2:21-cv-02014-CSB-EIL # 1 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND

FRENCHPORTE, LLC, )
FRENCHPORTE IP, LLC )
)
Plaintiff, )
) Civil Action No. ___________
v. )
)
C.H.I. OVERHEAD DOORS, INC. ) JURY TRIAL DEMANDED
)
Defendant. )

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiffs FrenchPorte, LLC and FrenchPorte IP, LLC (“FrenchPorte”) files this

Complaint against Defendant C.H.I. Overhead Doors, Inc. (“CHI”), 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 consists of two Maryland LLCs. FrenchPorte is the assignee

and owns all right, title, and interest to U.S. Pat. No. 9,272,558, or the '558 Patent.

2. CHI is an Illinois corporation, with its principal place of business at 1485

Sunrise Drive, Arthur, Illinois, 61911. CHI engages in the development, manufacture and

distribution of garage doors. CHI may be served with process by service on its registered

agent for service, Tisha L. Pfeiffer, 1485 Sunrise Drive, Arthur, Illinois, 61911.

Jurisdiction and Venue

3. 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).
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4. CHI has transacted business in the State of Maryland, and has caused

tortious injury in this State by an act or omission outside this State and derived

substantial revenue from goods used or consumed in this State, by (a) establishing a

network of authorized dealers, with the intent and for the purpose of selling CHI garage

doors to persons in this State, and by (b) selling CHI garage doors that are made by a

process that infringes the '558 Patent to persons in this State through CHI dealers. (See

Ex. A).

5. CHI has offered for sale and sold residential “Accents Woodtones” doors

in this State that are made by a process that infringes the '558 Patent as described below.

6. Venue is proper in this District, under 28 U.S.C. §§ 1391 and 1400. CHI

resides within this District.

Factual Background

7. For the past 20 years, FrenchPorte has created innovative overhead garage

doors that are much more attractive than standard metal garage doors. The original

FrenchPorte design was a garage door that looks just like French doors – hence the name

of the company. An example from FrenchPorte’s website is reproduced below:

(Ex. B at 1).

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8. 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). Accordingly a FrenchPorte garage is difficult to recognize as a garage at all

as the following picture illustrates:

(Ex. D at 1).

9. 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:

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(Ex. E at 1).

10. 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).

11. 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

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).

12. 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.

13. After years of work, the first FrenchPorte doors were exhibited 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

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from potential customers started rolling in as to how to obtain the door and at what price.

(See Ex. M at 1).

14. While FrenchPorte’s aluminum doors did reasonably well in the

marketplace, they were much more expensive than normal garage doors, so much so that

the Great Recession and infringement of FrenchPorte’s patents by Martin Doors and

Raynor hurt FrenchPorte’s full potential. FrenchPorte brought suit against both of these

companies based on its patents, and both of those cases settled prior to trial.

15. Thus vindicated, in the late 2000s, FrenchPorte’s CEO, Mr. Ken Maher,

came up with a new idea for making attractive garage doors that was much less expensive

than the original FrenchPorte door and palatable to consumers post-Great Recession: use

large format printers to print high resolution images onto the doors so they look like

French doors, or wood, or whatever style a customer desired. This provided infinite

customization at a fraction of the cost of making an aluminum FrenchPorte door. He filed

a patent application describing his invention on September 16, 2009.

16. In 2012, while his patent application was still pending, Mr. Maher shared

his idea with the then-CEO of CHI, Jim Oberholt, who flew in from Illinois to see how

the print door was manufactured. Mr. Oberholt took a video of how the process worked

and loved the idea.

17. Following this meeting, Mr. Maher and Mr. Oberholt engaged in licensing

negotiations. CHI and Mr. Oberholt insisted Mr. Maher would never be issued a patent

for his process. Mr. Oberholt later retired in early 2016, and was replaced by Mr. David

Bangert. Mr. Maher attempted to resume negotiations with Mr. Bangert. In response Mr.

Bangert insisted the printed garage door was CHI’s idea.

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18. In parallel with these negotiations, on August 18, 2010, a patent attorney

named Mr. Philip L. Bateman filed a letter with the U.S. Patent and Trademark Office

(the “PTO”) in connection with Mr. Maher’s patent application notifying the PTO that a

patent application filed by a Mr. Scales “may be material to the patentability of the claims

in the above-identified patent application.” While Mr. Bateman declined to disclose

whom he represented, stating in his letter he was simply “a party who is not associated

with the filing or prosecution of the above- identified application” in fact Mr. Bateman

has represented CHI before the PTO in 2004 in connection with U.S. Pat. No. 6,735,905,

suggesting Mr. Bateman was paid by CHI to attempt to undermine FrenchPorte’s patent

claims. This is also suggested by Mr. Bateman’s highly unusual location in Decatur,

Illinois, only 30 minutes from CHI’s headquarters, Arthur, Illinois, both remote locations

in Illinois 180 miles south of Chicago. In particular, Arthur, Illinois is a village with an

estimated population of just over 2000 people, and is a significant location in the Amish

community, with just over 4,000 Amish living in the town and nearby, making it the 8th

largest Amish community in the world, according to Wikipedia. Given that the Amish

forbid the use of most technology introduced over the past two centuries or so, including

for example the use of motorized vehicles, Arthur is an unusual location for a patent

attorney to do business to say the least. For all of these reasons, it can be reasonably

inferred that Mr. Bateman was surreptitiously acting on CHI’s behalf, as will be further

confirmed through discovery in this matter.

19. While Mr. Bateman’s efforts succeeded in delaying Mr. Maher’s patent

from issuing for six years, during which time CHI made millions of dollars selling

digitally printed doors, ultimately Mr. Maher and his attorneys convinced the PTO that,

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while Mr. Scales did indeed suggest the idea of printing on garage doors, he did not

invent what Mr. Maher had invented: a practical process for doing this type of printing on

a massive scale. In particular, as Mr. Maher knew from years of garage door

manufacturing experience, garage doors are not flat and thus are particularly difficult to

print on: they are warped and thus it is very difficult to obtain a good print quality on

garage doors. For that reason, the industry had long dismissed the concept as impractical

– as Mr. Scales himself found out, because he abandoned his own patent application

before it issued.

20. Mr. Maher, however, discovered that by applying a vacuum to the bottom

surface of the door it could be flattened and thus printed on at high speed. While the PTO

argued in response that this feature was obvious in view of certain references disclosing

the use of vacuums in printing operations, Mr. Maher and his attorneys pointed out that

these references only suggested using a vacuum to hold the material to be printed on (a

“substrate”) in place – but instead disclosed using a variable height print head to deal

with substrates that had varying surfaces. Thus these references not only didn’t disclose

what Mr. Maher had invented – they in fact taught a very different approach to printing

on variable height surfaces – move the print head itself – rather than using a vacuum to

flatten the substrate so that printing with fixed height print heads at high speed was

practical.

21. On September 18, 2015, the PTO agreed with Mr. Maher and his attorneys

that Mr. Maher’s process was indeed new and not at all obvious to those in the garage

door manufacturing field, and accordingly issued the '558 Patent.

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22. Following this, Mr. Maher continued to attempt to strike a deal with CHI,

only to continue to have CHI reject his proposals and insist their manufacturing process

was their invention, not Mr. Maher’s. This was, of course, entirely possible: CHI was free

to use manufacturing methods such as a variable height print head that were disclosed by

others so long as they did not use a vacuum to flatten garage doors for printing. CHI’s

manufacturing process was conducted in secret in the remote location of Arthur, Illinois,

making it impossible for Mr. Maher to readily verify CHI’s claims.

23. Mr. Maher, however, retained an expert, Mr. Christoph Hörmann, CEO of

Hörmann, the largest garage door manufacturer in Europe, to determine whether CHI

applied “negative pressure on at least one [] door section having a warped portion, said

negative pressure sufficient to secure and hold said warped portion of the section flat on a

support during printing such that the surface of the door section to be printed is uniformly

spaced from the support . . .” as claimed in his patent. ('558 Patent, Claim 10, col. 12, ll.

32-37). The '558 Patent is infringed by any manufacturing of a garage door that falls

within the scope of any one of its claims, such as claim 10.

24. In Mr. Hörmann’s opinion, CHI manufacturing process does use such a

step. (Hörmann Declaration ¶¶ 9-10).

25. CHI’s accent doors continue to sell briskly, which Mr. Maher estimates

will total 80,000 doors this year at around $900-$1000 per door, most of which is profit

given that plain steel doors are only around $200 per door.

26. Mr. Maher and FrenchPorte accordingly bring the instant lawsuit so that

the past 20 years of work by himself and his wife can finally be rewarded with the

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commercial success it should have enjoyed but for CHI’s unfairly practicing their

invention without paying the Maher’s a dime.

Count 1 – CHI’s Infringement of U.S. Patent No. 9,272,558

27. FrenchPorte incorporates by reference the material factual allegations

above.

28. CHI has infringed and is continuing to infringe the '558 Patent by

engaging in acts including making, using, selling, or offering to sell within the United

States, products made by the process described and claimed in the '558 Patent, including

CHI’s Accents Woodtones garage doors.

29. CHI’s activities have been without express or implied license from

FrenchPorte.

30. CHI will continue to infringe the '558 Patent unless enjoined by this Court.

As a result of the CHI’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 preliminary and permanent injunctive relief against such infringement, under

35 U.S.C. § 283.

31. As a result of the infringement of the '558 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

32. FrenchPorte demands a trial by jury on all appropriate issues.

//

//

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Prayer for Relief

Therefore, upon final hearing or trial, plaintiff FrenchPorte prays for the

following relief:

(a) A judgment that CHI has infringed the '558 Patent;

(b) A judgment and order permanently restraining and enjoining CHI, 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 '558 Patent;

(c) A judgment and order requiring CHI to pay damages to FrenchPorte adequate

to compensate it for CHI’s wrongful infringing acts, in accordance with 35 U.S.C. § 284

and 35 U.S.C. § 289, of at least $45,000,000;

(d) A judgment and order requiring CHI 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

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

Dated: February 21, 2020

Respectfully submitted,

Geoffrey C. Mason
Bar No. 15772
Moarbes, LLP
Senior Partner
2200 Pennsylvania Ave, NW
4th Floor, East Tower
Washington, D.C. 20037

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 2:21-cv-02014-CSB-EIL # 1-1 Page 1 of 2
JS 44 (Rev. 08/16) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

Frenchporte IP, LLC and FrenchPorte, LLC C.H.I. Overhead Doors, Inc.

(b) County of Residence of First Listed Plaintiff Montgomery County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Geoffrey Mason Esq., Moarbes, LLP, 2200 Pennsylvania Ave,
Washington D.C. 20037 240-888-7644

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4
of Business In This State

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

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

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Clic ere for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 3729(a))
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of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud Act ’ 862 Black Lung (923) ’ 490 Cable/Sat TV
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’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 Agency Decision
’ 245 Tort Product Liability Accommodations ’ 530 General ’ 950 Constitutionality of
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION State Statutes
Employment Other: ’ 462 Naturalization Application
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Other ’ 550 Civil Rights Actions
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’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’ 1 Original ’ 2 Removed from ’ 3 Remanded from ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict ’ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 USC 271
VI. CAUSE OF ACTION Brief description of cause:
Patent infringement of U.S. Pat. No. 9,272,558
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions): Theodore D. Chuang 8:14-cv-00295-TDC
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
2/21/2020 /s/ Geoffrey C. Mason, Esq., Bar Number 15,772
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

JS 44 Reverse (Rev. 08/16) 2:21-cv-02014-CSB-EIL # 1-1 Page 2 of 2

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
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I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
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VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
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Date and Attorney Signature. Date and sign the civil cover sheet.
 2:21-cv-02014-CSB-EIL # 1-2 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

FRENCHPORTE IP, LLC, and ​)

FRENCHPORTE, LLC, ​ ​)
)
Plaintiffs, ​ ​ ​ ​)
) ​Civil Action No.
___________
v. ​ ​ ​ ​ ​)
)
C.H.I. OVERHEAD DOORS, INC. ​)
Defendant. ​ ​ ​ ​) ​JURY TRIAL
DEMANDED

DECLARATION
Declaration of ChristophOF _____
Hormann

1. My name is Christoph Hörmann, Managing Partner of

Hörmann, the largest garage door manufacturer in Europe. I
am familiar with the manufacture of sectional steel garage
doors and the printing process on sectional steel garage
doors because these are both products offered by Hörmann.
As the managing partner of that company, I am of course
extremely familiar with such manufacturing processes,
which are essential to our operations.
2. During manufacture of printed sectional garage doors,
each section is manufactured individually on an assembly
line and each section is individually printed upon. After this
printing, other manufacturing steps are undertaken to
produce the final garage door product, including joining all
t
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of the sections together using hinges.

3. Steel garage door sections are manufactured from flat
rolled steel, which is received at a garage door
manufacturing factory in large circular drums that look like
the following:

4. The steel on these circular drums is uncoiled, flattened

and roll-formed as part of the sectional steel garage door
manufacturing process. While steel can be purchased in
other forms, for garage door manufacturing, the only
commercially viable form of purchasing steel is in a roll of
this kind, typically received via railroad to further reduce
costs. The steel garage door market is very price sensitive,
so it is extremely important to minimize the cost of the
materials used in their manufacture.
5. Steel will be roll-formed to make the garage door
sections, which while flat to the naked eye, are in fact
warped and uneven when examined more closely because
the roll- forming process is not perfect and there needs to
be a vacuumed seal to insure a perfectly flat section every
time, especially for this printing process. Put another way,
if the sections are not held down tightly with a vacuumed
seal on the flatbed as the sections go through the printing
assembly line, you will not get a perfect image on the

t
sections due to the slightest warp and unevenness of the
 2:21-cv-02014-CSB-EIL # 1-2 Page 3 of 4

sectional steel surface. If you were to put a section through

the printing assembly line without a vacuumed seal the
process and method of printing on the section would not
work.
Each of the garage door sections is made up of a sandwich
that is: (1) a first apparently flattened steel plate; (2)
polyurethane, an adhesive type of foam; (3) a second
apparently flattened steel plate. This three part sandwich
creates a garage door section that has apparently flat
surfaces of steel on both sides.
6.
7. The garage door industry uses a “Plattenband” machine
to create pressure to flatten the sections themselves. The
“plattenband” puts pressure on the sections just after
polyurethane foam is put on the apparently flattened steel
plates. This foam reacts with oxygen so if you don’t press
the sections using a plattenband, you will have oil canning
and bumps on the section.
8. Even though garage door sections are made to high
industry standards, they are never completely flat enough to
go through a printing assembly line and create a flawless
image without using a vacuum. The newly made sections
going through the printing assembly line have to be held
down with a vacuum seal to get rid of any steel surface
imperfections, that is, slight warping, creases, dents or
bending not visible with the naked eye. The sections also
need the vacuum seal to keep the section from moving at
all during printing and to make sure the section is the right
distance from the printer head. The fact that you need to
use a vacuum seal for proper printing distinace proves that
the steel is always slightly warped, creased, or dented in
one way or another. The large scale digital printer on the
assembly line prints an image, such as of a wood grain or
of a French Door image, onto the flat surfaces of the garage
t
 2:21-cv-02014-CSB-EIL # 1-2 Page 4 of 4

door sections to make a whole printed garage door.

9. Accordingly, in my opinion, any large scale
manufacturer of sectional garage doors making printed
garage door sections must be using a vacuum seal to flatten
the section even more to get rid of any small imperfections
during printing.. The only mechanism that can achieve the
necessary flatness at a large scale is a vacuumed seal to
insure the disappearance of any small imperfections during
printing, producing a perfect image.
10. C.H.I. Overhead Doors, Inc. (CHI) is a very large scale
manufacturer of sectional steel garage doors that have
printed images on them. In my opinion, CHI must
accordingly be using a vacuumed seal in their
manufacturing processes for these doors during printing.

feiere
flüster ____________________
-

_
Christoph Hörmann
Managing Partner of
Hörmann

2 Merch Eth 2019

,
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Exhibit B
 FrenthPorte - B^Jutilul A Elegant French Cif3ge Oooi
,< t- ; & + W frtnchpone.com
cgSgJji o
«"» CD E3 Appte V«hoo1 CoogltMapt VouTulw tttkjfwdii Nwn* Popular* W*b Hwllng.-.bMail login PNC RSS f»«i* *
Call: 301.230.7125 fofiowu*: t D
Our personal philosophy it thai 'nothing
ever has 10 be unattfaarvt'" For the list
lew years, f renenporte has been driven to
develop and patent a line of fnnovairve Or Call:
garagedoors based on this principle.Our 301.230.7125
Frenthporte family, whose name comes
from the concept of a French door, is
uniQuery designedespecialV fo* the homeowner whoIs feeing the front loadgarage doerdilemma. Withus
durability, dependability andcurbside appeal; asaconsumer, nowthereareoptions because nowthere is irenenporte.
Now « Mltci Lowe's Store*. Lowe's. Never Stop Improving.
Louie's
Understanding The Design
When form and function blend seamlessly
Frenchpone LLCis pleased to introduce our expanded line of innovative
garagedoors! The garage« one areathai ISmost often overlooked when
creatinga particular look or feel in the home, yet u is undoubtedly a
majorcomponentof the home's overall balance andcurbappeal.The
FrenchporteGarage Door now allows you to take what was once ordinary
and maVe it extraordinary by Iniroduttng tout uniformity and harmony,
isn't it time you considered a garage door that ts complimentary to the
rest of your home?
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Exhibit C
 FrenthPofti' Beautiful & F_l**g*nt ftpnch Garage Ooori
Q + 0 ffenehpone.com
M CO SI Apple Yahoo? Coog> Mapi YeuTute Wlldprdi* N*wt • Popular' WtbHotting bMail Login FNC HAS fe»d*»
FrenchPorte
Affordable Elegance
Unparalleled Beauty & Strength
Our personal philosophy n thai "nothing
ever has lo tie unattractive** For the last [ gram )
few years. Frenthporte has been driven to
develop and patent a line of Innovative Or Coll:
garage doors based on this principle. Our 301.230.7125
Frenthpone family, whose name comes
from the concept of a French door. 11
uniquelydesigned especiallyfor the homeownerwho is lacingthe From load oaragedoor dilemma,Wtthms
durability, dependability andcurbudeappeal; as a consumer, nowthereareoptionsbecause nowthereis Frenchpone.
v at select Lowe's Stores. Lowe's. Never Stop Improving.
Louie's
Understanding The Design
When form and function blend seamlessly
Frenchporte LLC Is pleased to introduce our expanded Itne of innovative
garage doors' The garage (s one area that is most often overlooked when
creating a particular look or feel in the nome. yet it is undoubtedly a
major component of the home's overall balance and curs appeal. The
Frenchpone Carage Door now allows you to take what was once ordinary
and make ft enraordinarv by introducing total uniformity And harmony,
isn't it time you considered a garage door that is complimentary to the
rest of your home?
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Exhibit D
 FrenthPorte Before & Afters - dtigf Ooot Makeover I FrenthPorte Garage 0oor\
o |
w CD 3 Appt* Ythool CoogWMips VouTube W.WpedU N*wt~ Popular * Web Hinting b*Uil login FWC ftSSf*•<!**
JT1
FrenchPorte Call: 301.230.7125 rottowu* lt)H
a •. . • j.'Ti.^.J.
!!!!# !!!!!!# !!!!!!!§ :!!E!E!!E
Door Selection
Before & After
Before A Afiet
Safety Features
Security Features
installation GuWe
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Exhibit E
 PrenthPorte Before A Afters - drag* Doo* Makeover | frenchPortf Garage Doors
i < > i : i© , +i t$ frenchporte.com h ,. •>•> ij>,^' 'r>»to<e ,<!>.••
««» CD 53 Apptt VaNw) Google M*pi VouTubc Wliripedl* fc*wt» Repute- * Uf«b Hotting..b&Uil LoQin PNC RS5 fwdft*
French Porte
Door Selection
Before & After
Before A After
Safety Features
Security Features
installation Guide
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Exhibit F
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For more information, contact

Jennifer Mahf r, TELEPHONE;
EMAIL

Make-Up Artist Launches Company to Improve Curb Appeal

Invents French Doorsfor Garage that Roll Up into Ceiling

ROCKV1LLE, MO—Five years ago, Jennifer Maher, a TV make-up artist, turned her
critical eye on the blank faces ofAmerica's garage doors, and she did not like what she
saw. Soshe invented a new garage door, and it's now ready for prime time.

"It just completes the look ofabeautiful home," said Maher, who was featured on
HGTV's Sunday night program on innovators at the recent Las Vegas builders
convention.

Made ofaluminum and polycarbonate. Maher's garage door looks like aset offancy
French doors, but itrises up into the ceiling ofthe garage, just like the traditional door
she hopes it will replace.

Maher—who has made up the faces ofluminaries such as Cokie Roberts, Leonardo de
Caprio and Bill Clinton- -was inspired after visiting adevelopment of new houses, where
the builder had turned a garage in a model home into a temporary office and had replaced
the garage door with French doors.

•1 told them I'd be interested in a house with those doors," Maher said. "They told me
that the situation was only temporary and that they would be reinstalling that ugly garage
door as soon as the house was sold."
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Maherwas hooked. After finding out it had not been done before, she patentedher idea
fora new kind of garage door, and sheand herentrepreneur husband, Kenneth, began to
workon a business plan for the company she founded. FrenchPorte™, LLC.

They hired an engineer to build a prototype forthe I-renchPorte™, and located a factory
thatcould reproduce the high-quality product. Jennifer designed twostyles, which she
named afterherdaughters Kendra and Madeleine, and came up with a range of colors
that would complement the facades of most houses. The company's website
(www, frenchnone .com! features a before and after video that demonstrates the impact
the Fiuivhl\vu doors car. have :r. ".he curb aprc.*.! of?, house.

Maher notes that the doors assure privacy, as the polycarbonate is frosted. And because
the material is translucent, it allows in the suns rays, which warms up a space that is
traditionally the coldest room in the house.

"I'm tryingto get people to think outside the box—literally," Mahersaid. "1 thinkwe're
going to find that people are tired of pretending that their plain-Jane garages match the
style of their lovely homes."

FrenchPorte, LLC. is wholly owned and operated by Jennifer Maher, who believes that
nothing ever has to be unattractive. FrenchPorte'", coming from the concept of a
French door, is uniquely designed especially for the home owner who is facing the
front load garage door challenge. It allows the convenience of the overhead garage
door but with the lovely overall look of French doors. It also looks great on the side
and back of the home too!

With Its durability, dependability and beautiful curbside appeal, as a consumer now
there are options because now there is FrenchPorte'".

It makes your house a home.

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Exhibit G
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Making It
A FORMER MAKEUP ARTIST
BUILDS A BUSINESS
BEAUTIFYING
GARAGE DOORS
By Elizabeth Chang
KNNii-iU; MAHI-.lt sees a clear link be-
v.t • !«' »,! 1 ;,rier ;•• \ t, ! v. : ;;'• ",
and her new out as a garage door in-
vrntor. "hirst I did people makeovers.
Now I'mdoinghome makeovers."
The 49-year old ChevyChase resident
savsshe "just can't stand to see things not
lock a* good asthey can." So. when she and
iu-r husband. Ken. \seie looking a( new
house; in the i.uc i»-k.s. ;i bothend hci
that the garages looked like l»ii» ugiv boxes
Hist plopped on the trout <>t the ho:-'.ts.
I low h.ud v.i.nl.i i! be, ihc icmeniht'is
thinking to lo.ib' a garauc dm>i th.ii \\:v-
.int." tut ••in: that looked like a I tench
door I»ir ":i!l opnarrd :• • an ovettv-ad door.
' She s <>i>i .1 good eye. says Ken, 4$.
lenmrer. whogrew up in Silver Spring,
s.i\.s she was alwavs intctested in cosmerics
and appearances. I let parents discouraged
her pursuitot a makeup career, however, so
she majored in communications at the Uni
versity or Mankind. But. wit!) Ken's en-
t oiiiagement. sheeventually followed lift
passion spending a decade as a makeup
aitiM at AFH New* in Wellington
Xhenthen -csond daugiuct was horn in
! n*. Jennifer sin back to part time, which, al
lowed herto pursue thegarage door idea. She
worked wiih an engineer to comeup withthe
materials tobring herdesign to fruition, using
•iinbieakabie polycarbonate pliistit lor the
hosted "glas.s" andaluminum lot theframing.
Shenamed thecompany l:tenchPotte ("pone"
being irendi tordoor). Her early reception
was difficult, she says; themostly male garage-
eioot dealers were underwhelmed, though
theirwives "immediately got it." But HGTV
named FrenehPorte a hot newproduct at the
2004 International Builders'Show.
The Mailers found a Pennsylvania manti-
lacuuetand a is-state garage-dooi distiibutor
and began selling doorsin 1004. In 100(1. to
lower costs, theymoved production to China.
Ken Mahet's success withhis mortgage
brokerage andbanking company and the
couple's real estate investments allowed the
N(alters to fund the research, earlyproduc-
4 GwttlMtim^roflwtflkaaiin*
OPENOPPORTUNITY: Jennifer Matter and her
garage French doors.
tioii and inj-i.,!>:. ieg.,1 tee- to n.i'.ei:! the
doors. I he company had $w, :>>,<• „\ u liolo-
•ok levcnucl.lsi vy.t: Ken s.o-s. .m,i this '.cai
I- .elhug.Uor;U!lu-| of .Vi . I,, |;,.. ,|u, ,js ;-i0
mom!, in >:vt;i\:rib>:tor for about >::..-.<j< ...
iSit M.lhtls .,11 l.tikll.i: It: olinp.slil:.':. ill Alls-
•:.ii:.i -l!\d hiiii'tv .ir-niit nunuraanrmK .iriti
-elling doorsiheie
! he three models of doors (named loi
daughters Madeline, v.and Keiuiu. l«;- and
toi leiiiiiler.i start .1! around $3,000 for sin
glesloors and >4,000 for doubles, includ
ing installation, and have a limited litetiim-
•.variantv
riiey tegoigcoiis. 1hey give a real dilTcr-
<r,: look toyour house savs Katrina Moig.m
•>'. I'riiise Fiedcnck. Sheand her husband
liked the appearanee oi garages that hud been
1•'livened10 olikes and outfitted with French
siooi.,. Km ihev wanted then garage toremain
a gauge. Katrina foundan ad for FrcnchPortc
in alocal home design magazine, "We didn't
know it was out there." she savs.
in addition to being sold to dealers
through thedistributor, the doorsaxe olfered
through FrcnchPortes Web .site and will be
available atthecompany's Roclcviiie shosv-
:oom. e.vpecied toopen in September. Jen-
niter will do some ofthe sales liciself. "I've got
the passion. I've got the idea. IVe got every
thing it takes for people to understand these
duoi.s," she says. It's been along road, and
I'm exhausted. But I'm as proud ofthis as I
could beofanything.''
Have you used skills acquired Inone careerto
launch a related business? E-mail
changb@washpost.com.
-i.-i.js. 1s. .<cj- I nuBjrtinjbnPixlnUeaiitif 5
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Page

Exhibit H
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Page

expert interview

A Different Kind of
Garage Door
FRENCI-IPORTE OVERHEAD GARAGE DOORS,
one of HGTV's "100 Best Innovative ideas,"
.ire desigiH-d to look just like ITench doors.
They were invented by a woman with a highly de
veloped aesthetic sense: Jennifer Maher. a make-up
artist with ABC News in Washington. "My personal
philosophv" \;ivs Maher, "is that nothing evei has
to be unattractive.

WWkG: How did you get the idea for liench- stalled ITench doors. This made the whole
I'orle garage doors/ house look better.

Some years ago, vvliile we wen1 house hunting.
we found that many houses had garages that
faced the street, something I found unattrac
tive. At the time, I noticed that some model
homes had offices in their garages and had in
U'H&G: How dot's the Frenchl'orte door open/
It rolls up in sections just like a regular garage
door. You am t see that there are sections be
cause with our new design [we have a paten I on

26 vw •• Ham It C.J;.JC" Sprr-q .

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Page

Now in Bethesda...

this|, you can't see theseams. Also, the door has

been made pinch proof.
Auto Wash
WH&G.Js <i Irenchl'orte door as sturdy as a
& Detailing
premium care for your automobile. ^^
regular wooden door'/

It may look fragile, but what makes it such a

good door is that it is made of polycarbonate
and aluminum. The polvcaiuoiiaie panes are
like bullet-proof plastic. The aluminum is
light, strong and needs no upkeep because it's
powdi-i i ii.ited rCM
WHkG: What about priuny?

The pr.hv.irbenate panes are lightlv hosted t<>i

pnxacs. Irons the cum, !iie\ look trauspaicnt. Save on our most popular package:
but the closei you get. the. hcvwme translucent.
From inside, it's beautiful. You have this stream
Premium Hand Wash,
of natural light coming in. It makes the sur Vacuum & Wax Service
roundings inside bright andseems to keep musti-
ness down. An added perk in winter is the door's • Handwash &chamois dry
• Moderate tar/Bug removal just
passive solar value. • Interior vacuum plus basic cleaning
dash, doors, front panels &mats
• Wipe door laT.ns
WH&ii: Are your doois more expensive titan • Clean windows & mirro'S
• Clean wheels &dress tires Trucks/Vans/SUVs
regulargarage doors.' • Premium hand wax ^ slightly higher >

As far as expense goes, we've kept the price very

competitive. Atraditional garage door runsabout Gift Certificates Available!
The Perfect GiftFor Friends, Family and Co-workers!
S 100b. Ours run about 52200 tor a single.

WH&G: What about im existing garage

door opener? Or choose to save with

Our door just pops into the existing track and

uses the existing openei. You can keep your
overhead remote.
$35 Off
A Complete Detail Service
WIl&G: Do vnu have more than one style? Just bring in this ad!

< urrently. we are offering three styles: the

Keiulra and the Madeline are named for our
Auto Detailers
daughters, fhe third style is the Jennifer—that's of Bethesda
me! We now have a number ol design and utililv 7909 Woodmont Ave.
patents for more designs. # 301.652.2912
Visit Asia Dtlafim »fBt!itl)l tar jsnplete sllei tali. Sjldlll cirislti csmbbid voltliSirotitis.

'.(.rinaioo? | •.V„.i.;.'.'<,Vii Una:-, h <„ii;t~n 27

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Page

Exhibit I
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Page

-3CM : Uaring Design, Inc. FAX NO. : 410 528 8758 Sep. 1? 2001 ai:i8Ptt P2

cy
,V
\o~ La
\o r^

Disclosure Agreement

<A ()ouJcK.
This disclosure agreement is entered into this 4th day ofSeptember 2001, between Innovati:weDes
Design
Solutions, Inc. ("IDS") having offices at 34233 Homestead Road. Gumee. IL 60031
and Mr. &Mrs. Ken Maher (French Port) CMAHER") having offices at:
MAHER may disclose CONFIDENTIAL INFORMATION to IDS in connection with companies review or
evaluation of the newor novel conceptspecifically described below ("Concept"). SuchCONFIDENTIAL
INFORMATION and/or CONCEPT of MAHER constitutes the property of MAHER and are "Trade Secrets"
as defined in the Illinois Trade Secrets Act or its successors.

Product description:

FRENCH PORT DOORS - Constructed out of 1 54" wood or other material with frosted panes of %"
l\
\ ^_\ polycarbonate or other material inserted and arranged ina way to give the appearance of French
Doors in place ofthe garagedoor while retaining the ability to function in the same way as a standard
garage door.

cLOr^C**^ Y)<ky^<~
JJ2§, agrees that it will keep the above said CONFIDENTIAL INFORMATION and/or CONCEPT confidential
and will not discloseitto any other partyor use itfor companies own benefit without the prior written
consent of MAHER.

g_ IDS has on-going R&D and product development activities. Ifa concept disclosed to IDS is similarto
V concept in development by IDS, then IDS will notify MAHER at the time of disclosure. In the event that a
a\<-. disclosure by MAHER is similar to product concept in development by IDS, then IDSwill be under no
obligation of confidentiality.

%/7-q/ Innovative Design Solutions. Inc.

Company

7'/?^/ French Port

Mrfor'Mrs. Ken Maher*" Date Company
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Exhibit J
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Page I of 1

From: Jim Waring

To: KennethMaher; jenmarri
Date: 1/16/2002 2:47:54 PM
Subject: Prototype Pic's

Jennifer,
Please find attached photos ofthe FrenchPorte garage door. The door is completed with the
exception ofthe PolyCarb inserts. Ihave contacted another piastics vendor to get things moving Iam
being told that the plastic will not be received for another five business days. Iapologize for the'
inconvenience.
When 1get this plastic in it should take less then an aday-to-instal! all-ofthe panes ofplastic and
package them for shipping. Iwill then send it COD using acommon carrier to your Chew Chase
address. The brake down for the final balance is as follows:

$9,060.00 Total quoted amount

Ina, ,. $8,154.00 Total quoted amount with applied
10% discount K
$5,134.00 Total outstanding less deposit
Iwill give you acall when Ihave more information on the shipping schedule. Ialso left amessage
with Charles Fallow giving him all ofthe details ofthe prototype and told him ifhe had any other
questions to give me a call.

Ifyou have any questions for me feel free to give me a call any time.
Best Regards,
Jim Waring
Innovative Design Solutions, Inc.

cc: Ken Maher

lile://C:\WlNDOWS\TKMP\HLP3312.TMP 1/28/2002
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Exhibit K
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Innovative Design Solutions. Inc.

invoice
34233 Homestead Road
Gurnce, 1L 60031 Date Invoice #

1/28/2002 128016

Bill To

Frenchport
: Kenneth Mahcr
.4015 Oliver Street
' Chew Chase MD 20815

Description Amount

Full Scale FrcnchPorte Garage Door M 34.00

Total $5,134.00
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Exhibit L
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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 seriesof French doors, but operating as a traditional overhead garage door.

Thecompany 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 theaesthetic 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 inthe 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 companycalled 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 theFrenchPorte garage door in animated action and received a lotinterest.
However, with the actualdoors on display, the attendees that visited the boothwere very excited
and interested in the garage door and the data basecreated by visits to the booth wasjust over
1,000 entries.

Significant interest was also shown by Overhead DoorCorporation, 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 relationshipwith each of them.

Thedisplay booth alsocaught 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 selectedFrenchPorte Garage Door as one of the products. HGTV interviewed and video
taped Jennifer Maher for a segment to be aired on one of theirshows aboutthe concept and
design of the FrenchPorte Garage Door. Once the spotwas aired on HGTV inquiries from
potential customers started rolling in as to how to obtain the doorand at whatprice.
 2:21-cv-02014-CSB-EIL
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3 3 of 3 PageID# 47

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.
 2:21-cv-02014-CSB-EIL
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17 1 of 17 PageID# 48

Exhibit M
 2:21-cv-02014-CSB-EIL
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17 2 of 17 PageID# 49

-fl^l Jl. ipi§

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WWW.RAYN0R.COM
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17 3 of 17 PageID# 50

..f--;*"-*1

"StyfeViewxl<iorsiiriafl':
^x<xlleintjcombination^i\ '
! . '• I V.',''' •-'" •*fcissis7.:.j •-..

•configprqiiohiaptiojispfs^
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•omplement the
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offers arehitectu ral! flexibiIity; hiaxirtiumivisibiIity and* -extreme
durability in a maihtenanee-free aluminum door. The Custom
Profile, Wide Profile and Narrow Profile models feature a series
of unprecedented desighs, arehiteetural glass options and; 1:87
ArmorBrite™ color finishes for showcasing a home's unique flair.i
From modern styles to classic facades, StyleView is the choice
for achieving§;contemporary=look'0Raeeentuating:the,design of
^*aihlilier?ftsiclerice•; '^^^^^^^^^^MS-
 2:21-cv-02014-CSB-EIL
Case 1:13-cv-00638-TSE-IDD
WSgSgB^^»!SS#S^:S^,-^^rf--,'^:
Custom Profile,Carriage House,
1 car, ArmorBrite White
Wide Profile, 2 car,
Clear Anodized
Narrow Profile, 1 car,
ArmorBrite White
Document 1-13# Filed
1-15 05/28/13
Page 4 ofPage
17 4 of 17 PageID# 51
CUSTOM Pi
An ideal complement to modern, conventional and rustic styles, the Custom
Profile model is a 2" thick rail and stile door with a standard jointseal.
Engineered for resilience and exceptional beauty, the Custom Profile model
offers a maintenance-free alternative to steel and wood carriage house doors
and is available in 187 ArmorBrite™ color matched aluminum panels to
correspond with the window scheme or architectural design of your home's
facade.
Myou; are looking for a heavy-duty door that will^ sjihance your home's
panache or timeless architecture, the Wide Profile model is the answer.
Designed for both strength and durability, the 2" thick Wide Profile door
features rail and stile construction with a standard joint seal. This model offers
optional 187 ArmorBrite™ exterior finishes and optional white or black
EnduraCote™ hardware. And, for added design flexibility, the Wide Profile
model is also available with window thicknesses ranging from 1/8" to 1/2" in
various glass types, including frosted, laminate, reflective, satin, tinted,
tempered, acrylic and insulated.
NARROW PROFILE
Accented with a streamlined design, the Narrow Profile model is a 1-3/4" thick
door with a ship lap section joint and standard joint seal. This model'is a
maintenance-free solution for your garage djsor needs with 18?ArmorBrite™
exterior finishes and optional white or black EnduraCote™ hardware. In
addition, Narrow Profile doors feature architectural variation with multiple
glass options for contemporary and traditional styles alike. The offering
includes thicknesses ranging from 1/8" to 1/2" in various glass types,
including frosted, laminate, reflective, satin, tinted, tempered, acrylic and
insulated. ->
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CustomCarriage HouseBi-Fold, ArmorBrite beige rails, ArmorBrite matched panels,2 over2 tempered clearpane

StyleView Custom Profile Carriage House doors feature architectural grandeurwithout the maintenance concerns
of a typicalwood door. The Swing-Up, Swing-Out, Accordion and Bi-Fold designs can be modified to meet the
aesthetics of your homebyselecting from 187 ArmorBrite™ color finishes and numerous glass and batten options.
And, for addedstyle, choose betweentrueandsimulated divided lites invarious pane configurations.

CUSTOM CARRIAGE HOUSE SPECIFICATIONS

Poor Width Door Height 1 Section I Section I Door Styles I Window Designs l Glass
••Thickness I. joint I I I; Thickness
4'-20' 6'-10' Tongue& Swing-Up, 1 Pane, 2 Pane, 1/8",3/16",
Groove Swing-Out, 3 Pane, 4 Pane, 1/4", 1/2"
Accordion, 2 over 2, 3 over 3,
Bi-Fold 4 over 4, Prairie
3 L
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r^
RAYNOR
Top Section
OPTIONAL HEADER SEAL
2" 7 feet high illustrations shown
r^U- WINDOW SWING-UP
1 ' '-' ~ .....„.„
^sifa'

•Tpf)
OPTIONS 1 ! !
II i
fL 1
1
1
-1
5-1/4" TOP RAIL II flJ
1 pane

SWING-OUT
DI •,
2 pane n~x _ .hid™
u un 1:1111
no batten 1 batten 2 batten 3 batten
GLASS OPTIONS
SEE SPECIFICATIONS
im
BELOW 3 pane
rrhh' fr raini rajin
1 LU _L U_ ffi
1-1/2" [
I
miMLL no batten 1 batten 2 batten

4 pane ACGORDIQNi
3-13/16" MEETING
\ 2-5/16" < RAIL 31 o
" L._. J fflBE BE
2" JOINT
2 over 2 pane a
BULB T batten 1 batten
SEAL
fflffifflffl BI-FOLD
2 over 2 pane

R Dm TTT
EflEB dill
it
1 batten
_JL
no batten
I !.
1 batten
3 over 3 pane
nnrn

5-1/4" BOTTOM RAIL

BfflE \Wr tat
no batten
ID n u
4 over 4 pane 2 batten 3 batten

OCT nin
-3" VINYL ASTRAGAL Prairie (Simulated Only)

1-7/16"
6-1/2" 3-5/8" - 6-3/4" 6-1/2"

6" END STILE

2" SECTION THICKNESS
2-5/6" BATTEN 5-3/4" CENTER STILE 1" BATTEN 7/16" BATTEN 6" END STILE

Glass Typi End Stile I Center Stile I Batten Width Track/Hardware I Warranty
Width I Width Finish I
J!
• Clear, !i 6"VWde Std •' ?r3/4B Std; ! 7/1£aStd, !|AnbdbeiRhfehes, ;! Galvanbed, -See Page 14
Laminate,Acrylic, 2-5/8" Std TOpt, 187 ArmorBrite EnduraGote White,
Insulated, Reflective, 2-5/8" Opt Colors EnduraCote Black
Tinted, Frosted, Satin
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17 7 of 17 PageID# 54

Custom Millcreek,single car with panels, ArmorBritegray with satin glass

A perfect alternative to standard steel doors,StyleView Custom Profile Mixed Panel designs offer a distinctive
look for your home. By utilizing various panel spacing options, the Mixed Panel model will differentiate your
garagedoor from others in your neighborhood. Featuring 187ArmorBrite™ finishes and a varietyof glass
options, StyleView Custom Mixed Panel doors complement the individuality of your residence.

4'-16' &-W 2" Tongue & See Elevation Chart 1 Pane l/8",3/16",
Groove 1/4", 1/2"
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RAYNOR
OPTIONAL HEADER SEAL
7 feet high illustrations shown

•r - 'vr-—A
:• i r
4-3/4" n UL_U- ""'"TT
JI
...jLt;: ii _ J J

5-1/4" TOP RAIL Mlllcreek Mjllcreek Summitreef Summitreef

with panels with panels
n i II JDZZDJ ocno
7D
::n:::LB r:±::i: :i
Ridgelake Bridgeport Shoreland
GLASS OPTIONS
SEE SPECIFICATIONS
•nizrri ;:.ttti
BELOW
IriHn
Ridgelake with panels Bridgeport with panels Shoreland with panels
1-1/2"
.£=3 I
3-13/16" MEETING
XLJ il 1 1.
2-5/16" RAIL n: IX JJXIO il II 1 i 11
. t I
it: L luixi !| II 1 ! : 1
Edgewater Baypoint Highcrest
2- JOINT
BULB "1"
^J.
j; " T1|^
lj^^ OpOC; 1 1 ;| 11 \ T
SEAL
" J •m
tat: \h t o
l.
:l:iJ , 1J
Edgewater with panels Baypoiritwith panels Highcrest with panels
Bottom
Section I I- JL^J -- -Ii... J: |t J EZDl DlZI lZXDTltzi
.on:
nooEzrrn LJIXimL:.]
Springfield Brookview Riverside
4-3/4" 5-1/4" BOTTOM RAIL
LZJOZXEZ] mnnmri
["] J \- "TTT'I [-JDZJOCU l.ULI U IIIi
i" _ ;nr':r r r

Springfield with panels Brookview with panels Riverside with panels

3" VINYL ASTRAGAL
All options available with ArmorBrite color matched aluminum orglass panels.
- 3-3/8" - 3-5/8" - - 6-1/2"

2* SECTION THICKNESS
! i

- 6" END STILE

2-7/8" END STILE 2-5/8" CENTER STILE

Glass Type End Stile I Center Stile I BattenWidth Track/Hardware I Warranty

Width 1 w'dth I Finish I
Clear; Laminate, 6"wlde std i'S/a" std Not Ahodlze Finishes, '. '""• Galvanized, See Page 14
Acrylic, Insulated, Available 187 ArmorBrite EnduraCote White,
Reflective.Tinted, Colors EnduraCote Black
Frosted, Satin
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17 9 of 17 PageID# 56
:.]'.

Custom FrenchView, single car,ArmorBrite white with blacktinted 1/8" tempered glas:

The epitome of sophistication, the StyleView Custom Profile French View model isjustthe thing for homeowners
that are looking for something beyond traditional, carriage house and contemporarydesigns. Available in 187
ArmorBrite™ finishes and anassortmentof glass options,these doors offerbalance betweenwindowand entry
architecture. Select StyleView Custom Profile French View doors and makeanexquisite entrance out of your
garage door today.

CUSTOM FRENCH VIEW SPECIFICATIONS

Door Width Door Height , Section I Section I Door Styles I Window Designs I Glass •
iThickness I Jojnt I I I Thickness^
4'-20' &-101 Tongue& Not 2 Pane, 3 Pane, 1/8°,3/16",
Groove Available 4 Pane, 2 Over 2, 1/4", 1/2"
3 Over 3,4 Over 4
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Page 10 of 17 10 of 17 PageID# 57
Page

RAYNOR
OPTIONAL
HEADER SEAL
7 feet high illustrations shown S'V^-fe/^v1 •: • '_ .•

SINGLE CAR

.mm LUJ 1 I LTJUJLTJ

5-1/4" TOP RAIL mm. JLJL mm mi imm
i i ii i i llllilll mm in mmm
2 panel, 2 pane 2 panel, 3 pane 2 panel, 4 pane 3 panel, 2 pane
fin
; ~i—ri
1 1 1 II 1 1
1 1 llll tffl
•II
il1 11
1
1
—J— T\
i llll 1
1 1 1 II II
rrnn—n
1 1
~rTT" I a i
GLASS OPTIONS
SEE SPECIFICATIONS
H—M 1 11 Hill j+itfj+n: e B
BELOW 2pane|, 2 panel, 2 panel, 3 panel,
2 over 2 pane 3 over 3 pane 4 over 4 pane 2 over 2 pane
DOUBLE CAR

3-13/16" MEETING mm mm mmmmm mmmmmm

2-5/16" i RAIL
.mmmm. mmmmm. mmmmmm
mm mm mmmmm mmmmmm
2" JOINT 4 panel, 2 pane 5 panel, 2 pane 6 panel, 2 pane
BULB
SEAL

BfflfflB BH BfflB mmm™

SH Bffi Bfflffl
Bottom f HEafflBH E H3
Section 4 panel, 2 over 2 pane 5 panel, 2 over 2 pane 6 panel, 2 over 2 pane
M l 11111111111111
ldltdhelid: LTfflmillDLTLT] iiii irnTii 1111
11111 r r m 1111i r r m
n fflLTDDII nTnTTTTinTnrrm nTrl mTITTTtl rTTTI
4-3/4" 5-1/4" BOTTOM RAIL i i i i irrrni l i t n 1111
m m nri in IIID OID LTED LTLT] llll irTTTil M III lj 11
4 panel, 3 pane 4 panel, 4 pane 4 panel, 4 over 4 pane
est J
XX
^3" VINYL ASTRAGAL

1-7/16" 1-7/16"

6-1/2" 6-3/4" 6-1/2"

! I a.

- 6" END STILE - - 6" END STILE

2" SECTION THICKNESS 7/16" BATTEN 5-3/4" CENTER STILE 7/16" BATTEN

..-., ..,,v.^T^.....^r.,,-. .*.w^.«; J* *.«J* _!:...••».!!:•, r.-^r^KS';" • • •' vrr^^^^r:-. -'' .."•• ";• •"• f\imJi ." "."• ™ •FT*""#^"
* •' ' • • . "

Glass Type 1 End Stile Center Stile Finish 1 Track/Hardware Warranty

1 Width Width 1 Finish

Glear, Laminate, Acrylic, 16°^rlde$td ' sWstd Anodfee Finishes, Galvanized, See Page 14
Insulated, Reflective, 187 ArmorBrite EnduraCote White,
Tinted, Frosted, Satin Colors EnduraCote Black
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Page 11 of 17 11 of 17 PageID# 58
Page

Wide Profile, double car, ArmorBrite white rails with 1/8" satin glass

If you are looking for aheavy-duty door that will enhance your home's panache or timeless architecture,theWide
Profile model Is the answer. Designed for both strength and durability, the 2" thickWide Profile door features rail
and stile construction with astandard joint seal. This model also offers 187 ArmorBrite™ exterior finish options
and optional white or black EnduraCote™ hardware. And,for added design flexibility, the Wide Profile model is
also available with window thicknesses ranging from 1/8" to 1/2", in various glass types, including frosted,
laminate, reflective, satin,tinted, tempered, acrylic, clear and insulated.

WIDE PROFILE SPECIFICATIONS

•• .- • .

Ijjr DoorWidth Door Height 1 Section Section Door Styles Window Designs : Glass §
1 Thickness Joint
I Thickness x
4'-2d' 6'-10' 2" 1Tongue& Not 1 Pane 1/8",3/16",
Groove Available 1/4", 1/2"
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Page 12 of 17 12 of 17 PageID# 59
Page

RAYNOR
OPTIONAL
HEADER SEAL
7 feet high illustrations shown

SINGLECAR

J 1 -1
5-1/4" TOP RAIL E a i 1 11
II
! "1
singlecar, 4'0"to 9'2", 2 paneldesign

rimm
GLASS OPTIONS CZUZUCZ] CZHZDCU 1 T V '
SEE SPECIFICATIONS
BELOW
EZEZIEZI. i . — a..
! '1
nnn
single car,9'3" to 12'2", 3 panel design

3/16" MEETING DCJtJBLECAR

2-5/16" i RAIL
T- 1 1 II 1 1 II 1
4 1 i ji
1 !„ , •„«'„ ,1
X 1 j: ' i 1 JI 11. 1 1
x~ir~Ti r, \ • -ii ir - •I ,f V 1

! • LULU , .ii. l:.l::i_":xi"jl_ j ummm—j:

t rim "ir~ CXlfTTI
L i ii i ir T~~T J _ L I .
1 . L_Jt 1 ii t ;i _JL... ILJL_.u. T
double car,12'3" to 20'0", 4 &5 paneldesigns
4-3/4" 5-1/4" BOTTOM RAIL All options available with ArmorBrite color matched aluminumor glass panels.

XX

- 6" END STILE -

2-7/8" END STILE 2-5/8" CENTER STILE
2" SECTION THICKNESS

Clear, Laminate, 2-7/8" Std, ! 2-5/8" Std Not Anodize Finishes, ' Galvanized, : See Page 14
Acryliclnsulated, 6"Wide Opt Available 187ArmorBrite EnduraCoteWhite,
Reflective.Tinted, Colors EnduraCote Black
Frosted, Satin
10
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Page

Narrow Profile, single car, ArmorBrite white rails with 1/8" tempered black glass

Accented with astreamlined design, the Narrow Profile model Is a1-3/4" thick door with aship lap section joint
and standard joint seal. This model is amalntenence-free solution for your garage door needs with 187
ArmorBrite™ exterior finishes and optional whiteorblack EnduraCote™ hardware. In addition, Narrow Profile
doors feature architectural variation with multiple glass options for contemporary and traditional styles alike. The
offering Includes thicknesses ranging from 1/8" tempered to 1/2" Insulated In various glass types, Including
frosted, laminate, reflective, tinted, satin,clear, acrylic and insulated.

NARROW PROFILE SPECIFICATIONS

Door Width Door Height Section I Section. I Door Styles I Window Designs I Glass
Thickness I Joint I I I r^-.r.i^
Thickness:

4'-16' 6'-10' 1-3/4" Ship-Lap Not 1Pane 1/8°, 3/16",

Available 1/4", 1/2"

.. L
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Page

RAYNOR
Top Section
OPTIONAL HEADER SEAL
7 feet high illustrations shown
''^^^^mm^.
75*Ssw-i
SINGLE CAR

5*16" TOP RAIL

1 ! 1 r~~~r ! i
1 nzz J I r—f
1 ( 1 1 -i L B
[ i 1 ^3 i r—r
singlecar,4'0° to 9'2°, 2 panel design

CZEHZ] 72
GLASS OPTIONS H_Jl_Jl I :•••
SEE SPECIFICATIONS
Section Joint
BELOW nirjizn
1-3/4'
LJLJCT "1
singlecar, 9'3" to 12'2", 3 panel design
3-1/4-MEETING

P^MBliCAR
I I I: . 1 1 « « 1
I J 1 i 8 S i u r •.«-. I § 1
j . I fc :••-•• ir^
—"1 i ----- i i-Jj j—Jh^^+H

.1 IE II II 1! ... [' T " i" ^ i—ir- ii ii " 1 1

Bottom 1 II II II II 1 II II ! ir - i -J--"!!'"' ::
"" ""IT
Section :ujo-Jl II li r:: ][.." .J!...:; . . li n .1.._!' Tl
l._JL. .11 li II ! Jl . .i . : r i: JL... i 1: .1
doublecar12'3" to 16'0". 4 &5 panel designs
5-3/16- BOTTOM RAIL
All optionsavailable with ArmorBrite color matchedaluminum orglass panels.

.. _ ^
^3" VINYL ASTRAGAL

- 3-3/B- -

Glass Type End Stile I Center Stile I Batten Width Track/Hardware Warranty
Width I Width I Finish

Clear, Laminate, 2*7/8"Std, I^Std Mot Anodlzefinishes, Galvanized, See Page T4

Acrylic Insulated, 6" Opt Available 187 ArmorBrite EnduraCote White,
RefIective,Tinted, Colors EnduraCote Black
Frosted, Satin
12
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Page 15 of 17 15 of 17 PageID# 62
Page

SS««i»«^'S*:^
.^aoaem^^^
Glass Options

^irti

Glazingoptions range in thicknesses including 1/8" ,3/16", 1/4" and 1/2" insulated

ArmorBrite™ Color System For a clean, finished look and

maximum protection against rust,

StyleView doors are available with
a powdercoated hardware system.
The EnduraCote™ Hardware

System features extended-life

torsion springs and powdercoated
hardware. Nylon rollers with steel
ball bearings also help to provide
Choose from over 187 Raynor ArmorBrite™ colors.
superior noise reduction.

Anodized Finish Options EnduraCote™ Track & Hardware

Galvanized

Low-E Glass Also Available

Dark Bronze
Low-e glass is the
perfect solution
for long-term White
exposure to high
Extra Dark Bronze Black temperatures by
allowing full
visibility,while
providing a
barrier from the
sun. Low-e glass Black
Light Bronze Clear Anodize is only available
for StyleView
doors with
insulated glass.

Medium Bronze Champagne

13
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Page

Mug
RAYNOR

\ Door Sections: ArmorBrite™:

' Raynor warrants St^eVlewdoor sec^ons against defects In Raynor warrants^Stylevlewirsecflpns.p^nted with ArmorBrite
I material andwdnVmarKhlp, for rte origin powdercoat finishes against ca^Ingipri^IhgforrWetSJyears
\ As YouOwn Your Home* from the datedfdelivery.to theortglnalipurchaser.
! Window Components: Galvanized Hardware&Springs:
| Window componentsate warranted against defects Inrnaterlal Raynor waitants all galvanized hardware andspring components
I and workmanship for three (3ty^ against defects In material andworkmanship for five (5) years
i theorlglnalipurchaser. from the date ofdellveryto^the original purchaser.
EnduraCote™ Hardware &Springs:
; Raynorwanraittsdll^ *M warfare d ^
1 agalnft defectIn material and wor^
i purthasfer,for*AsLflng As Ybudwn Your Home"
'''immmmmmmitmmmmmmfmmmm mmmmmmmm mmmmm. mmmmmmmmmmm

Raynor Prodigy - Offering Space-Saving Operation

DC Motor, Jackshaft Operation
Raynor Prodigy offers an exceptional solutionforStyleView garage doors. StyleView
doors provide full-view capabilities andthe Prodigy opener ensures your garage
dooropenerwon'tclutter the view. Itmounts easily on the wall beside the garage
doorand comeswith a remote2-port, 100-watt light that can be positioned
anywhere in the garage.

Each unitcomesstandard with a 3-buttonpremium remotecontrol with rolling code

security technology. Smart Control Panel™ and 200watts of lighting for brighter
illumination.

Lifetime Motor Warranty - 5 Year Parts

Raynor Ultra - the Perfect Match for Your StyleView Door

3/4 Horsepower, Chain Operation
Designed to handleeventhe heaviest StyleView doors, the
Raynor Ultra combines a 3/4 hp motor with a rugged I-beam rail
and chassis support foradded strengthand reliable operation. A
dual-drive sprocket allows the opener's speedto be adjusted to
optimize door and opener performance.

Each unitcomes standard with a 3-button premium remotecontrolwith

rolling code securitytechnology,Smart ControlPanel™ and 200watts of
lighting for brighter illumination.

Lifetime MotorWarranty - 5 Year Parts

14
 2:21-cv-02014-CSB-EIL
Case 1:13-cv-00638-TSE-IDD Document 1-13# Filed
1-15 05/28/13
Page 17 of 17 17 of 17 PageID# 64
Page

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1-800-4-RAYNOR (472-9667)

Raynor Worldwide
P.O.Box 448,1101 East River Road
Dixon, IL 61021-0448

WWW.RAYNOR.COM

©Raynor 2009 •-*«&.-„

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