the sixteen Martin Avignon French door designs have these
required elements of Claim 1 of the '547 Patent. (Ex. R at 2 (see Styles 215, 237, 235,
218, 236 and 238)). While four of these styles have a thicker central vertical column, and
at least two other vertical columns, these styles infringe to the same extent as Style 237
(the original Avignon door) because these vertical columns are only required to be wider
than the three requisite gaps. (Ex. L at col. 7, ll. 4-14). The remaining ten Martin
Avignon French doors, however, lack the required second “vertical column” and
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therefore do not literally infringe Claim 1 of the '547 Patent, although many of these
doors do infringe FrenchPorte’s '032 patent, as well as a number of the FrenchPorte
design patents, as further explained below. (Id.)
46. Likewise, the Martin Avignon French doors have “light-transmitting”
panels in the configurations required by '547 Patent claim 1, when they are sold with any
of the four “Window Tint” or Laminate Glass Options, (Ex. R at 2-3), all of which
glasses are depicted by Martin as transmitting light when samples of these glasses are
displayed against a red-flower background, (Ex. R at 3). As Martin warrantees its garage
doors for 5 years (Ex. R at 1) and would also be liable for any injury its garage doors
might cause, these light-transmitting panels are also “impact resistant” as further required
by '547 Patent claim 1.
47. '547 Patent claim 1 further requires the claimed garage door to have “a
plurality of guide rollers.” (Ex. L at col. 7, ll. 15). As Martin “doesn’t cut corners or
scrimp on the hardware for the world’s best garage door,” Martin’s Avignon French
doors have rollers most likely for the two interior longitudinal sections, as well as at the
top and bottom of the door, without which the door would not remain on the track. (Ex.
S at 1). With at least two rollers and more likely four, Martin’s Avignon French doors
have the requisite “plurality of guide rollers” and therefore meet this element of Claim 1
as well.
48. Finally, '547 Patent claim 1 requires that “said light-transmitting panels
permit light from the front side to transmit through the door to the rear side,” (Ex. L at
col. 7 at ll. 16-18), which all of the options available meet, as discussed above in detail.
See, supra, ¶ 42. '547 Patent claim 1 further requires that the “arrays be[] arranged on
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 18 of 38 PageID# 474
19
said exterior facade to simulate adjacent, light transmitting doorways” (Ex. L at col. 7 at
ll. 18-19), which, as discussed previously, they do. See, supra, ¶ 35. Finally, Claim 1
requires “said impact resistant light-transmitting panels in conjunction with said vertical
columns provide the functionality of structural integrity for the garage door.” (Ex. L at
col. 7 at ll. 20-22). These requirements are also met because Martin stands by the safety
and structural integrity of its Avignon French doors, (Ex. S at 1), and specifically
warranties its products against defects for 5 years, (Ex. R at 1).
49. Accordingly, for all of these reasons, Martin’s Avignon French doors
infringe at least Claim 1 of the '547 patent.
50. DirectBuy may offer Martin’s Avignon French doors for sale, but as
DirectBuy is a members only club, and very limited information regarding the Martin
doors DirectBuy sells is available to the public, FrenchPorte needs to explore the exact
models offered by DirectBuy through discovery to assess infringement of the '547 patent
by DirectBuy.
Martin’s Infringement of the '032 Patent
51. In addition to infringing at least Claim 1 of the '547 patent, Martin’s
Avignon French doors also infringe at least Claim 1 of the '032 Patent, as do all of
Martin’s Residential Aluminum Doors.
52. In 2004, prior to meeting with FrenchPorte, Martin made only steel and
wood doors, which used Martin’s FingerShield to protect children’s fingers from being
injured in doors:
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 19 of 38 PageID# 475
20

(Ex. T at 23).
53. In late 2007, however, after meeting with FrenchPorte and seeing
FrenchPorte’s aluminum door sample, Martin began offering residential aluminum doors,
which used a new device to protect against finger injury for these doors:

54. Martin’s Aluminum FingerShield joint infringes Claim 1 of the '032
patent, as can be seen by reference to a photograph of this joint, which will be
progressively annotated to illustrate infringement. First, the original photograph:
#1 DOOR SECTION
(BOTTOM DOOR SECTION)
OPTIONAL PUNCHED
ANGLE TRACK HANGER
COUPLER
TORSION
SPRING
BLACK
SPRING WINDING CONE
CENTER BEARING
BRACKET
GREY STEALTH PLUGS
OR RED SAFETY CAPS
RED
SPRING WINDING CONE
BOTTOM
WEATHER SEAL
BOTTOM
REINFORCING ANGLE
VERTICAL
TRACK
TRACK
BRACKET
FLAG
ROLLER SHIELD™
AND ROLLER
SIDE SPRING
ANCHOR BRACKET
SPLICE
PLATE OR
SPLICE
BRACKET
LOCK-ON SIDE
BEARING BRACKET
BLACK
CABLE DRUM
HORIZONTAL
TRACK
HORIZONTAL
TRACK ANGLE
RED
CABLE DRUM
TOP ROLLER
BRACKET
#3 ROLLER
BRACKET
AND HINGE
#2 ROLLER
BRACKET
AND HINGE
#1 ROLLER
BRACKET
AND HINGE
INSULATED DOOR
LIFT HANDLE
SPRING
ANCHOR CONE “L” STRUT
LIFT
CABLE
ROLLER SHIELD
AND ROLLER
LOW PROFILE
HINGES
INSULATED DOOR
LIFT HANDLE
CENTER STILE
END STILE
VERTICAL SLOT
LATCH HOLE
REVERSE ANGLE
OR REVERSE
BRACKET SHIELD
LOCK-ON BOTTOM ROLLER BRACKET
(SCREWS REQUIRED TO LOCK-ON
TO BOTTOM OF WOOD DOORS)
PACKET FOR OWNERS
DOOR AND OPENER
INSTRUCTION MANUALS
#2 DOOR SECTION
#3 DOOR SECTION
#4 DOOR SECTION
(TOP DOOR SECTION)
FOR OPTIONAL
3“ - 6” (51 - 102)
TRACK EXTENSIONS
SEE PAGE 11
FOR OPTIONAL SIDE
LATCH SEE PAGE 16
HOLES FOR OPTIONAL
CENTER LOCK
HOLES FOR OPTIONAL AUTOMATIC
DOOR VAULT RELEASE
TORSION TUBE
HORIZONTAL
TRACK
COPYRIGHT © 2004 MARTIN DOOR 23
FASTEN PACKET TO
WOOD DOOR WITH
SCREWS PROVIDED
MARTIN FINGER SHIELD™ GARAGE DOOR SYSTEM*
•SAFETY SECTION ASSEMBLY •SAFETY TRACK ASSEMBLY •SAFETY SPRING ASSEMBLY
HELPS PREVENT GARAGE DOOR INJURIES TO CHILDREN AND ADULTS
*
o P f e o l L w r i
e in H g
r Shi nge l i e d F
M T
FI GER SHIELDS N
RE STA DA D O DO S A N R N OR
UP TO 9’ (2740) IGH H
r

D
o
o
D
r

o
o
STEEL DOOR
ALL HINGES FASTEN FACE
DOWN ON WOOD DOORS,
FACE UP ON STEEL DOORS.

D
o
r
o
o P f e l L w ro i
n e i g H
r

D
o
o
SA ER F NGER SHIEL F I D
OINT ARE STANDAR ON J S D
WOODS D RS OO
WOOD DOOR
nge el Fi d r Shi
e J i nt ct on i S o
M T
#1 DOOR SECTION
(BOTTOM DOOR SECTION)
OPTIONAL PUNCHED
ANGLE TRACK HANGER
COUPLER
TORSION
SPRING
BLACK
SPRING WINDING CONE
CENTER BEARING
BRACKET
GREY STEALTH PLUGS
OR RED SAFETY CAPS
RED
SPRING WINDING CONE
BOTTOM
WEATHER SEAL
BOTTOM
REINFORCINGANGLE
VERTICAL
TRACK
TRACK
BRACKET
FLAG
ROLLER SHIELD™
AND ROLLER
SIDE SPRING
ANCHOR BRACKET
SPLICE
PLATE OR
SPLICE
BRACKET
LOCK-ON SIDE
BEARING BRACKET
BLACK
CABLE DRUM
HORIZONTAL
TRACK
HORIZONTAL
TRACK ANGLE
RED
CABLE DRUM
TOP ROLLER
BRACKET
#3 ROLLER
BRACKET
AND HINGE
#2 ROLLER
BRACKET
AND HINGE
#1 ROLLER
BRACKET
AND HINGE
INSULATED DOOR
LIFT HANDLE
SPRING
ANCHOR CONE “L” STRUT
LIFT
CABLE
ROLLER SHIELD
AND ROLLER
LOW PROFILE
HINGES
INSULATED DOOR
LIFT HANDLE
CENTER STILE
END STILE
VERTICAL SLOT
LATCH HOLE
REVERSE ANGLE
SHIELD OR REVERSE
BRACKET SHIELD
LOCK-ON BOTTOM ROLLER BRACKET
PACKET FOR OWNERS
DOOR AND OPENER
INSTRUCTION MANUALS
#2 DOOR SECTION
#3 DOOR SECTION
#4 DOOR SECTION
(TOP DOOR SECTION)
FOR OPTIONAL
3” - 6” (51 - 102)
TRACK EXTENSIONS
SEE PAGE 11
FOR OPTIONAL SIDE
LATCH SEE PAGE 16
HOLES FOR OPTIONAL
CENTER LOCK
HOLES FOR OPTIONAL AUTOMATIC
DOOR VAULT RELEASE
TORSION TUBE
HORIZONTAL
TRACK
COPYRIGHT © 2008 MARTIN DOOR 23
CURVE SHIELD
(ON DOORS UP
TO 8’ HIGH (2440)
BOTTOM WEATHER SEAL AND ANGLE INCREASES
DOOR HEIGHT ABOUT 3/4” (19)
CONTROLLED
DESCENT DEVICE
MARTIN FINGER SHIELD™ GARAGE DOOR SYSTEM*
• • • SAFETY SECTION ASSEMBLY SAFETY TRACK ASSEMBLY SAFETY SPRING ASSEMBLY
HELPS PREVENT GARAGE DOOR INJURIES TO CHILDREN AND ADULTS
*
Low Profile
Hinge
Finger Shield
TM
FINGER SHIELDS ARE
STANDARD ON STEEL/COPPER
DOORS UP TO 9’ (2740) HIGH
D
o
o
r
D
o
o
r
ALL HINGES FASTEN FACE
DOWN ON ALUMINUM DOORS
UP TO 9’(2740) HIGH.
D
o
o
r
Low Profile
Hinge
D
o
o
r
FINGER SHIELD JOINTS
ARE STANDARD ON
ALUMINUM DOORS
Finger Shield
Section Joint
TM
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 20 of 38 PageID# 476
21

(Ex. U at 22).
55. Claim 1 requires a “sectional overhead garage door, comprising: a first
door section; and a second door section, the first door section and the second door section
being configured to be hingedly attached to each other.” (Ex. N at col. 11, ll. 23-29).
Martin’s aluminum doors have two such sections which are hingedly attached to each
other. (Ex. U at 23).
56. Next, Claim 1 requires there to be an “upper rail being attached to the first
door section and having a front vertical leg, the front vertical leg having a rear face, and a
lower portion of the rear face forming a convex protrusion.” (Ex. N at col. 11, ll. 30-33).
These elements are present in all of Martin’s aluminum doors, as shown below:
1. Follow the regular Instruction Manual except the extruded aluminum
type door does not have clip-on Finger Shields. The Finger Shields are
designed into the aluminum door extrusion. Stack sections following
Aluminum Door Section Placement Chart. See page 2.
2. For doors up to 9’(2740) high, fasten all low profile hinges “face
down” into the grooves provided in the horizontal rails with
3. Use reasonable care in fitting/stacking each Carriage House/Arch
Crest section over the clear polycarbonate finger shield inserts that are
screwed inside the vertical board/stile designs. See 2.
4. Install Lock-on BottomRoller Bracket as shown on page 4.
1/4” x1”
thread forming screws. Fasten to stiles and rails using the pre-drilled
1/8”(3) holes. See FIGURES 1 and 2.
FIGURE
See FIGURE4
For doors over 9’(2740) high,
fasten all low profile hinges regular “face up”.
5. For Antique Hinge, decide, level, mark, and drill one 1/8”(3) hole
through first aluminumextrusion in horizontal rail. See FIGURES3 and 4.
Attention! Do not drill through second aluminumextrusion.
EXTRUDED ALUMINUM TYPE DOORS
6. Fasten Antique Hinge with one (5/8”(17) long) stainless steel black screw
provided.
1/8”(3) holes
in the horizontal rail. 5/8”(17) long)
provided. See FIGURES3, 4 and 5
See FIGURE5
7. Level the Hinge with the Horizontal Rail, then drill the other three
Fasten the hinge with three additional (
stainless steel black screws
8. Decide, mark, drill, and fasten the remaining hinges and handles following the
completed door example.
FIGURE 1 FIGURE 2
CLEAR POLYCARBONATE
FINGER SHIELD INSERT
FINGER SHIELD JOINT
“OUTSIDE” CARRIAGE HOUSE ALUMINUM DOOR SECTION
VERTICAL
BOARD/STILE
SCREW
FINGER SHIELD JOINT
HORIZONTAL
RAILS
GROOVE
LOW
PROFILE
HINGE
“FACE DOWN”
“INSIDE” ALUMINUM DOOR SECTIONS UP TO 9’(2740) HIGH
FIGURE 5
FIGURE 3
TOP DOOR SECTION
(5/8” (17) LONG)
STAINLESS STEEL
BLACK SCREWS
EDGE OF
DOOR JAMB
HORIZONTAL
RAIL
1/2” (13) MINIMUM
STILE
FIGURE 4
ANTIQUE HINGE
SECOND
ALUMINUM
EXTRUSION
FINGER
SHIELD
STAINLESS
STEEL
BLACK
SCREW
COPYRIGHT © 2008 MARTIN DOOR 22
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 21 of 38 PageID# 477
22

57. Claim 1 next requires there to be a “lower rail being attached to the second
door section, the lower rail having a front face and a multiple arcuate surface on the front
face, the multiple arcuate surface having an upper convex portion, a concave portion
which mates with the upper rail convex protrusion . . . ” (Ex. N at col. 11, ll. 34-38).
These elements are also all present in all of Martin’s aluminum doors, as shown below:
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 22 of 38 PageID# 478
23

58. Claim 1 next requires that “the upper rail convex protrusion [be] extending
rearward into the concave portion of the lower rail and toward a front surface of the
overhead garage door when the first section and the second section are in a closed
position, and an inflection region between the upper convex portion and the concave
portion” (Ex. N at col. 11, ll. 38-43). These elements are also all present in all of
Martin’s aluminum doors, as shown below:
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 23 of 38 PageID# 479
24

59. Finally Claim 1 requires “the lower rail concave portion has a radius of
curvature smaller than a radius of curvature of the upper convex portion of the lower rail,
and the upper rail front vertical leg moves in a curvilinear manner to generally follow the
curvature of the upper convex protrusion during rotational motion of the upper and lower
rails.” (Ex. N at col. 11, ll. 44-49). These elements are also all present in all of Martin’s
aluminum doors, as shown below:
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 24 of 38 PageID# 480
25

60. Accordingly, Claim 1 of the '032 patent is infringed by all of Martin’s
residential aluminum doors. Claims 2 and 3 of the '032 patent are also infringed by all of
Martin’s residential aluminum doors as these require simply that the upper and lower rail
“comprise a metal material” and more specifically “aluminum.” (Ex. N at col. 11, ll. 50-
54). Martin’s rails are both metal and aluminum. (Ex. U at 22, 23).
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 25 of 38 PageID# 481
26
61. DirectBuy sells and offers for sale all of Martin’s current models of
residential aluminum doors. DirectBuy accordingly also infringes the '032 patent.
Martin Also Infringes FrenchPorte’s Design Patents
62. In addition to infringing the '547 and '032 patents, Martin’s Avignon
French doors also infringe the remainder of the FrenchPorte patents, namely the '495
Patent, the '979 Patent, the '142 Patent, the '143 Patent, the '736 Patent, the '241 Patent,
and the '585 Patent. All seven of these patents are design patents which, unlike a utility
patent such as the '547 Patent, have only a single claim that covers all of the figures in the
patent. The scope of the claim encompasses the design’s visual appearance as a whole.
All matter depicted in solid lines contributes to the overall appearance of the design,
whereas broken lines constitute unclaimed subject matter. To show infringement of these
patents, FrenchPorte must show that the overall appearance of Martin’s Avignon French
doors is substantially the same as the overall appearance of the claimed FrenchPorte
garage doors.
63. Like the '547 Patent, the '495 Patent, the '979 Patent, the '142 Patent, the
'143 Patent, the '736 Patent, the '241 Patent, and the '585 Patent all depict in their figures
and therefore claim overhead garage doors that look like swinging French doors.
Martin’s Avignon French doors are all garage doors that appear to be swinging French
doors and therefore they infringe the '495 Patent, the '979 Patent, the '142 Patent, the '143
Patent, the '736 Patent, the '241 Patent, and the '585 Patent. Indeed, as Martin concedes,
“the Avignon . . . Garage Door . . . features a French-style . . . . and is a sectional garage
door, designed to look like a swinging door.” (Ex. Q at 1). For that reason, the Martin
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 26 of 38 PageID# 482
27
Avignon French doors infringe the '495 Patent, the '979 Patent, the '142 Patent, the '143
Patent, the '736 Patent, the '241 Patent, and the '585 Patent.
64. DirectBuy may offer Martin’s Avignon French doors for sale, but as
DirectBuy is a members only club, and very limited information regarding the Martin
doors DirectBuy sells is available to the public, FrenchPorte needs to explore the exact
models offered by DirectBuy through discovery to assess infringement of the '495 Patent,
the '979 Patent, the '142 Patent, the '143 Patent, the '736 Patent, the '241 Patent, and the
'585 Patent by DirectBuy.
FrenchPorte Suffers from Martin’s Infringement
65. Martin’s infringement had a devastating effect on FrenchPorte because of
Martin’s much greater size. Martin’s annual wholesale revenues are on the order of 100
times as much as FrenchPorte’s. With the FrenchPorte door itself a proven winner,
FrenchPorte’s marketing was simply no match for Martin’s promotion of its infringing
Avignon French door and Martin’s residential aluminum doors. FrenchPorte’s wholesale
revenues have shrunk from their peak in 2007 of over a million dollars a year back to
only a quarter of that height today at best. The Maher’s closed their showroom in 2009
and have operated their business out of their home ever since.
66. FrenchPorte accordingly comes now to this Court to obtain relief from
Martin and DirectBuy’s infringement, as otherwise the Maher’s dream of beautiful
FrenchPorte garage doors may well be realized, only not by them as the rightful
innovators, but instead by Martin and DirectBuy’s infringement of FrenchPorte’s patents.


Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 27 of 38 PageID# 483
28
Count 1 – Martin’s Infringement of U.S. Patent No. 6,948,547
67. FrenchPorte incorporates by reference the material factual allegations
above.
68. Martin has infringed and is continuing to infringe the '547 Patent by
engaging in acts including making, using, selling, or offering to sell within the United
States, products that embody the patented invention described and claimed in the '547
Patent, including Martin’s Avignon French garage doors.
69. Martin’s activities have been without express or implied license from
FrenchPorte.
70. Martin will continue to infringe the '547 Patent unless enjoined by this
Court. As a result of the Martin’s infringing conduct, FrenchPorte has suffered, and will
continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
71. As a result of the infringement of the '547 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Count 2 – Martin’s Infringement of U.S. Patent No. 7,857,032
72. FrenchPorte incorporates by reference the material factual allegations
above.
73. Martin has infringed and is continuing to infringe the '032 Patent by
engaging in acts including making, using, selling, or offering to sell within the United
States, products that embody the patented invention described and claimed in the '032
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 28 of 38 PageID# 484
29
Patent, including Martin’s Avignon French garage doors and Martin’s other residential
aluminum garage doors.
74. Martin’s activities have been without express or implied license from
FrenchPorte.
75. Martin will continue to infringe the '032 Patent unless enjoined by this
Court. As a result of the Martin’s infringing conduct, FrenchPorte has suffered, and will
continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
76. As a result of the infringement of the '032 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Count 3 – DirectBuy’s Infringement of U.S. Patent No. 7,857,032
77. FrenchPorte incorporates by reference the material factual allegations
above.
78. DirectBuy has infringed and is continuing to infringe the '032 Patent by
engaging in acts including using, selling, or offering to sell within the United States,
products that embody the patented invention described and claimed in the '032 Patent,
including Martin’s residential aluminum garage doors.
79. DirectBuy’s activities have been without express or implied license from
FrenchPorte.
80. DirectBuy will continue to infringe the '032 Patent unless enjoined by this
Court. As a result of the DirectBuy’s infringing conduct, FrenchPorte has suffered, and
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 29 of 38 PageID# 485
30
will continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
81. As a result of the infringement of the '032 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Count 4 – Martin’s Infringement of U.S. Patent D505,495
82. FrenchPorte incorporates by reference the material factual allegations
above.
83. Martin has infringed and is continuing to infringe the '495 Patent by
engaging in acts including making, using, selling, or offering to sell within the United
States, products that embody the patented invention described and claimed in the '495
Patent, including Martin’s Avignon French garage doors.
84. Martin’s activities have been without express or implied license from
FrenchPorte.
85. Martin will continue to infringe the '495 Patent unless enjoined by this
Court. As a result of the Martin’s infringing conduct, FrenchPorte has suffered, and will
continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
86. As a result of the infringement of the '495 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 30 of 38 PageID# 486
31
Count 5 – Martin’s Infringement of U.S. Patent D452,979
87. FrenchPorte incorporates by reference the material factual allegations
above.
88. Martin has infringed and is continuing to infringe the '979 Patent by
engaging in acts including making, using, selling, or offering to sell within the United
States, products that embody the patented invention described and claimed in the '979
Patent, including Martin’s Avignon French garage doors.
89. Martin’s activities have been without express or implied license from
FrenchPorte.
90. Martin will continue to infringe the '979 Patent unless enjoined by this
Court. As a result of the Martin’s infringing conduct, FrenchPorte has suffered, and will
continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
91. As a result of the infringement of the '979 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Count 6 – Martin’s Infringement of U.S. Patent D464,142
92. FrenchPorte incorporates by reference the material factual allegations
above.
93. Martin has infringed and is continuing to infringe the '142 Patent by
engaging in acts including making, using, selling, or offering to sell within the United
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 31 of 38 PageID# 487
32
States, products that embody the patented invention described and claimed in the '142
Patent, including Martin’s Avignon French garage doors.
94. Martin’s activities have been without express or implied license from
FrenchPorte.
95. Martin will continue to infringe the '142 Patent unless enjoined by this
Court. As a result of the Martin’s infringing conduct, FrenchPorte has suffered, and will
continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
96. As a result of the infringement of the '142 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Count 7 – Martin’s Infringement of U.S. Patent D464,143
97. FrenchPorte incorporates by reference the material factual allegations
above.
98. Martin has infringed and is continuing to infringe the '143 Patent by
engaging in acts including making, using, selling, or offering to sell within the United
States, products that embody the patented invention described and claimed in the '143
Patent, including Martin’s Avignon French garage doors.
99. Martin’s activities have been without express or implied license from
FrenchPorte.
100. Martin will continue to infringe the '143 Patent unless enjoined by this
Court. As a result of the Martin’s infringing conduct, FrenchPorte has suffered, and will
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 32 of 38 PageID# 488
33
continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
101. As a result of the infringement of the '143 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Count 8 – Martin’s Infringement of U.S. Patent D464,736
102. FrenchPorte incorporates by reference the material factual allegations
above.
103. Martin has infringed and is continuing to infringe the '736 Patent by
engaging in acts including making, using, selling, or offering to sell within the United
States, products that embody the patented invention described and claimed in the '736
Patent, including Martin’s Avignon French garage doors.
104. Martin’s activities have been without express or implied license from
FrenchPorte.
105. Martin will continue to infringe the '736 Patent unless enjoined by this
Court. As a result of the Martin’s infringing conduct, FrenchPorte has suffered, and will
continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
106. As a result of the infringement of the '736 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 33 of 38 PageID# 489
34
Count 9 – Martin’s Infringement of U.S. Patent D486,241
107. FrenchPorte incorporates by reference the material factual allegations
above.
108. Martin has infringed and is continuing to infringe the '241 Patent by
engaging in acts including making, using, selling, or offering to sell within the United
States, products that embody the patented invention described and claimed in the '241
Patent, including Martin’s Avignon French garage doors.
109. Martin’s activities have been without express or implied license from
FrenchPorte.
110. Martin will continue to infringe the '241 Patent unless enjoined by this
Court. As a result of the Martin’s infringing conduct, FrenchPorte has suffered, and will
continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
111. As a result of the infringement of the '241 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Count 10 – Martin’s Infringement of U.S. Patent D486,585
112. FrenchPorte incorporates by reference the material factual allegations
above.
113. Martin has infringed and is continuing to infringe the '585 Patent by
engaging in acts including making, using, selling, or offering to sell within the United
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 34 of 38 PageID# 490
35
States, products that embody the patented invention described and claimed in the '585
Patent, including Martin’s Avignon French garage doors.
114. Martin’s activities have been without express or implied license from
FrenchPorte.
115. Martin will continue to infringe the '585 Patent unless enjoined by this
Court. As a result of the Martin’s infringing conduct, FrenchPorte has suffered, and will
continue to suffer, irreparable harm for which there is no adequate remedy at law.
FrenchPorte is entitled to permanent injunctive relief against such infringement, under 35
U.S.C. § 283.
116. As a result of the infringement of the '585 Patent, FrenchPorte has been
damaged, will be further damaged, and is entitled to be compensated for such damages,
pursuant to 35 U.S.C. § 284, in an amount to be determined at trial.
Jury Trial Demand
117. FrenchPorte demands a trial by jury on all appropriate issues.
Prayer for Relief
Therefore, upon final hearing or trial, plaintiff FrenchPorte prays for the
following relief:
(a) A judgment that Martin has infringed the '547 Patent;

(b) A judgment that Martin has infringed the '032 Patent;

(c) A judgment that DirectBuy has infringed the '032 Patent;

(d) A judgment that Martin has infringed the '495 Patent;

(c) A judgment that Martin has infringed the '979 Patent;

(d) A judgment that Martin has infringed the '142 Patent;

Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 35 of 38 PageID# 491
36
(e) A judgment that Martin has infringed the '143 Patent;

(f) A judgment that Martin has infringed the '736 Patent;

(g) A judgment that Martin has infringed the '241 Patent;

(h) A judgment that Martin has infringed the '585 Patent;

(i) A judgment and order permanently restraining and enjoining Martin, its
directors, officers, employees, servants, agents, affiliates, subsidiaries,
others controlled by them, and all persons in active concert or participation
with any of them, from further infringing the FrenchPorte Patents;

(j) A judgment and order permanently restraining and enjoining DirectBuy,
its directors, officers, employees, servants, agents, affiliates, subsidiaries,
others controlled by them, and all persons in active concert or participation
with any of them, from further infringing the '032 Patent;;

(j) A judgment and order requiring Martin and DirectBuy to pay damages to
FrenchPorte adequate to compensate it for Martin’s wrongful infringing
acts, in accordance with 35 U.S.C. § 284 and 35 U.S.C. § 289;

(k) A judgment and order requiring Martin and DirectBuy to pay to
FrenchPorte pre-judgment interest under 35 U.S.C. § 284, and post-
judgment interest under 28 U.S.C. § 1961, on all damages awarded; and

(l) Such other costs and further relief, to which FrenchPorte is entitled.


Dated: J anuary 7, 2014 Respectfully submitted,


/s/
J ay M. McDannell, Esq. (VA #45630)
Potomac Law Group, LLP
1300 Pennsylvania Avenue, NW
Suite 700
Washington, D.C. 20004
Direct: (703) 718-0171
Fax: (202) 318-7707
jmcdannell@thepotomaclawgroup.com
Of Counsel:

Neil H. Koslowe
Potomac Law Group, LLP
1300 Pennsylvania Avenue, NW
Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 36 of 38 PageID# 492
37
Suite 700
Washington, D.C. 20004
Direct: (202) 508-8118
nkoslowe@potomaclaw.com

Geoffrey C. Mason, Esq.
Potomac Law Group, LLP
1300 Pennsylvania Avenue, NW
Suite 700
Washington, D.C. 20004
Direct: (202) 507-5720
gmason@potomaclaw.com


Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 37 of 38 PageID# 493



CERTIFICATE OF SERVICE

I hereby certify that on this 7th day of J anuary 2014, the foregoing Amended Complaint
was served via ECF on the following:


J effrey K. Sherwood
Dickstein Shapiro, LLP
1825 Eye Street NW
Washington, DC 20006
Telephone: (202) 420-2200
sherwoodj@dicksteinshapiro.com





/s/
J ay M. McDannell, Esq. (VA #45630)
Potomac Law Group, LLP
1300 Pennsylvania Avenue, NW
Suite 700
Washington, D.C. 20004
Direct: (703) 718-0171
Fax: (202) 318-7707
jmcdannell@potomaclaw.com

Case 1:13-cv-01329-TSE-TRJ Document 38 Filed 01/07/14 Page 38 of 38 PageID# 494
Exhibit A

Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 1 of 18 PageID# 495
10/16/13 2:29 PM Martin Garage Doors | Find a Dealer
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112 Saint Claire Place, Suite 201,
Stevensville, MD 21666
☎ 410-643-4903
Shore Doors
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Categories:AUTH
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Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 2 of 18 PageID# 496
Exhibit B

Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 3 of 18 PageID# 497
Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 4 of 18 PageID# 498
Exhibit C

Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 5 of 18 PageID# 499
Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 6 of 18 PageID# 500
Exhibit D


Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 7 of 18 PageID# 501
Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 8 of 18 PageID# 502
Exhibit E


Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 9 of 18 PageID# 503
Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 10 of 18 PageID# 504
Exhibit F

Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 11 of 18 PageID# 505
Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 12 of 18 PageID# 506
Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 13 of 18 PageID# 507
Exhibit G


Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 14 of 18 PageID# 508
Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 15 of 18 PageID# 509
Exhibit H

Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 16 of 18 PageID# 510
Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 17 of 18 PageID# 511
Case 1:13-cv-01329-TSE-TRJ Document 38-1 Filed 01/07/14 Page 18 of 18 PageID# 512
Exhibit I

Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 1 of 28 PageID# 513
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 2 of 28 PageID# 514
Exhibit J

Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 3 of 28 PageID# 515
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 4 of 28 PageID# 516
Exhibit K

Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 5 of 28 PageID# 517
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 6 of 28 PageID# 518
Exhibit L


Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 7 of 28 PageID# 519
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 8 of 28 PageID# 520
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 9 of 28 PageID# 521
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 10 of 28 PageID# 522
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 11 of 28 PageID# 523
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 12 of 28 PageID# 524
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 13 of 28 PageID# 525
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 14 of 28 PageID# 526
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 15 of 28 PageID# 527
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 16 of 28 PageID# 528
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 17 of 28 PageID# 529
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 18 of 28 PageID# 530
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 19 of 28 PageID# 531
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 20 of 28 PageID# 532
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 21 of 28 PageID# 533
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 22 of 28 PageID# 534
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 23 of 28 PageID# 535
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 24 of 28 PageID# 536
Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 25 of 28 PageID# 537
Exhibit M

Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 26 of 28 PageID# 538
1
FrenchPorte, LLC

FrenchPorte, LLC is a limited liability company which was formed in the State of Maryland in
February 25, 2000 for the purpose of producing and marketing a sectional garage door made to
resemble a series of French doors, but operating as a traditional overhead garage door.

The company was founded by Jennifer Maher of Chevy Chase, Maryland. While working as a
makeup artist for ABC News in Washington, D.C. Jennifer developed a personal philosophy that
nothing ever has to be unattractive. Based on this philosophy, Jennifer designed and patented the
garage doors that she believed would make the aesthetic look of a house more attractive with her
FrenchPorte garage doors.

To date, FrenchPorte has been granted 13 design patents and 1 utility patent in the United States,
2 design patents and 2 utility patents in Australia, 2 design patents and 1 utility patent in Canada,
3 design patents in the European Union, and 2 design patents in Korea. The “FrenchPorte” name
and FrenchPorte logo “FP” are registered trademarks in the United States, Canada, Europe and
Australia. Additionally there are 25 design patents pending and 11 utility patents pending in
various countries.

FrenchPorte currently has three styles of doors, the Madeleine, the Kendra and the Jennifer. The
significant difference is how the panes in the doors are proportioned with the number of vertical
stiles.

In the summer of 2003 a company called Alto Garage Door Manufacturing in Harrisburg,
Pennsylvania was hired to develop and manufacture FrenchPorte garage doors. Shortly there
after, FrenchPorte displayed a single and double Kendra Model garage door at a booth at the
International Builder’s Show in Las Vegas, Nevada in January 2004. During the previous
International Builder’s Show held in January 2003 FrenchPorte had a booth at the show that
displayed videos of the FrenchPorte garage door in animated action and received a lot interest.
However, with the actual doors on display, the attendees that visited the booth were very excited
and interested in the garage door and the data base created by visits to the booth was just over
1,000 entries.

Significant interest was also shown by Overhead Door Corporation, Amarr, Wayne Dalton,
Raynor, CHI Overhead Door, Clopay, 1st United Door and Menards for the FrenchPorte garage
door display at the show.. Meetings were held with all of these companies and we are very close
to developing a business relationship with each of them.

The display booth also caught the attention of HGTV (Home and Garden Television) at the
show. HGTV was looking to identify 10 of the best new products being displayed at the show
and selected FrenchPorte Garage Door as one of the products. HGTV interviewed and video
taped Jennifer Maher for a segment to be aired on one of their shows about the concept and
design of the FrenchPorte Garage Door. Once the spot was aired on HGTV inquiries from
potential customers started rolling in as to how to obtain the door and at what price.




Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 27 of 28 PageID# 539
2
In an effort to lower the selling price, FrenchPorte explored production alternatives. Contacts
were made with a garage door manufacturer in China. Several meetings were held with the
owner, Xinyan Ni, of the Hangzhou Legend Autodoor Factory in Hangzhou, China. A Patent and
Trademark License Agreement and an Exclusive Export and Manufacturing Agreement were
executed in May 2005 between FrenchPorte, LLC and Hangzhou.

FrenchPorte was finally in a position to offer a product line at a reasonable price to the market
place. FrenchPorte displayed the garage door at the The International Garage Door Exposition in
Orlando, Florida in April 2005. Many garage door manufacturers were impressed with the design
and showed interest in the door. Among those interested was A-tech Suburban, Inc., a large
garage door distributor located in Palmer, Pennsylvania. A-tech has a network of approximately
1,500 dealers in the east.

FrenchPorte entered into a distribution agreement with A-Tech in August 2005. Following the
execution of the agreement, A-tech issued a purchase order to FrenchPorte to buy a container of
each model of FrenchPorte garage doors. The first container of 128 units was shipped from
China in March of 2006 and the next two shipped in the months following.

The owners of FrenchPorte traveled to Germany to meet with the Hormann Company, the largest
garage door manufacturing company in the world. They are in the process of making extrusions
and have plans to manufacture market and sell the FrenchPorte garage doors and pay
FrenchPorte a royalty.

The FrenchPorte garage door must continually be promoted so that the customer is aware of our
product. FrenchPorte has advertised in many local and national publications as well as has been
featured on public television broadcasting commercials. As a result of this exposure we have
received an enormous amount of interest from homeowners from all across the country and
abroad. The owners of FrenchPorte are now ready to take our product to the next level and that
would be to open a local showroom with all three of our garage doors on display. We are very
excited about this endeavor and have leased space at 121 Congressional Lane in Rockville,
Maryland. We are anxiously awaiting the grand opening of our showroom to the public on June
1, 2007.

If approved for a Small Business Administration loan, Jennifer Maher and FrenchPorte plan to
do the following:

1. Launch an aggressive advertisement campaign to appeal to homeowner’s everywhere
2. Purchase the inventory needed to efficiently fill a customer’s order without the current
wait for the order to be placed.

The owner’s of FrenchPorte are confident that our product has the potential to capture a large
portion of the garage door industry and we plan to aggressively go after that market.

Case 1:13-cv-01329-TSE-TRJ Document 38-2 Filed 01/07/14 Page 28 of 28 PageID# 540
Exhibit N

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 1 of 65 PageID# 541
(12) United States Patent
Ni et a1.
US007857032B2
US 7,857,032 B2
Dec. 28, 2010
(10) Patent N0.:
(45) Date of Patent:
(54) OVERHEAD GARAGE DOOR
(75) Inventors: Xiao-Ming Ni, Zhejiang (CN); Jennifer
Armstrong Maher, Chevy Chase, MD
(Us)
(73) Assignee: Frenchporte IP, L.L.C., Rockville, MD
(Us)
( * ) Notice: Subject to any disclaimer, the term of this
patent is extended or adjusted under 35
U.S.C. 154(b) by 89 days.
(21) App1.No.: 11/277,466
(22) Filed: Mar. 24, 2006
(65) Prior Publication Data
US 2007/0175601 A1 Aug. 2, 2007
Related US. Application Data
(63) Continuation-in-part of application No. 11/328,454,
?led on Jan. 10, 2006, Which is a continuation-in-part
ofapplication No. 11/229,713, ?led on Sep. 20, 2005,
noW abandoned, Which is a continuation of application
No. 10/098,384, ?led on Mar. 18, 2002, noW Pat. No.
6,948,547.
(30) Foreign Application Priority Data
Mar. 13,2006 (CN) ...................... .. 2006 3 0105541
Mar. 13,2006 (CN) ...................... .. 2006 3 0105542
(51) Int. Cl.
E06B 3/48 (2006.01)
(52) US. Cl. ..................... .. 160/229.1; 160/40; 160/201
(58) Field of Classi?cation Search ............... .. 160/201,
160/235, 236, 40, 229.1; 49/383, 496.1,
49/483.1; 16/355
See application ?le for complete search history.
(56) References Cited
U.S. PATENT DOCUMENTS
3,221,465 A * 12/1965 McKee .................... .. 52/6564
5,133,108 A 7/1992 Esnault
5,148,850 A * 9/1992 Urbanick ............... .. 160/231.1
5,566,740 A 10/1996 Mullet et al.
5,626,176 A 5/1997 Lewis et al.
5,709,259 A 1/1998 Lewis et al.
5,782,283 A 7/1998 Kendall
5,857,510 A 1/1999 Krupke et al.
5,934,352 A 8/1999 Morgan
5,992,497 A 11/1999 Jaehnen et a1.
6,076,590 A 6/2000 Ford et al.
6,098,697 A 8/2000 Krupke et al.
(Continued)
FOREIGN PATENT DOCUMENTS
DE 10310628 A1 10/2004
(Continued)
OTHER PUBLICATIONS
International Search Report dated Nov. 21, 2007.
Primary ExamineriBlair M. Johnson
(74) Attorney, A gent, 0r FirmiBanner & Witcoff, Ltd.
(57) ABSTRACT
An overhead garage door has an apparatus for pinch resistant
operation. The garage door may include horizontal sections
and the door may be formed from a plurality of these sections,
arranged in a stack, and pivotally connected to adjacent sec
tions. The apparatus, such as meeting rails, may be attached to
adjacent horizontal sections to mask the appearance of a seam
created as adjacent sections are joined or provide pinch resis
tant operation.
12 Claims, 24 Drawing Sheets
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 2 of 65 PageID# 542
US 7,857,032 B2
Page2
U.S. PATENT DOCUMENTS 6,899,157 B2 5/2005 Mullet
6,935,400 B1 8/2005 Welsh
6,227,281 B1 5/2001 Martin 6,942,000 B2 9/2005 Hoerneretal.
6,328,091 B1 12/2001 Whitley 6,955,206 B2 10/2005 Mullet etal.
6363993 B1 4/2002 Aquilina 2003/0000656 Al* 1/2003 Zen .......................... .. 160/201
6,408,486 B1 6/2002 Saliba eta1~ 2004/0069421 A1 4/2004 Mullet
6,527,036 B1 3/2003 Welsh 2005/0269043 A1 12/2005 Welsh
6,578,619 B2 6/2003 Wright 2007/0175602 Al* 8/2007 Ni et a1. .................... .. 160/201
6,626,226 B2 9/2003 Whitley
6,629,387 B2 10/2003 Whitley et a1. FOREIGN PATENT DOCUMENTS
6,672,362 B1 1/2004 Mullet et a1. W0 9841723 9/1998
6,810,938 B2 11/2004 Aqulllna WO 2004029395 A2 4/2004
6,843,300 B2 1/2005 Mullet et a1.
6,883,578 B2 4/2005 Whitley * cited by examiner
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 3 of 65 PageID# 543
US. Patent Dec. 28, 2010 Sheet 1 0f 24 US 7,857,032 B2
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Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 4 of 65 PageID# 544
US. Patent Dec. 28, 2010 Sheet 2 0f 24 US 7,857,032 B2
16
FIG. 2
PRIOR ART
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 5 of 65 PageID# 545
US. Patent Dec. 28, 2010 Sheet 3 0f 24 US 7,857,032 B2
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 6 of 65 PageID# 546
US 7,857,032 B2
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Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 7 of 65 PageID# 547
US. Patent Dec. 28, 2010 Sheet 5 0f 24 US 7,857,032 B2
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 8 of 65 PageID# 548
US. Patent Dec. 28, 2010 Sheet 6 0f 24 US 7,857,032 B2
FIG. 6
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 9 of 65 PageID# 549
US. Patent Dec. 28, 2010 Sheet 7 0f 24 US 7,857,032 B2
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 10 of 65 PageID# 550
US. Patent Dec. 28, 2010 Sheet 8 0f 24 US 7,857,032 B2
2501/
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 11 of 65 PageID# 551
US. Patent Dec. 28, 2010 Sheet 9 0f 24 US 7,857,032 B2
MA
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 12 of 65 PageID# 552
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 13 of 65 PageID# 553
US. Patent Dec. 28, 2010 Sheet 11 0f 24 US 7,857,032 B2
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 14 of 65 PageID# 554
US. Patent Dec. 28 2010 Sheet 12 0f 24 US 7,857,032 B2
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Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 15 of 65 PageID# 555
US. Patent Dec. 28, 2010 Sheet 13 0f 24 US 7,857,032 B2
FIG. 15
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 16 of 65 PageID# 556
US. Patent Dec. 28, 2010 Sheet 14 0f 24 US 7,857,032 B2
\
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 17 of 65 PageID# 557
US. Patent Dec. 28, 2010 Sheet 15 0f 24 US 7,857,032 B2
FIG. 17
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 18 of 65 PageID# 558
US. Patent Dec. 28, 2010 Sheet 16 0f 24 US 7,857,032 B2
542
FIG. 18
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 19 of 65 PageID# 559
US. Patent Dec. 28, 2010 Sheet 17 0f 24 US 7,857,032 B2
662
FIG. 19
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 20 of 65 PageID# 560
US. Patent Dec. 28, 2010 Sheet 18 0f 24 US 7,857,032 B2
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FIG. 20
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 21 of 65 PageID# 561
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 22 of 65 PageID# 562
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 23 of 65 PageID# 563
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 24 of 65 PageID# 564
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 25 of 65 PageID# 565
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 26 of 65 PageID# 566
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 27 of 65 PageID# 567
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 28 of 65 PageID# 568
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 29 of 65 PageID# 569
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 30 of 65 PageID# 570
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 31 of 65 PageID# 571
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 32 of 65 PageID# 572
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 33 of 65 PageID# 573
Exhibit O

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 34 of 65 PageID# 574
10/17/13 11:00 AM Martin Garage Doors | History
Page 1 of 2 http://www.martindoor.com/about-us/history/
0ne 5ource, 0ne 0oor
lº3ó
Hortln 0verheod 0oors ls ïounded ln lº3ó ln 5onto Ano, CA by Leno Hortln. Leno lnvents
one oï the ïlrst one-plece overheod type goroge doors. 1he lnventlon oï the one-plece
overheod type door beglns to reploce the populor swlnglng door.
lº/2
world wor ll denles occess to steel ond wood needed to moke goroge doors. 1he ïlrm
moves to 5olt Loke Clty where lt hos ïomlly tles.
lº5l
0ovld 0. Hortln, younger brother oï Leno, buys buslness ïrom hlm due to Leno hovlng
serlous heolth problems.
lºóû
Hortln chonges lts emphosls ïrom one-plece goroge doors to sectlonol goroge doors.
lº7ó
Hortln develops ldeo ond deslgn ïor rolsed ponel steel sectlonol doors.
lº77
Hortln beglns moklng sectlonol goroge doors oï roll-ïormed pre-polnted, hot-dlpped
golvonlzed steel. Pl-1ensll steel sectlonol doors ore lntroduced.
lº85
Hortln beglns to monuïocture rolsed ponel steel sectlonol doors. Long-llïe golvonlzed
torslon sprlngs ore lntroduced.
lº8ó
Hortln beglns to export lts goroge doors lnternotlonolly. Hortln Frelghtlng re-estobllshed
to dellver doors weekly to hundreds oï Hortln deolers.
Hortln olrs the ïomous 0ove Hortln "5tlïï" televlslon commerclol ïor the ïlrst tlme. 1he
memoroble od wlns o CLl0 the ïollowlng yeor.
lººû
Honuïocturlng copoblllty lncreosed to óûû doors per doy. Hortln 0oors ore now shlpped
to mo|or dlstrlbutors ln over /û countrles.
lºº/
Hortln 0oor Honuïocturlng recelves the "L" oword ïrom the Presldent oï the Unlted
5totes ïor excellence ln exportlng. Begon onnuol deoler lncentlve trlp.
lººó
Hortln lntroduces Flnger5hleld?, o potented ïlnger soïety system to help ellmlnote
escolotlng ln|urles ossocloted wlth sectlon |olnts ond other hlgh-rlsk oreos oï goroge
doors.
Pl510R¥
Plstorlcol 1lmellne
Contoct Us About Us Flnd o 0eoler News Blog
!"#$%"&'$() %"()"!#
Search Site
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 35 of 65 PageID# 575
10/17/13 11:00 AM Martin Garage Doors | History
Page 2 of 2 http://www.martindoor.com/about-us/history/
2ûûû
Consumer Product 5oïety Commlsslon (CP5Cì recognlzes Hortln 0oor ïor promotlng o
soïer product deslgn, quoted soylng: "Hortln bullds to o hlgher stondord."
2ûûl
Hortln 0oor ls certlïled to l50 ºûûl quollty stondord becomlng the ïlrst UL reglstered
goroge door monuïocturer.
2ûû2
Hortln exponds ïeotures to lnclude: 7û- powder coot color cholces, reol copper metol
doors, over lûû wlndow deslgns, ond steel corrloge house doors.
2ûûó
Hortln lntroduced the Controlled 0escent 0evlce, the ultlmote ontl-drop door devlce.
Hortln 0oors ore now ln over 8û countrles.
2ûû7
Hortln lntroduces extruded olumlnum doors wlth o new Flnger5hleld? sectlon |olnt.
Hodels: Corrloge Pouse, Archcrest wlth custom orches ond Atheno ln over 7û color
ïlnlshes ond duo-tone optlons. 5oït touch reverse ! no photo-eye door ond opener
systems lntroduced.
2ûûº
Hortln 0oor lntroduces 6rooved Ponel steel doors. Hortln 6oroge 0oors ore sold ln º3
countrles.
2ûll
Hortln lntroduces the Collïornlo 6oroge 0oor. 1hls more competltlvely prlced door ls
ovolloble ln both resldentlol ond commerclol slzes, multlple colors, hundreds oï optlons
ond lncludes mony oï Hortln's essentlol soïety ïeotures.
6ARA6L 000R5
%*+,- /0 1*23,4 5677893,64
Atheno
Plnnocle
Cyprus
#87893 5677893,64
Legocy
5lgnoture
Cornerstone
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1rodltlonol

:66- 5677893,64
Cholet
Chorterhouse
Provldence
5ummlt
5llverloke
wlndrlver
Rlverstone
5LRvlCL & 5UPP0R1
Llve Pelp
vldeo 1utorlols
FA0
Ports Flnder
Resource Llbrory
AB0U1 U5
0uollty ond Perïormonce
5oïety
HortlNews
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News
Coreers
 
© 2ûl3 Hortln 6oroge 0oors. All rlghts reserved.
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Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 36 of 65 PageID# 576
Exhibit P

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 37 of 65 PageID# 577
Page 1 of 5
FrenchPorte, LLC
121 Congressional Lane
Penthouse Suite
Rockville, MD 20852

MEMO: To File
RE: Martin Door Visit
FROM: Roger K. Davis

A meeting was held on May 2, 2006 at Martin Door Manufacturing, Inc. located at 2820
South 900 West, Salt Lake City, Utah 84119.

Those in attendance included the following:
David Martin, Chairman and CEO (Martin Door)
David Haslam, Director of Sales & Marketing (Martin Door)
Robert Scott, Chief Engineer (Martin Door)
Roger K. Davis AIA , Vice President (FrenchPorte)
Sam Bunch, Academy Door & Control Corp. (FrenchPorte Consultant)
Scott Schmidt, Chief Operating Officer (A-Tech)

Before the meeting David Haslam gave Roger Davis, Sam Bunch and Scott Schmidt a
tour of the facility.

Martin’s whole operation is conducted from this facility (Sales, Marketing, Advertising,
Engineering, Administrative, Production, etc.) Photographs were not allowed to be taken
at the approximate 500,000 square foot facility that ship to over 60 countries and have a
distribution network in the US west of the Mississippi.

The production is all viewed from an enclosed hallway above the production floor. We
observed the shipping dock, inventory, plastic press, metal press, track and spring
packaging, spring production and die shop.

The facility was impressive and very clean and well organized. After the tour we
displayed our pinch resistance extrusion design and door sample. The Martin group of
David Martin, David Haslam and Robert Scott reviewed the pinch resistance operation of
the door. They all seemed genuinely interested with the sample.

After talking about the sample for a length of time David Martin asked where do we go
from here?

The meeting adjourned to their corporate conference room. When asked about
FrenchPorte, Roger Davis gave a history of the company and then Roger Davis and Sam
Bunch continued to explain various aspects of the door, patents, models, hinges, roller
carriages, etc.

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 38 of 65 PageID# 578
Page 2 of 5
We talked about many aspects of the door and because several issues were so interrelated
and several different discussions were going on at one time they are identified below with
no real sequence.

The questions arose as to whether the Martin hinge and roller carriage would work. We
indicated that the pivot point of the “Chinese-FP” hinge was designed to work with the
pinch resistance extrusion. We indicated that the intermediate Chinese-FP hinge would
work as an edge hinge if the structured strut was not removed in order to eliminate a
hinge type.

David Martin suggested that we disassemble our sample and see how a reversed Martin
hinge would work. John McLaughlin, a Sales Manager with Martin assisted in the effort.

It was concluded that a Martin hinge could be inverted at the edge condition and could
probably work. The Martin intermediate hinge could also be modified to work at the
intermediated locations. The diameter pin of the Martin hinge is a different size and it
would depend on the exact attachment to the sections as to whether the Martin hinge
would work.

David Martin was concerned that the tolerance at the pinch proof extrusion was too close
and should be increased by 3/32 of an inch. This would avoid the possibility of metal on
metal rubbing after repeated use that might create a squeaky noise during operation.

David Martin was also concerned about the bottom roller carriage. For safety purposes
Martin’s bottom carriage has a hook or clip built into the design so that in the event if a
consumer would attempt to remove the bottom roller carriage screws that they would not
be able to remove the bottom carrier while the carrier is still in tension from the cable and
torsion spring. This would prevent a possible injury to the consumer. The Martin bottom
carriage created issues with FrenchPorte weather-stripping astygal as well.

We also discussed the possibility of increasing our door thickness from 1 5/8” to 2”. This
would solve many Martin hardware issues as well as make the door sections and
extrusions better able to withstand wind load tests in Florida and designated hurricane
belts due to the increased “box beam” of the thicker extrusion. This could also make the
section more interchangeable with existing designs.

There was a lot of discussion regarding Martins business model that produces and
delivers a garage door in approximately 14 days once an order is received. This
eliminates inventory issues for Martin and allows all models to be manufactures
regardless of the door size.

Martin engineer, Robert Scott suggested that Martin had the expertise and production
ability to possibly use FrenchPorrte’s extrusions and make the FrenchPore garage door to
order. Their machinery could be tooled to virtually make any size. FrenchPorte could
provide the extrusions powder coated in white. Then Martin would fabricate the entire
pieces based on a specific size. Robert Scott felt that the labor taken to assemble the
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 39 of 65 PageID# 579
Page 3 of 5
sections would be offset by the shipping, inventory, quality control, packing fee, etc.
Martin requested that FrenchPorte provide pricing for the extrusions only.

Roger Davis expressed concern that our manufacturer may not understand this request
since they do not manufacture the extrusions themselves. WE need to discus among
ourselves a s how best to pursue this issue with our manufacture..

Another possibility would be for Martin to purchase extrusion sections in the US based
on FrenchPorte extrusion designs and FrenchPorte could then be paid a royalty for each
door sold.

All parties agreed that numbers would need to be crunched to determine if this would be
feasible. Martin’s engineer was very positive that it would work. The question remains
as to whether the price point would still make the door sellable.

Scott Schmidt through the idea of purchasing a door from Martin of any size and model
on demand would work for A-tech for odd size doors. However after the meeting, he
expressed that the price from Martin would need to be in line with the current pricing
structure to make it work.

The standardization of section heights would not become an issue if all doors were made
to order. However, A-tech would like for FrenchPorte to explore this possibility.

The thought of a complete redesign of the extrusion to 2 inches could be phased in after
initial development and testing is completed. Martin would be willing to collaborate with
FrenchPorte in the process.

Martin would like to cycle the pinch resistance design doors as well as wind load test a
16 x 7 sample.

FrenchPorte agreed that Martin would take the 3 samples from A-Tech (that were made
for the upcoming garage door show in Las Vegas) after the show in Las Vegas to begin
cycle testing. We would need to confirm whether the Martin hardware or the “Chinese –
FrenchPorte” hardware would be used or both.

Martin would need 2 16 x 7 door to chamber test. FrenchPorte will need to decide how
best to get this door to Martin. That may be put into the next container shipment A-Tech.

For Martin doors to meet Dade County Florida, the roller carriages are made of 10 gage
steel, are installed in pairs, the roller itself is made of high strength steel, and the roller
carriages are actually tack welded to prevent separation. This is a very severe test. It
took Martin our 25 doors to find the correct combination of hardware design to withstand
150 mph wind test (both negative and positive pressure).

Their engineer thought that our structural flange would need to be modified to prevent
crimping in the negative pressure test. Their engineer also believes that polycarbonate
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 40 of 65 PageID# 580
Page 4 of 5
would withstand the projectile test. FrenchPorte’s extrusion that retains the
polycarbonate panels may need to be mechanically fastened.

Martin agreed to collaborate with FrenchPorte in the elevation and extrusion modification
to the door. David Martin executed a confidentiality agreement when presented by
FrenchPorte.

FrenchPorte agreed to provide Martin with shop drawings and possibly a CAD file of the
drawings as soon as possible so that they could layout various sizes and determine the
aesthetic impact of the odd door sizes.

Parties agreed that Florida and Dade County test are not an immediate concern, but could
be accomplished with tweaking the exiting design.

Martin has the machinery and computer aided design to develop the required drill pattern
for the extrusions as well as mass produce the various extrusion components of each
section.

Martin expressed interest in possibly replacing their existing Silverline Door Model with
FrenchPorte. If Martin manufacturers the door, the design, style, color, and consumer
choices could be endless.

Because of the uniqueness of the door design, David Halsom believes Atlanta (Home
Depot) would be doing back flips for the opportunity to supply this door at their stores.

As to the issue at patents, David Martin educated us as too Martin’s some 60 patents. He
says every door manufacture has and is infringing on his patents. He used an example
over an infringement by Overhead Door. The cost to litigate would be prohibitive for the
return. He could not even get Overhead Door to pay $1.00 a door for Martin’s door seal
design.

He also informed us that four known companies in China is actually using Martin’s name
and his picture to promote a knock-off all of their design without their permission. When
consulting with the authority, they informed him that it was a loosing battle. (His other
example was of 1,000 plus companies copying NOKIA phones and NOKIA not being
able to do anything about it.)

The idea being made that a patent is important in this country if put to market quickly,
because a good design patent can be slightly modified and may not be ruled an
infringement. However, FrenchPorte’s utility patent would make it very difficult for
infringement.

We discussed the possibility of redesigning the pinch resistance extrusion so that the
radius points at the extrusion would prevent the overlapping extrusion from rubbing
against each other. Making the door section 2 inches may create the additional room in
extrusion section to accomplish this a little easier.
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 41 of 65 PageID# 581
Page 5 of 5

The structural strut could also be extruded at an angle instead of being straight so that any
pinching at the interior of the door could be eliminated.

Martins hardware is high end and we want to be aware that this could price the door out
of a certain segment of the market.

The door extrusion could possibly be integrated into their carriage house door design.

Scott Schmidt thought our visit was very successful. Dialogue had been accomplished
and the pinch resistance design was well received by Martin Door. The collaboration
between Martin, A-tech and FrenchPorte could provide a very unique opportunity for all
parties.


Roger Davis agreed to provide David Halsam with the HGTV air schedule of the
FrenchPorte spot.
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 42 of 65 PageID# 582
Exhibit Q

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 43 of 65 PageID# 583
August 2009
Beautiful New Designs
ISO 9001
Quality
Standard
MARTIN DOOR MFG.
ISO 9001 A8949 R
E
G
I
S
T
ERE

D
F
I
R
M
R
TM
GARAGE DOORS
M N
GARAGE DOORS
S I N C E 1 9 3 6
MARTINEWS


Martinews is Distributed to 86 Countries of the World Martinews is Distributed to 86 Countries of the World
MARTIN DOOR MFG., SLC, UT 1-800-388-9310 801-973-9310 www.martindoor.com © Copyright 2009 AD-NR50-42 MARTIN DOOR MFG., SLC, UT 1-800-388-9310 801-973-9310 www.martindoor.com © Copyright 2009 AD-NR50-42
Martin Door Manufacturing has added
two new garage door styles, to its
expanding list of garage door options.
The company will begin the Avignon (ä-
ven-yô) Garage Door, which features a
French-style, and also a unique flushline-
style door, known as the Kensington
Garage Door, effective immediately. Both
doors will be offered with a powder coat
finish only.
The Avignon comes in a variety of glass
options and is a sectional garage door,
designed to look like a swinging door.
The Kensington is a hybrid garage door

continued on page 2...
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 44 of 65 PageID# 584
Shaun Murphy
Shaun Murphy, national sales manager
for Martin Door Manufacturing, has been
elected to a three-year term on the board
of directors of the International Door
Association (IDA).
Murphy brings a wealth of experience to
his position. He has been involved in the
garage door industry since 1984. He has
held his current post with MDM for the
past 10 years
He joins a leadership body that includes
20 other directors and includes
representation from 18 countries. The
IDA is based in West Milton, Ohio and
was formed in 1996 with the
consolidation of the Door & Operator
Dealers Association and the Far
Western Garage Door Association. It
represents the door and operator dealer
industry worldwide and includes a
membershi
p of 1,600.
He and his
wife Lisa
live in
Draper, UT
and are the
parents of
three
children.
Murphy Elected to IDA Board
Avignon continued...
New Martin Kensington Garage Door
featuring smooth panels made
of 24-gauge steel, with
carriage house style windows
in extruded aluminum.
“It's a new look and a new
approach for the garage door
market,” David Haslam,
Director of National Sales said
of the new options.
He thinks the broader offering,
will help dealers develop a
niche.
“I think a lot of people will be
surprised at how these styles
will fit on more homes than
they thought possible,”
Haslam said.
The Avignon is named after a city in
southern France famous for being the home
of seven Catholic popes in the period from
1305 to 1378. It is located
approximately 580 kilometers from
Paris.
The Kensington door is named after
an affluent suburb of London,
known for its museum district and
for its gardens.

The new hybrid door fills a need
customers have requested for a
smooth panel on a steel carriage
house door, according to Haslam.
A Wyoming garage door dealer
has taken his hobby to another
level.
Dave Harding of The Doorman,
LLC of Casper not only loves
mud bogging, he is now
promoting and sponsoring events
to showcase the growing sport.
Harding and his associate Loren
MacDonald, an installation
specialist for The Doorman,
recently acquired land from the
city of Casper and set up their
own mud bogging and rock
crawling course. They recently
hosted a two-day event, which
drew 50 trucks and over 200
spectators. They hope to expand
the event in the future.
The two garage installers also
started a new club to attract like-
minded folks called the Wannarock
Offroad Club.If there is one thing that
sticks out about Harding, it is that he
doesn't mind sticking out and using his
hobbies and passions to promote
business at the same time.
“We promote Martin on every thing we
can,” Harding said.
Harding has adopted a unique means of
making his business and hobby
stand out. He utilizes a special
color to make sure people
notice. It's a fluorescent green,
sure to light up the night. He
refers to it as “sic green.”
Turning A Hobby Into
An Event, Business
Dave Harding with Loren MacDonald
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 45 of 65 PageID# 585
Dave Martin and Martin Garage
Doors are two of the good things
about Utah.
Three times in the past last few
months, the chairman of Martin
Door Manufacturing has made
an appearance on the local TV
show “Good Things Utah” to
pitch the environmental virtues
of Martin Garage Doors.
During one appearance, Dave
took a portion of an old wooden
door to showcase the common
problems associated with wood
garage doors.
Martin also took a special green
issue of the Martinews with him
to help illustrate the green
Martin On TV Show
nature of Martin Garage Doors. Martin
Garage Doors have been described as
being “greener than green” because of
their longevity and how easily materials in
the door are recycled.
In his last appearance, the TV cameras
rolled live from the Martin showroom,
with a unique means of introducing Dave
to the audience. Playing off an old ad
where a cardboard cutout of
Dave is a prominent part of the
infamous “stiff ad,” the news
reporter put the camera in front
of the cutout before switching
to Dave, who was standing
nearby. Dave used the live
remote to talk about some of the
new technologies, and safety
mechanisms featured on Martin
Garage Doors.
Doing TV is almost old hat for
Dave, who is a well known
figure throughout the Beehive
State because so many people
grew up seeing him on TV,
through ads run by the company
over the years, including the
world famous “stiff ad”, which
won a Cleo.
Selected Smooth Paint Samples
Now in Standard or Low Gloss
Select powder coat paint chips
are available in a lower gloss or
standard gloss option, with a
smooth surface.
Mike Martin, director of
Advertising, said small sized
paint chips in what he termed
“the most popular colors” are
available for dealer use.
Those colors include Martin's
metallic specialty colors such as
copper vein, copper gold,
mahogany vein, rusty iron and
sandcast bronze, and many
popular solid RAL colors. These
smooth solid RAL color chips
feature a 25 percent gloss or the
standard gloss choice. These chips are
available individually by request.
Contact your Martin Door
representative or customer service for
access to the special color samples.
Dave Martin on TV
Standard Gloss is on the left.
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 46 of 65 PageID# 586
It’s all about GREEN
on new web site
Martin Door will expand its
promotion of going green, with
the introduction of a new web
site www.ecogreengarage
doors.com, which focuses on
green issues within the garage
door industry.
The website will highlight key
environmental concerns, and
also address how Martin Garage
Doors fit within a growing
concept of green in the building
and replacement market.
There is no garage door industry
standard to define green, but
Martin Door Manufacturing has
been pro-active in trying to raise
awareness about environmental
issues, as well as educate
consumers on other key issues
involving energy use and garage
doors. Company officials have
often claimed that Martin Doors
is “greener than green.”
In 2008, Martin Door generated
a special edition of
“Martinews”---an in-house
publication---to address some of
those green concerns or
initiatives. At the behest of
Michael Martin, director of
Advertising, MDM officials
have also investigated the
possibility of creating an Energy
Star designation for garage
doors. The government sets
those standards and has not
included a garage door category.
Martin says the website will be
a key educational tool, for
people in search of a green
garage door. “It will explain our
opinion of what constitutes a
green garage door and help
people make their own
decisions about what is green,”
Martin said of the website.
While there is no consensus
about what is green, there are
some variables, which appear to
Martin
Appointed To
Standards
Committee
Ken Martin, president of
Martin Door
Manufacturing, has been
selected as a member of
a standards committee,
which has authority to
regulate garage door
opener standards for the
United States.
Martin was announced
as the newest member of
the UL325 Standards
Technical Panel
Committee earlier this
year. The committee
falls under the
auspices of the
American National
Standards Institute,
which has been
charged by
Congress to
oversee all
revisions to garage
door opener laws
and regulations.
Ken is the eldest
son of Virginia and
David O. Martin
and has been
active in the
garage door
industry for years.
A graduate of the
University of Utah, Ken
is a member of the Door
& Access Systems
Manufacturer's
Association (DASMA)
and former president of
the National Association
of Garage Door
Manufacturers
(NAGDM).
Ken and his wife, Sandi,
live in Sandy, Utah and
are the parents of six
children.
Ken Martin
be consistent with most
discussions about
environmentally friendly
products. Those include,
product durability, Energy Star
compliance, life cycle
assessment, no or low volatile
organic compounds (VOCs),
regional manufacture or
fabrication, LEED certification,
manufacturing energy
reduction/water use practices,
Green Seal certification, Green
Guard certification, cradle to
cradle certification, EcoLogo
listing and the coating or primer
used on products.
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 47 of 65 PageID# 587
Martin Door® Part of LEED Platinum Home Project
Steve Blanchard hopes to have the
first home in Orange County
California to be certified to LEED
platinum status, and he is featuring
one of Martin Door Manufacturing's
newest garage door models, to do so.
Installers from Mr. Martin Garage
Doors in Buena Park, Ca. recently
installed an Athena Garage Door on
a home being renovated in Costa
Mesa, California by Blanchard, a
real estate developer. Blanchard said
the home is already being described
as the “greenest home in Orange
County.”
Blanchard approached Martin Door
earlier this year, about partnering in
the project. More details on the
project are available at
www.costamesagreen.com.
When completed, Blanchard expects
the home to certified platinum by the
U.S.Green Building Council's
Leadership in Energy and
Environmental Design (LEED) for
homes program. He is confident the
home will be a model on
green technology and
innovation and serve as a
practical example of what
other homeowners can do
in the future.
Per LEED guidelines,
projects are rated on a
point scale for different
aspects of environmental
design. There are three
levels of LEED, going
from silver, gold to
platinum. Blanchard is
confident the home will
meet platinum guidelines,
even with its size. Larger
homes, because they use
more natural resources to
build, have to reach a
higher point level to be
certified, according to
Blanchard. According to
the USGBC website, no
Orange County projects
have rated higher than
Silver thus far.
The home is being gutted and
remodeled in a style called “modern
interpretation of craftsman.”
Blanchard hopes his home will
influence future projects elsewhere.
He had hoped to move his family
into the structure by early summer,
but has revised his timetable to the
fall of this year.
The developer chose an Athena door
on his project, after reviewing a
number of garage door options from
various manufacturers. He liked the
door's style and design which best
fit within the scope of what he was
trying to do with the home.
The new home will incorporate a
number of energy-saving
mechanisms, according to
Blanchard. He says the home will
have enough photovoltaic panels to
bring the electricity bill down to $0.
www.costamesagreen.com
An Athena Garage Door, made by Martin Door Mfg., is one component of a home
renovation project in Southern California. The home is already described by the
developer as the “greenest home in Orange County.” The home, located in Costa
Mesa, which officials hope will result as the first home in the County certified to
LEED platinum status.
It will also feature Energy Star
appliances, tankless water heaters
located close to the faucets they
service, plus special windows and
insulation.
Water-saving systems will be
installed and “smart landscaping”
will also be installed.
Ironically Orange County is the
original home of MDM, which was
started in 1936 in Santa Ana.
LEED
F O R H O M E S
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 48 of 65 PageID# 588
Latest CPSC Safety Stats Show No Improvement
1999 Injuries by Age
20%
Children
1-17
22%
Adults
36-45
20%
Adults
46-60
23%
Adults
18-35
15%
Seniors
60+
2008 Injuries by Age
17%
Children
1-17
17%
Adults
36-45
25%
Adults
46-60
23%
Adults
18-35
18%
Seniors
60+
Year: 1999
7,760
12,918
Year: 2008
The numbers continue to tell a grim
story. Recent statistics for 2008,
released by the Consumer Product
Safety Commission via their NEISS
library, estimates there were 20,017
injuries in the garage for the year. The
numbers are compiled from a sampling
of hospital visits and reports
throughout the United States.
Based on the data, an estimated 12,918
of those incidents were related to
something on the garage door or
Annual Estimated Garage
Door Related Injuries
The word needs to get out in a louder
voice than it has before: garage door
safety is important to everyone,
especially children.
Martin is setting up a website
www.garagedoorchildsafety.com
focused on bringing attention to
specific safety issues involving
garage doors.
The website is centered on 10
different components of garage door
safety and will utilize information,
experiences, and other data available
online to help the consumer consider
those factors, when looking at a new
garage door purchase or repair.
The intent of the new web site will
not be to sell a specific product, but
to arm the consumer with important
issues they should consider in the
day-to-day use of a garage door.

In most cases, the website will
New Website Focuses On Safety
feature stories,
articles or data
released by
independent
organizations, such
as the U.S.
Consumer Product
Safety
Commission
(C.P.S.C.) or other
writers, with no
Martin affiliation.
opener. By contrast there were
an estimated 7,760
accidents in 1999.
A closer examination
of the data also
shows that about
17% of the victims
were children. 18%
of the people injured
were seniors. The data
can be accessed at
https://www.cpsc.gov/
cgibin/NEISSQuery/
home.aspx by using codes
1886 and 138.
2008 estimated injuries by category:
1. Fingers entrapped in section
joints...5,610.
2. Sharp edge lacerations...2,890.
3. Falling doors...2,040.
4. Spring...977.
5. Broken door needing repair...467
6. Glass 425
7. Entrapped in Rollers or Track...297
8. Riding the door...127
9. Beat the door...85
Total...12,918
To address the
, Martin Door Mfg.
has just announced that their anti-drop
device is now available as a kit for older
garage doors.
CPSC’s third largest, the
falling door category
The Controlled Descent Device™, a
device which is designed to
resolve the potential dangers of
a falling door that could result
from a relaxed spring, a
broken spring or broken lift
cables, is now available as a
retrofit option for older
garage doors.
"Our CDD is the ultimate safety
device for a garage door" Dave
Martin, chairman of MDM said.
Martin said the device gives the
owner a lifetime of protection.
The CDD is one
of over 20
advanced
safety
features
that are
standard
options on
every Martin
Garage Door.
The Controlled
Decent Device is
now offered in a
kit to upgrade
older doors.
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 49 of 65 PageID# 589
Garage Doors are green, simply
based on durability alone. All
Martin Garage Doors, save one
model, come with a lifetime
warranty.
Even when a door does reach
the end of the road, Martin has
stressed almost every
component of the door is
recyclable---relieving the need
to landfill the product.
It’s All About Durability, Architects Survey Shows
Martin Garage Doors are now
available with a new R-14
insulation option, which could
significantly boost the R-value
of the Utah-manufactured
garage door.
The added insulation is targeted
at customers who want a higher
R-value in their garage door.
A standard Martin Garage Door
with insulation has an R-value
of 8. The new option is
expected to boost the R-value to
14, according to Robert Scott,
director of Engineering at
MDM. He insists Martin is
careful not to overestimate the
R-value of its doors.
Dave Martin, a garage door
safety expert and chairman of
Marti n Adds Insulati on Booster
Martin Door Mfg, downplays the
significance of R-value for energy
savings in the garage, due
to venting requirements
for areas featuring
combustible materials.
The new insulation option
comes with some R-value
disclaimers. Doors with
two or more sections of
designer windows will
require double pane
windows to maintain the
R-14 rating. Doors with
one or more extruded
aluminum row sections
will also require double
pane glass to maintain the
rating.
Martin Garage Doors are
available in steel, copper
and aluminum and come
Cut-away of acrylic double pane window
Fastened here
Cut-away of R-14 Insulation option
O
Y
R
N
P
L
S
T
Y
E
E
MULTI-LAYER INSULATION CORE MULTI-LAYER INSULATION CORE
STEEL BACK
in over 77 different color options and over 100
window options.
A recent 2009 survey done among
architects, has given fuel to
discussion of durability as the most
important component of how green a
product is.
Results released from a survey of
612 architects by PPG Industries,
suggests durability is the most
important characteristic of a green
product, followed by Energy Star
compliance, life cycle assessment
and then LEED certification.
92 percent of those surveyed pointed
to durability as the top component of
defining green.
That information becomes critical for
Martin Door dealers, in trying to
appropriately deal with anyone
asking for green products. No other
garage door company makes a more
enduring and durable garage door.
Dave Martin, chairman of MDM, has
steadfastly maintained that Martin
Dave Martin in front of the “Phenomenal” Martin Door
and opener system that lasted 326,000 cycles. Not
one hinge or roller was replaced. Springs were
replaced every 35,000 - 40,000 cycles.

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 50 of 65 PageID# 590
A bit
Martin Athena Designs Rock
It's a look that is catching
on. Since introducing the
Athena Door in 2007 the
unique aluminum
extruded door, has been a
popular option for higher
end homes.
Available in 77 powder
coat colors, with multiple
acrylic or glass options,
the garage door is a head
turner.
Dealers who have recently
installed Athena Doors are
invited to submit pictures
to Martin Door Mfg.
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 51 of 65 PageID# 591
Exhibit R

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 52 of 65 PageID# 592
10/16/13 3:06 PM Martin Garage Doors | Garage Doors
Page 1 of 3 http://www.martindoor.com/residential/garage-doors/david-o-martin-collection/athena/
0ovld 0. Hortln Collectlon
wood Collectlon
5elect Collectlon
Atheno
0ownlood Brochure
- cllck to enlorge
!"#"!$ &''#( ~ 0Avl0 0. HAR1lN C0LLLC1l0N
)*+ (,-../.012 345+6. !7670+ &446
1he Atheno model uses o contemporory comblnotlon oï heovy-duty extruded olumlnum metol ond gloss
ponels to creote o stunnlng ond unlque plece ïor your home. 1hls beoutlïul door ls olso low-
molntenonce, provldlng o perïect, long-term solutlon ïor your home.
/8 "1-9/.-9 : ";621/; <4.=,6-;,/4.
6et volue ond duroblllty wlth thls non-lnsuloted steel door. 1hese heovy-duty olumlnum doors ore
dependoble, duroble, ond mlnlmol upkeep
2" thlck door constructlon
0ependoble, duroble, mlnlmol upkeep
Lnvlronmentolly ïrlendly
Lnergy eïïlclent
very qulet operotlon
Contoct Us About Us Flnd o 0eoler News Blog
Atheno !
Plnnocle !
Cyprus !
#$(>&$?)>"@ &$"@$#(
6ARA6L 000R5 0PLNLR5 0L5l6N ¥0UR 000R 5LRvlCL & 5UPP0R1 BR0CPURL5
Search Site
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 53 of 65 PageID# 593
10/16/13 3:06 PM Martin Garage Doors | Garage Doors
Page 2 of 3 http://www.martindoor.com/residential/garage-doors/david-o-martin-collection/athena/
Ponel 5tyles
Powder Coot Flnlshes
Long-lostlng, duroble ïlnlsh. vlew oll Color 0ptlons.
wlndow 1lnt 0ptlons
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 54 of 65 PageID# 594
10/16/13 3:06 PM Martin Garage Doors | Garage Doors
Page 3 of 3 http://www.martindoor.com/residential/garage-doors/david-o-martin-collection/athena/
Lomlnote 6loss 0ptlons
6ARA6L 000R5
&7A/5 'B 376,/. <411+;,/4.
Atheno
Plnnocle
Cyprus
(+1+;, <411+;,/4.
Legocy
5lgnoture
Cornerstone
6otewoy
1rodltlonol

C445 <411+;,/4.
Cholet
Chorterhouse
Provldence
5ummlt
5llverloke
wlndrlver
Rlverstone
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Llve Pelp
vldeo 1utorlols
FA0
Ports Flnder
Resource Llbrory
AB0U1 U5
0uollty ond Perïormonce
5oïety
HortlNews
Brochures
News
Coreers
 
© 2ûl3 Hortln 6oroge 0oors. All rlghts reserved.
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 55 of 65 PageID# 595
Exhibit S

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 56 of 65 PageID# 596
10/16/13 3:20 PM Martin Garage Doors | Quality and Performance
Page 1 of 2 http://www.martindoor.com/about-us/quality-and-performance/
0UALl1¥ AN0 PLRF0RHANCL
Lndurlng 0uollty - Peoce oï Hlnd
Hortln doesn't cut corners or scrlmp on the hordwore ïor the world's best goroge door.
Hortln hordwore ls mode oï hlgh-grode steel, our llït cobles ore thlcker-thon-lndustry cobles, ond every slngle component oï the hordwore ïor the door system
hos been englneered wlth longevlty ln mlnd.
1hot ottentlon to detoll lncludes Hortln's Flnest worronty on the lndustry's best torslon sprlng. lnsurlng o llïetlme oï relloblllty ond superlor curb oppeol.
Hortln Pordwore
5eoled boll-beorlng rollers'
Commerclol-grode reverse ongle shlelds'
Cose-hordened ïosteners
l/ gouge steel hlnges
lû gouge steel roller brockets'
l/!l7 gouge hemmed-rolled edge trocks
lûû,ûûû cycle rotlng on hordwore'
' 5ome door models hove llghter gouge componenets ond con be upgroded.

Llïetlme 5prlng 5ystem
Hartin 6arage ßoor 5prings
1ested to o hlgher stondord, Hortln's duol, slde-mounted, golvonlzed torslon sprlngs provlde unporolleled longevlty ond soïety durlng the llïe oï your goroge
door.
Contoct Us About Us Flnd o 0eoler News Blog
R£5IߣN7IAL ߣAL£R5
Search Site
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 57 of 65 PageID# 597
10/16/13 3:20 PM Martin Garage Doors | Quality and Performance
Page 2 of 2 http://www.martindoor.com/about-us/quality-and-performance/
' 5ee monuïocturer's wrltten worronty ïor detolls ond llmltotlons.

Long-Lasting Finish
Hortln ïlnlsh hos superlor Uv protectlon, corroslon reslstonce, provldlng o long lostlng, duroble ïlnlsh.
Flve stondord enomel colors, two-coots boked-on enomel
5eventy-seven powder coot ïlnlshes
1hree yeors oï 5oudl Aroblon weother- these two doors were lnstolled ot the some tlme.

6ARA6L 000R5
ßavid 0. Hartin 6ollection
Atheno
Plnnocle
Cyprus
5elect 6ollection
Legocy
5lgnoture
Cornerstone
6otewoy
1rodltlonol

Wood 6ollection
Cholet
Chorterhouse
Provldence
5ummlt
5llverloke
wlndrlver
Rlverstone
5LRvlCL & 5UPP0R1
Llve Pelp
vldeo 1utorlols
FA0
Ports Flnder
Resource Llbrory
AB0U1 U5
0uollty ond Perïormonce
5oïety
HortlNews
Brochures
News
Coreers
 
© 2ûl3 Hortln 6oroge 0oors. All rlghts reserved.
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 58 of 65 PageID# 598
Exhibit T

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 59 of 65 PageID# 599
DO NOT completely weather seal this door! Vent according to local building codes.
CAUTION! Low levels of carbon monoxide in the garage and home can cause headaches
and flu-like symptoms. Additional venting may be required to help reduce the health risks
associated with combustible fuels and noxious fumes.
The insulation used in Martin Doors comply with all known building codes. It has been
tested and approved by Omega Point Laboratories and meets the UBC-26-8 standard for
smoke and flame spread. The insulation is removable and reusable which helps the
environment by reducing landfill waste!
Martin regular and insulated door sections are rated among the most dent resistant in the
world. They do not require insulation bonded to them for strength. Because of this unique
construction it may not be necessary to replace a door section or a complete door to avoid
the prolonged appearance of a damaged surface. For dent repair see page 18.
The Martin Warranty is to the original owner. Lifetime ltd. for most residential doors (12 year
ltd. on Montana). Six Year ltd. for commercial, rentals, and 5 yr. on wood doors. Replacement
part shipping and labor costs are not included. Springs have life cycle limits. Note: with
proper care and maintenance all Martin Doors (except springs) are designed to last a
lifetime. Contact your Martin Dealer for details on the full written warranty and limitations.
!
7/2004
Martin Door Manufacturing Salt Lake City, Utah 84127-0437 U.S. A www.martindoor.com Printed in the U.S.A. 20m Copyright 2004 © AD-01IM-07
MAINTENANCE
DOOR OPENERS (We recommend Martin Door Openers)
NOXIOUS FUMES
INSULATION
DENT REPAIR (Steel Doors)
THIS IS THE WORLD’S FINEST, SAFEST DOOR. HOWEVER, UNTRAINED OR NEGLIGENT INSTALLING, ADJUSTING, AND SERVICING CAN BE DANGEROUS. THE SPRINGS
AND RELATED PARTS CAN CAUSE SERIOUS INJURY OR DEATH! IF UNSURE, CALL A TRAINED MARTIN DOOR DEALER
Oil all hinges, roller shafts, and spring coils, using a high quality 10/40 motor oil.
Oil yearly for a smooth operation. Do not allow parts to squeak!
Wax yearly the leading edge of metal door Finger Shields or inside wood door section
joints. Also wax Reverse Angle Shields or jambs (where door seals while closing).
As needed, use lightly oiled cloth to wipe galvanized parts to help retain clean galvanized
look. In damp, wet areas, galvanized parts may require painting to help prevent rust.
Touch-up paint not recommended on steel doors. Read “Painting Theory” on back
page.
As needed, wash away dirt, salt residue, etc. from steel door sections. Automobile type
cleaners and waxes may improve the look and prolong the life of aged paint or a
neglected steel door. Frequent waxing or painting may be required in extremely damp,
salty or caustic areas. For wood doors see “WOOD DOOR NOTES” page.
Clean the acrylic windows with a soft wet cloth. Remove scratches in the acrylic window
pane with a quality plastic window cleaner.
Always keep the garage door in full view while using the electric opener.
Monthly check the automatic reverse function, following the manufacturer's
electric opener instructions.
Martin Doors are designed to reduce risk of entrapment and injury to children and adults.
Roller Shields, Finger Shields, Low Profile Hinges, Reverse Angle Shields, Inside Lift
Cables, Rolled Steel Edges, etc., are all designed for added child safety .
Remove all pull down ropes and disable any garage door locking mechanism.
The top door section should have a full length strut for center mounted openers. Side
mounted openers may not require a strut on single size doors under 12’3” (3734) wide.
.
.
.
.
.
WARRANTY
DO NOT completely weather seal this door! Vent according to local building codes.
CAUTION! Low levels of carbon monoxide in the garage and home can cause headaches
and flu-like symptoms. Additional venting may be required to help reduce the health risks
associated with combustible fuels and noxious fumes.
The insulation used in Martin Doors comply with all known building codes. It has been
tested and approved by Omega Point Laboratories and meets the UBC-26-8 standard for
smoke and flame spread. The insulation is removable and reusable which helps the
environment by reducing landfill waste!
Martin regular and insulated door sections are rated among the most dent resistant in the
world. They do not require insulation bonded to them for strength. Because of this unique
construction it may not be necessary to replace a door section or a complete door to avoid
the prolonged appearance of a damaged surface. For dent repair see page 18.
The Martin Warranty is to the original owner. Lifetime ltd. for most residential doors (12 year
ltd. on Montana). Six Year ltd. for commercial, rentals, and 5 yr. on wood doors. Replacement
part shipping and labor costs are not included. Springs have life cycle limits. Note: with
proper care and maintenance all Martin Doors (except springs) are designed to last a
lifetime. Contact your Martin Dealer for details on the full written warranty and limitations.
!
7/2004
Martin Door Manufacturing Salt Lake City, Utah 84127-0437 U.S. A www.martindoor.com Printed in the U.S.A. 20m Copyright 2004 © AD-01IM-07
MAINTENANCE
DOOR OPENERS (We recommend Martin Door Openers)
NOXIOUS FUMES
INSULATION
DENT REPAIR (Steel Doors)
THIS IS THE WORLD’S FINEST, SAFEST DOOR. HOWEVER, UNTRAINED OR NEGLIGENT INSTALLING, ADJUSTING, AND SERVICING CAN BE DANGEROUS. THE SPRINGS
AND RELATED PARTS CAN CAUSE SERIOUS INJURY OR DEATH! IF UNSURE, CALL A TRAINED MARTIN DOOR DEALER
Oil all hinges, roller shafts, and spring coils, using a high quality 10/40 motor oil.
Oil yearly for a smooth operation. Do not allow parts to squeak!
Wax yearly the leading edge of metal door Finger Shields or inside wood door section
joints. Also wax Reverse Angle Shields or jambs (where door seals while closing).
As needed, use lightly oiled cloth to wipe galvanized parts to help retain clean galvanized
look. In damp, wet areas, galvanized parts may require painting to help prevent rust.
Touch-up paint not recommended on steel doors. Read “Painting Theory” on back
page.
As needed, wash away dirt, salt residue, etc. from steel door sections. Automobile type
cleaners and waxes may improve the look and prolong the life of aged paint or a
neglected steel door. Frequent waxing or painting may be required in extremely damp,
salty or caustic areas. For wood doors see “WOOD DOOR NOTES” page.
Clean the acrylic windows with a soft wet cloth. Remove scratches in the acrylic window
pane with a quality plastic window cleaner.
Always keep the garage door in full view while using the electric opener.
Monthly check the automatic reverse function, following the manufacturer's
electric opener instructions.
Martin Doors are designed to reduce risk of entrapment and injury to children and adults.
Roller Shields, Finger Shields, Low Profile Hinges, Reverse Angle Shields, Inside Lift
Cables, Rolled Steel Edges, etc., are all designed for added child safety .
Remove all pull down ropes and disable any garage door locking mechanism.
The top door section should have a full length strut for center mounted openers. Side
mounted openers may not require a strut on single size doors under 12’3” (3734) wide.
.
.
.
.
.
WARRANTY
MARTIN FINGER SHIELD™ GARAGE DOOR SYSTEM
FINGER
SHIELD
TM
MARTIN
ISO 9001 A8949
MARTIN DOOR MFG.
R
E
G
I
S
T
E
RE

D
F
I
R
M
TM
GARAGE DOORS
M N
GARAGE DOORS
S I N C E 1 9 3 6
INSTRUCTION MANUAL
(STEEL COPPER AND WOOD DOORS)
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 60 of 65 PageID# 600
#1 DOOR SECTION
(BOTTOM DOOR SECTION)
OPTIONAL PUNCHED
ANGLE TRACK HANGER
COUPLER
TORSION
SPRING
BLACK
SPRING WINDING CONE
CENTER BEARING
BRACKET
GREY STEALTH PLUGS
OR RED SAFETY CAPS
RED
SPRING WINDING CONE
BOTTOM
WEATHER SEAL
BOTTOM
REINFORCING ANGLE
VERTICAL
TRACK
TRACK
BRACKET
FLAG
ROLLER SHIELD™
AND ROLLER
SIDE SPRING
ANCHOR BRACKET
SPLICE
PLATE OR
SPLICE
BRACKET
LOCK-ON SIDE
BEARING BRACKET
BLACK
CABLE DRUM
HORIZONTAL
TRACK
HORIZONTAL
TRACK ANGLE
RED
CABLE DRUM
TOP ROLLER
BRACKET
#3 ROLLER
BRACKET
AND HINGE
#2 ROLLER
BRACKET
AND HINGE
#1 ROLLER
BRACKET
AND HINGE
INSULATED DOOR
LIFT HANDLE
SPRING
ANCHOR CONE “L” STRUT
LIFT
CABLE
ROLLER SHIELD
AND ROLLER
LOW PROFILE
HINGES
INSULATED DOOR
LIFT HANDLE
CENTER STILE
END STILE
VERTICAL SLOT
LATCH HOLE
REVERSE ANGLE
OR REVERSE
BRACKET SHIELD
LOCK-ON BOTTOM ROLLER BRACKET
(SCREWS REQUIRED TO LOCK-ON
TO BOTTOM OF WOOD DOORS)
PACKET FOR OWNERS
DOOR AND OPENER
INSTRUCTION MANUALS
#2 DOOR SECTION
#3 DOOR SECTION
#4 DOOR SECTION
(TOP DOOR SECTION)
FOR OPTIONAL
3“ - 6” (51 - 102)
TRACK EXTENSIONS
SEE PAGE 11
FOR OPTIONAL SIDE
LATCH SEE PAGE 16
HOLES FOR OPTIONAL
CENTER LOCK
HOLES FOR OPTIONAL AUTOMATIC
DOOR VAULT RELEASE
TORSION TUBE
HORIZONTAL
TRACK
COPYRIGHT © 2004 MARTIN DOOR 23
FASTEN PACKET TO
WOOD DOOR WITH
SCREWS PROVIDED
MARTIN FINGER SHIELD™ GARAGE DOOR SYSTEM*
•SAFETY SECTION ASSEMBLY •SAFETY TRACK ASSEMBLY •SAFETY SPRING ASSEMBLY
HELPS PREVENT GARAGE DOOR INJURIES TO CHILDREN AND ADULTS
*
o P f e o l L w r i
e in H g
r Shi nge l i e d F
M T
FI GER SHIELDS N
RE STA DA D O DO S A N R N OR
UP TO 9’ (2740) IGH H
r

D
o
o
D
r

o
o
STEEL DOOR
ALL HINGES FASTEN FACE
DOWN ON WOOD DOORS,
FACE UP ON STEEL DOORS.

D
o
r
o
o P f e l L w ro i
n e i g H
r

D
o
o
SA ER F NGER SHIEL F I D
OINT ARE STANDAR ON J S D
WOODS D RS OO
WOOD DOOR
nge el Fi d r Shi
e J i nt ct on i S o
M T
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 61 of 65 PageID# 601
Exhibit U

Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 62 of 65 PageID# 602
DONOT
CAUTION!
The insulation
Martin
The MartinWarranty
completely weather seal this door! Vent according to local building codes.
Low levels of carbon monoxide in the garage and home can cause headaches
and flu-like symptoms. Additional venting may be required to help reduce the health risks
associated with combustible fuels and noxious fumes.
used in Martin Doors complies with all known building codes. It has been
tested and approved by Omega Point Laboratories and meets the UBC-26-8 standard for
smoke and flame spread. The insulation is removable and reusable, which helps the
environment by reducing landfill waste!
regular and insulated door sections are rated among the most dent resistant in the
world. They do not require insulation bonded to them for strength. Because of this unique
construction it may not be necessary to replace a door section or a complete door to avoid
the prolonged appearance of a damaged surface. For dent repair see page 18.
is to the original owner. Lifetime ltd. for most residential doors (12 year
ltd. on Montana). Six Year ltd. for commercial, and rentals. Replacement part shipping and
labor costs are not included. Springs have life cycle limits.
Contact your
Martin Dealer for details on the full written warranty and limitations.
Note: with proper care and
maintenance all Martin Doors (except springs) are designed to last a lifetime.
2008
Martin Door Manufacturing Salt Lake City, Utah 84127-0437 U.S.A www.martindoor.com Printed in the U.S.A. 20m Copyright 2008 © AD-01IM-08
MAINTENANCE
DOOR OPENERS (We recommend Martin Door Openers)
NOXIOUS FUMES
INSULATION
DENT REPAIR (Steel Doors)
THIS IS THE WORLD’S FINEST, SAFEST DOOR. HOWEVER, UNTRAINED OR NEGLIGENT INSTALLING, ADJUSTING, AND SERVICING CAN BE DANGEROUS. THE SPRINGS
AND RELATED PARTS CAN CAUSE SERIOUS INJURY OR DEATH! IFUNSURE, CALL A TRAINED MARTIN DOOR DEALER
Oil
Wax
As needed
Touch-up paint
As needed
Clean
Always
Monthly
Martin
Remove
The top door section
all hinges, roller shafts, and spring coils, using a high quality 10/40 motor oil.
Oil yearly for a smooth operation. Do not allow parts to squeak!
yearly the leading edge of metal door Finger Shields. Also wax Reverse Angle
Shields or jambs where door seals while closing.
, use lightly oiled cloth to wipe galvanized parts to help retain clean galvanized
look. In damp, wet areas, galvanized parts may require painting to help prevent rust.
is not recommended if more visible than the scratch. Read “Painting
Theory” on back page.
, wash away dirt, salt residue, etc. from door sections. Automobile type
cleaners and waxes may improve the look and prolong the life of aged paint on a
neglected door. Frequent waxing or painting may be required in extremely damp, salty or
caustic areas. We recommended that copper doors be allowed to age gracefully.
the acrylic windows with a soft wet cloth. Remove scratches in the acrylic window
pane with a quality plastic window cleaner.
keep the garage door in full viewwhile using the electric opener.
check the automatic reverse function, following the manufacturer's
electric opener instructions.
Doors are designed to reduce risk of entrapment and injury to children and adults.
Roller Shields, Finger Shields, LowProfile Hinges, ReverseAngle Shields, Inside Lift
Cables, Rolled Steel Edges, etc., are all designed for added child safety .
all pull down ropes and disable any garage door locking mechanism.
may need a full length strut for center mounted openers. Side
mounted openers may not require a strut on single size doors under 12’3” (3730) wide.
.
.
.
.
.
WARRANTY
MARTIN FINGER SHIELD™ GARAGE DOOR SYSTEM
FINGER
SHIELD
TM
MARTIN
ISO 9001 A8949
MARTIN DOOR MFG.
R
E
G
I
S
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GARAGE DOORS
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GARAGE DOORS
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S I N C E 1 9 3 6
INSTRUCTION MANUAL
ISO 9001
Quality
Standard
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 63 of 65 PageID# 603
1. Follow the regular Instruction Manual except the extruded aluminum
type door does not have clip-on Finger Shields. The Finger Shields are
designed into the aluminum door extrusion. Stack sections following
Aluminum Door Section Placement Chart. See page 2.
2. For doors up to 9’(2740) high, fasten all low profile hinges “face
down” into the grooves provided in the horizontal rails with
3. Use reasonable care in fitting/stacking each Carriage House/Arch
Crest section over the clear polycarbonate finger shield inserts that are
screwed inside the vertical board/stile designs. See 2.
4. Install Lock-on BottomRoller Bracket as shown on page 4.
1/4” x1”
thread forming screws. Fasten to stiles and rails using the pre-drilled
1/8”(3) holes. See FIGURES 1 and 2.
FIGURE
See FIGURE4
For doors over 9’(2740) high,
fasten all low profile hinges regular “face up”.
5. For Antique Hinge, decide, level, mark, and drill one 1/8”(3) hole
through first aluminumextrusion in horizontal rail. See FIGURES3 and 4.
Attention! Do not drill through second aluminumextrusion.
EXTRUDED ALUMINUM TYPE DOORS
6. Fasten Antique Hinge with one (5/8”(17) long) stainless steel black screw
provided.
1/8”(3) holes
in the horizontal rail. 5/8”(17) long)
provided. See FIGURES3, 4 and 5
See FIGURE5
7. Level the Hinge with the Horizontal Rail, then drill the other three
Fasten the hinge with three additional (
stainless steel black screws
8. Decide, mark, drill, and fasten the remaining hinges and handles following the
completed door example.
FIGURE 1 FIGURE 2
CLEAR POLYCARBONATE
FINGER SHIELD INSERT
FINGER SHIELD JOINT
“OUTSIDE” CARRIAGE HOUSE ALUMINUM DOOR SECTION
VERTICAL
BOARD/STILE
SCREW
FINGER SHIELD JOINT
HORIZONTAL
RAILS
GROOVE
LOW
PROFILE
HINGE
“FACE DOWN”
“INSIDE” ALUMINUM DOOR SECTIONS UP TO 9’(2740) HIGH
FIGURE 5
FIGURE 3
TOP DOOR SECTION
(5/8” (17) LONG)
STAINLESS STEEL
BLACK SCREWS
EDGE OF
DOOR JAMB
HORIZONTAL
RAIL
1/2” (13) MINIMUM
STILE
FIGURE 4
ANTIQUE HINGE
SECOND
ALUMINUM
EXTRUSION
FINGER
SHIELD
STAINLESS
STEEL
BLACK
SCREW
COPYRIGHT © 2008 MARTIN DOOR 22
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 64 of 65 PageID# 604
#1 DOOR SECTION
(BOTTOM DOOR SECTION)
OPTIONAL PUNCHED
ANGLE TRACK HANGER
COUPLER
TORSION
SPRING
BLACK
SPRING WINDING CONE
CENTER BEARING
BRACKET
GREY STEALTH PLUGS
OR RED SAFETY CAPS
RED
SPRING WINDING CONE
BOTTOM
WEATHER SEAL
BOTTOM
REINFORCINGANGLE
VERTICAL
TRACK
TRACK
BRACKET
FLAG
ROLLER SHIELD™
AND ROLLER
SIDE SPRING
ANCHOR BRACKET
SPLICE
PLATE OR
SPLICE
BRACKET
LOCK-ON SIDE
BEARING BRACKET
BLACK
CABLE DRUM
HORIZONTAL
TRACK
HORIZONTAL
TRACK ANGLE
RED
CABLE DRUM
TOP ROLLER
BRACKET
#3 ROLLER
BRACKET
AND HINGE
#2 ROLLER
BRACKET
AND HINGE
#1 ROLLER
BRACKET
AND HINGE
INSULATED DOOR
LIFT HANDLE
SPRING
ANCHOR CONE “L” STRUT
LIFT
CABLE
ROLLER SHIELD
AND ROLLER
LOW PROFILE
HINGES
INSULATED DOOR
LIFT HANDLE
CENTER STILE
END STILE
VERTICAL SLOT
LATCH HOLE
REVERSE ANGLE
SHIELD OR REVERSE
BRACKET SHIELD
LOCK-ON BOTTOM ROLLER BRACKET
PACKET FOR OWNERS
DOOR AND OPENER
INSTRUCTION MANUALS
#2 DOOR SECTION
#3 DOOR SECTION
#4 DOOR SECTION
(TOP DOOR SECTION)
FOR OPTIONAL
3” - 6” (51 - 102)
TRACK EXTENSIONS
SEE PAGE 11
FOR OPTIONAL SIDE
LATCH SEE PAGE 16
HOLES FOR OPTIONAL
CENTER LOCK
HOLES FOR OPTIONAL AUTOMATIC
DOOR VAULT RELEASE
TORSION TUBE
HORIZONTAL
TRACK
COPYRIGHT © 2008 MARTIN DOOR 23
CURVE SHIELD
(ON DOORS UP
TO 8’ HIGH (2440)
BOTTOM WEATHER SEAL AND ANGLE INCREASES
DOOR HEIGHT ABOUT 3/4” (19)
CONTROLLED
DESCENT DEVICE
MARTIN FINGER SHIELD™ GARAGE DOOR SYSTEM*
• • • SAFETY SECTION ASSEMBLY SAFETY TRACK ASSEMBLY SAFETY SPRING ASSEMBLY
HELPS PREVENT GARAGE DOOR INJURIES TO CHILDREN AND ADULTS
*
Low Profile
Hinge
Finger Shield
TM
FINGER SHIELDS ARE
STANDARD ON STEEL/COPPER
DOORS UP TO 9’ (2740) HIGH
D
o
o
r
D
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ALL HINGES FASTEN FACE
DOWN ON ALUMINUM DOORS
UP TO 9’(2740) HIGH.
D
o
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r
Low Profile
Hinge
D
o
o
r
FINGER SHIELD JOINTS
ARE STANDARD ON
ALUMINUM DOORS
Finger Shield
Section Joint
TM
Case 1:13-cv-01329-TSE-TRJ Document 38-3 Filed 01/07/14 Page 65 of 65 PageID# 605